Data Protection at Detention Action
Detention Action is a national charity (no. 1198554) that aims to change the way that migrants are treated by immigration detention policy in the UK. We defend the rights and improve the welfare of people in detention by combining support for individuals with campaigning for policy change.
Detention Action is committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and we want to ensure that you feel comfortable with our data and privacy processes. This Privacy Notice sets out how we collect, use and store your personal data (information that identifies or could identify you).
For the purposes of GDPR, we are a “data controller” which means that we are responsible for determining the purposes and means of processing your personal information. For the delivery of our services we may rely on “data processors”, such as email delivery platforms. These “data processors” will be responsible for processing your data and will not share your data unless you have given them express consent to do so.
We only collect and process data which is necessary to support our aims, and we only keep this data for as long as is reasonable and necessary for the relevant activity for which it was collected.
Third parties will only have access to this data if it is necessary to our work, and they are contracted to provide a service to Detention Action, such as accounting or IT support. These third parties will also have a Data Processing Agreement with us, which means that they must comply with data protection legislation and only process your data as instructed by us.
No other third parties will be able to access your personal data without your consent, unless the law allows them to do so.
What are your rights?
You retain your rights to the personal information that we hold about you. These include the right to:
- be informed about the collection of your data, how it is used and how long we keep this data;
- request a copy of the personal information that we hold about you, and information about why we use it, who we share it with and how long we keep it;
- object to your data being processed and/or to the way in which we process your personal information;
- withdraw your consent at any time;
- ask us to rectify any inaccurate or incomplete personal information about you;
- ask us to delete your personal information if you have withdrawn consent or we have no lawful basis for keeping it;
- (if you are on our mailing list) ask us to transfer your personal data directly to another data controller.
You can exercise any of these rights, make a complaint or request more information about our privacy processes (such as the purpose, lawful basis and retention period of data we collect, and to which third parties this data may be transferred) by emailing privacy@detentionaction.org.uk or calling 020 7062 4211 (option 2) and asking to speak to the person responsible for data protection.
Please review the sections below for more information on data related to specific persons.
What data we process and why
As a service user, Detention Action will ask you for personal information like your name, phone number, email address, and some reference numbers. This is so that we can contact you.
We often also ask you about your history and your situation now. This includes asking about your health and if you have any criminal convictions. Sometimes you might ask us to contact other organisations or people on your behalf and they may give us information about you. We may ask you about other personal information, and you may also choose to tell us other information, but you don’t need to give us any information that you don’t want to.
We ask you for this information so that we can understand your situation and how we can support you, and also to see if there are any other organisations who can support you. This information also helps us to understand and monitor what is happening in detention and when people are released so that we can try to change the system for everyone. We also keep your information so that we can show we have acted appropriately as a charity and to monitor and evaluate our services.
We keep information both on our computer systems and in written paper files. We keep your information confidential and make sure that it is kept securely. We do not share your information outside of Detention Action without your agreement, unless you tell us that you want to seriously harm yourself or to hurt someone else, in which case we must tell the detention centre or prison about this.
How long we keep this data
We keep your information for as long as we are supporting you, and then for 6 years after our last contact with you. After that, we delete your information. This is to allow us to show that we supported you appropriately as part of our organisation’s charitable aims.
What data we process and why
As a client, Detention Action will ask you for personal information like your name, phone number, email address, and some reference numbers. This is so that we can contact you.
We often also ask you about your history and your situation now. This includes asking about your health and if you have any criminal convictions. Sometimes you might ask us to contact other organisations or people on your behalf and they may give us information about you. We may ask you about other personal information, and you may also choose to tell us other information, but you don’t need to give us any information that you don’t want to.
We ask you for this information so that we can understand your situation and how we can support you, and also to see if there are any other organisations who can support you. This information also helps us to understand and monitor what is happening in detention and when people are released so that we can try to change the system for everyone. We also keep your information so that we can show we have acted appropriately as a charity and to monitor and evaluate our services.
We keep information both on our computer systems and in written paper files. We keep your information confidential and make sure that it is kept securely. We do not share your information outside of Detention Action without your agreement.
How long we keep this data
We keep your information for as long as we are supporting you, and then for 6 years after our last contact with you. After that, we delete your information. This is to allow us to show that we supported you appropriately as part of our organisation’s charitable aims.
What data we process and why
Detention Action processes the personal data that you provide as part of engaging you as a consultant or contractor. This includes information you provide in your communications with us prior to engagement with us. This may also include sensitive information, for example about your health, if you choose to disclose such information to us. We need to know this information so that we can communicate with you about your engagement with Detention Action. We will not keep any personal data from you that we do not need in relation to your engagement by us.
While you are engaged by us, we also process data we require from you for financial purposes, such as making payments to you.
How long we keep this data
We will keep your data for the term of our engagement agreement with you, and then for 6 years from the end of the financial year in which you stop working with us. This is to allow us to comply with our legal and financial obligations.
What data we process and why
If you make a monetary donation to Detention Action, we may collect certain information via a third party donation platform such as Engaging Networks. This information will include the data needed to process the donation and associated actions such as Gift Aid. This data will not be used for other purposes, such as news updates, unless you have given your express consent for this.
How long we keep this data
In line with financial regulations, we will keep a record of your donation for 6 years from the end of the financial year in which it was made.
What data we process and why
Detention Action processes the personal data that you provide as part of the recruitment process to become an employee. This includes information you provide in your application form, at interview, as part of a pre-interview task, and any information provided by your referee(s). This may include sensitive information, for example about your health, if you choose to disclose such information to us.
We need to know this information so that we can communicate with you about the recruitment process and working at Detention Action. We will not keep any personal data from you that we do not need as part of the recruitment process.
While you are working with us, we also process personal data you give us through the supervision and support we provide for you. It is important that we process this data so that we can communicate with you and support and supervise you effectively, as well as so that we can continue to develop and improve how we manage employees. If you ask us to be a referee, we will also need this data to provide a reference for you.
In addition, throughout your employment, we process any data required for payroll or tax purposes, so we can enrol you in the appropriate payroll, tax, and pension processes.
How long we keep this data
We will keep your data for as long as you remain an employee with us, and then for 6 years from the end of the financial year in which you stop working with us. This is to allow us to comply with our legal and financial obligations.
What data we process and why
Detention Action processes the personal data that you provide as part of the recruitment process for any given role. This includes information you provide in your application form and throughout the recruitment process, such as during an interview or for a pre-interview task, or information provided by your referee. This may include sensitive information, for example about your health, if you choose to disclose such information to us.
We need to know this information so that we can communicate with you about the recruitment process and working for Detention Action. We will not keep any personal data from you that we do not need as part of the recruitment process. Only the person administering the recruitment and individuals on the recruitment panel will have access to your application.
Detention Action operates a blind recruitment process, so your personal details will only be shared with the recruitment panel if you are invited to interview.
How long we keep this data
- If you are not invited to an interview, your application will be archived then deleted 6 months after the finalisation of the recruitment in which you participated.
- If you are invited for an interview, we keep your application for 1 year after the finalisation of the recruitment in which you participated.
- If you are successful in the recruitment and are employed by us, your application will form part of your employee record (see section on Employees).
What data we process and why
If you sign up for our email newsletter we will ask for your first name, surname and email address. By signing up to our newsletter you will receive roughly one email a month on the latest news and campaigns from Detention Action and issues relating to immigration detention in the UK.
We may also track which pages you visit when you click on links in our emails or other communications, as this helps us to improve our communications work.
You can opt out of these emails at any time by clicking unsubscribe at the bottom of the email or by getting in touch with privacy@detentionaction.org.uk.
How long we keep this data
We will keep your data until you unsubscribe from our mailing list, or ask us to remove you from our supporter database.
What data we process and why
Detention Action processes the personal data that you provide as part of your expression of interest to become a member of the Management Committee. This may include sensitive information, for example about your health, if you choose to disclose such information to us.
We need to know this information so that we can communicate with you about issues pertaining to the Management Committee and the process of joining the committee. We will not keep any personal data from you that we do not need as part of this process.
When you are a member of the Management Committee, we also process any data you give us in accordance with your role, as this ensures transparency between the organisation and the Management Committee, as well as allowing us to communicate with you effectively about any issues relevant to your role.
How long we keep this data
If you express an interest in becoming a member of the Management Committee, we keep your data for a period of 6 months from the time that a decision is reached on whether or not you will be appointed to the Management Committee.
If you are appointed as a member of the Management Committee, we will keep your data for as long as you remain a member, and then for 6 years from the end of the financial year in which you step down from the Management Committee. This is to allow us to comply with our legal and financial obligations.
What data we process and why
Detention Action processes the personal data that you provide as part of the recruitment process for any given role. This includes information you provide in your application form and throughout the recruitment process, such as during an interview, or information provided by your referee. This may include sensitive information, for example about your health, if you choose to disclose such information to us.
We need to know this information so that we can communicate with you about the recruitment process and volunteering with Detention Action. We will not keep any personal data from you that we do not need as part of the recruitment process. Only the person administering the recruitment and individuals on the recruitment panel will have access to your application.
Detention Action operates a blind recruitment process, so your personal details will only be shared with the recruitment panel if you are invited to interview.
How long we keep this data
- If you are not invited to an interview, your application will be archived then deleted 6 months after the finalisation of the recruitment in which you participated.
- If you are invited for an interview, we keep your application for 1 year after the finalisation of the recruitment in which you participated.
- If you are successful in the recruitment and begin volunteering with us, your application will form part of your volunteer record (see section on Volunteers).
What data we process and why
Detention Action processes the personal data that you provide as part of the recruitment process to become a volunteer. This includes information you provide in your application form, at interview, and any information provided by your referee(s). This may include sensitive information, for example about your health, if you choose to disclose such information to us. We need to know this information so that we can communicate with you about volunteering at Detention Action and as part of the recruitment process. We will not keep any personal data from you that we do not need as part of the recruitment process.
While you are volunteering with us, we also process personal data you give us through the supervision and support we provide for you. It is important that we process this data so that we can communicate with you and support and supervise you effectively, as well as so that we can continue to develop and improve how we manage volunteers. If you ask us to be a referee, we will also need this data to provide a reference for you.
How long we keep this data
We will keep your data for as long as you remain a volunteer with us, and then for 6 years from the end of the financial year in which you stop volunteering with us. This is to allow us to comply with our legal and financial obligations.
What data we process and why
For the purposes of GDPR, we are a “data controller” which means that we are responsible for determining the purposes and means of processing your personal information. For the delivery of our services we may rely on “data processors”, such as email delivery platforms. These “data processors” will be responsible for processing your data and will not share your data with third parties unless you have given them express consent to do so.
When you visit our website we gather anonymised browsing information, which includes things like which pages you visit, and how you arrived at the site (via a search engine or social media, for example). This information helps us to improve our website, as well as support our general communications work.
We may use ‘cookies’ which are stored on your computer and allow us to recognise you when you revisit our website and to help us monitor traffic.
How long we keep this data
As all of this data is anonymous, there is no limit to the time that we keep it.