Code on Data Protection and Privacy Notice

Action On World Health LLP
Code on Data Protection
Privacy Notice

Introduction

• 1. Action on World Health LLP (“AWH”, "we", “us”, “our” and “ours”)  is an international campaign group committed to reforming the World Health Organisation (WHO). AWH is the data controller. This means that we are responsible for deciding how we hold and use personal data about you.
• 2. AWH is an organization that seeks to protect and promote the autonomous rights of individuals and nations in relation to health: and remains opposed to the introduction by the World Health Organisation (WHO) of a Convention, Agreement or other international instrument on Pandemic Prevention, Preparedness and Response.
• 3. In the UK, Data Protection is governed by the United Kingdom Data Protection Regulation (GDPR) and the Data Protection Act 2018. AWH will be subject to any relevant national laws and regulations: and will comply with any legal requirements.
• 4. This Privacy Policy describes how we collect and process your personal data when you visit or use www.actionwh.org (our “Website”), as well as when you interact with us via telephone, post, email, social media, or by using our Services.

Contact Details

• 5. Our contact details are:-
• a. Registered Address: 7 Bell Yard, London, England, WC2A 2JR
• b. Email: contact@actionwh.org
• 6. Please contact us if you have any questions at: contact@actionwh.org

The Objectives of the AWH

• 7. AWH objective is to promote our aims, objectives, and values at every level of civil society, both nationally and internationally.  AWH will campaign on these issues both nationally and internationally.   AWH is an international campaign group committed to reforming the World Health Organisation (WHO).
• 8. The AWH is seeking your support, affiliation, and financial donations for these objectives.

The types of Personal Data we collect

• 9. AWH may need and retain your first name, last name,address, country of residence, phone number, email, payment information orother contact details or other information as required and/or as provided byyou such as donation amount, currency and messages.
• 10. AWH may process your technical information collected from your computer or mobile device when browsing our Website e.g. your IP address, your location (by country, state and city), device type, browser type, operating system; and information generated about you e.g. information about your visit to our Website, such as the pages you visit, how often you use our Website, problems with our Website, all of which help us to understand your interests.

How we use your Personal Data

• 11. AWH may remain in contact with you for the purposes of encouraging you to maintain support for these objectives. The AWH may communicate with you in order to canvass your opinion on health policy matters, your contact details, for relevant marketing purposes, for capacity building and for your donations and gifts. The AWH will retain information given by you.
• 12. AWH may contact you, including, inter alia by the use of all electronic data, social media, and telecommunications (but not limited to these) for the purposes of our campaigning, informing you of our policies and campaigns, any events (in person or virtual), for fundraising, for petitions, to contact your elected representative, for your use of social media to communicate with others, to complete surveys or other matters.
• 13. AWH is a not a political party, but a campaigning body that seeks to recruit supporters, donors, and volunteers.  It is not a membership organisation but reserves the right to remove any individual from our supporter lists.
• 14. AWH may also use your personal data to ensure we can run our organisation, by enabling you to contact us, browse our Website and donate.
• 15. We also use your personal data where it is necessary to verify your identity and to satisfy legal or regulatory requirements to which we are subject. Further, we use your personal data in order to exercise and protect our legal rights. For example, to detect, prevent and respond to: (i) fraudulent activity and claims; (ii) infringement claims; (iii) violations of law or our terms of purchase; and (iv) to prevent or detect money laundering.  
• 16. We analyse information about your use of and feedback on our Website and organisation to provide an improved experience. We may use your personal data for service testing and development, as well as site analytics.
• 17. We use your personal data to better understand your preferences and to personalise the messages we send to you. This includes sending you information by email and/or telephone and/or post about our organisation, as well as news or events that may be of interest to you.

Lawful bases

• 18. Our lawful bases for collecting or using personal information for campaigning are:
• a. Your Consent
• i. To send you direct marketing communications such as emails, post and telephone calls to inform you of about AWH, seek donations and support, our events or other news that may be of interest you.
  
• b. Our Legitimate interest
• i. For the purposes of, inter alia, to run our organisation such as campaigning, influencing politicians, attending events and seeking donations.
• ii. The AWH processes data with the intention of using it for the broad purpose of our campaigning, and fundraising activities.
• iii. We may use your personal data when we communicate with you, for example, if we are providing information about changes to our terms or if you contact us with questions about our organisation in general. This includes seeking your thoughts and opinions on our organisation; and notifying  you about any changes to our organisation.
• iv. To process your donation.
• v. To protect our organisation.
• c. Compliance with our legal obligations
• i. To process your donation and comply with laws applicable to such donation such as tax laws.

Where we get personal information from

• a. People directly (such as individuals contacting the AWH or by attending an event).
• b. Third parties such as data brokers and publicly available sources such sources include social media.
• c. From information we generate about you during our relationship with you, such as data collected from cookies and other similar technologies which are described in our Cookies Policy.
• 19. AWH may use the data provided expressly and explicitly to us: together with other outside sources (Facebook, Data brokers) to profile you for the purposes of, inter alia, identifying your specific interests, or skill set, interests, campaign interests, for the targeting of issues and for appeals for financial support,  so that we can work together to achieve our objectives.
• 20. AWH does not believe that such profiling, and any decisions that are based on any profiling will have any relevant legal or other significant effects for you.
• 21. AWH will seek further supporters - as we are stronger - the larger we become.

How long we keep information

• 22. This information will be retained for the purpose of campaigning in relation to the reform of the WHO.
• 23. We review our Data Retention policy annually, and whether we still need your information.
• 24. We may need to retain data for financial and tax purposes, for the purpose for which the data was collected, our business requirements, any legal or regulatory obligations to be balanced with your data protection rights.

Who we share information with

• 25. It is sometimes necessary for us to share your information with our data controllers, data processors and those who manage our data and IT systems, our professional and legal advisors, relevant regulatory authorities, and organisations we’re legally obliged to share personal information with.
• 26. We may need to share information with subcontractors and suppliers such as an Email Marketing Platform or Cloud Storage Provider, or an organisation who provide services for events, or with other political entities or with elected representatives or other social media technology providers.

Sharing information outside the UK

• 27. AWH is an international campaign organisation and needs to operate internationally.  Where necessary, we may transfer personal information outside of the UK. When doing so, we will use our best endeavours to comply with the UK GDPR, making sure appropriate safeguards are in place. Such appropriate safeguards include regulator approved standard contractual terms, reliance on adequacy decisions and self-certification mechanisms. These are intended to provide adequate protection of your personal data in accordance with GDPR. For more information on these safeguards or to obtain a copy of such safeguards, please contact us by emailing contact@actionwh.org.

Sharing information outside the UK

• 28. Where we rely on your consent, you may contact us any time, to withdraw such consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. For example, where we rely on your consent for the purposes of sending you direct marketing communications, to which you have given us consent to use and the AWH will remove you from our marketing lists. We will maintain a record of your withdrawal of consent.
• 29. Under data protection law in the United Kingdom, in certain circumstances, you have rights including:
• a. To be informed about the collection and use of your personal data (as described in this Privacy Policy).
• b. Your right of access - You have the right to ask us for copies of your personal data.
• c. Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• d. Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.
• e. Your right to the restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.
• f. Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
• g. Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
• h. Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.
• You don’t usually need to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
  
  We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.  
  
  If you make a request, we have one calendar month to respond to you. This may be extended by up to 2 months where the request is complex or have received a number of requests from the individual.  
  
  To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

How to complain

• 30. If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
• The ICO’s address:           
  Information Commissioner’s Office
  Wycliffe House
  Water Lane
  Wilmslow
  Cheshire
  SK9 5AF
  Helpline number: 0303 123 1113
  Website: https://www.ico.org.uk/make-a-complaint

Conclusion

• 32. AWH looks forward to working in partnership with you to achieve our objectives to preserve individual and national freedoms and autonomy.
• 33. Any changes we may make to our privacy notice in the future will be updated on our website.

This Policy is dated December 2024