Data Protection Policy
Romanian Children’s Relief (USA)
Fundati Inocenti (Romania)
Last updated June 8, 2018
- Charity – Romanian Children’s Relief, a U.S. based, 501c3 registered charity and/or Fundatia
Inocenti, a registered Romanian Charity.
- GDPR – General Data Protection Regulation (E.U. regulation effective May 25, 2018)
- Responsible Person – Eileen McHenry, Executive Director of Romanian Children’s Relief and Vice
President, Fundatia Inocenti. (firstname.lastname@example.org)
- Register of Systems – Register of all systems or contexts in which personal data is processed by the
1. Data protection principles
The Charity, Romanian Children’s Relief / Fundatia Inocenti, has never sold, and will not ever sell, our supporter database to any third party. The Charity does not share any personal information, including email addresses, phone numbers, postal mail addresses or any other donor information, except for keeping our lists updated and securely password protected on our email server, Constant Contact, or for reporting purposes required by laws of the U.S. government, the European Union, and/or the Romanian Government.
The Charity will occasionally enable an approved third party to process our online donations, such as PayPal, GalantOm or Network for Good, but the Charity does not provide those companies with any information unless the donor voluntarily provides this information directly to the online processing service. Donors of The Charity always have the right to forego using online donation processing services, and can instead send a check, wire, or contact us directly.
Any donor or supporter who wishes to be removed from The Charity email list or from our Constant Contact email list, can do so at any time by either clicking on the “unsubscribe link” at the bottom of each email, or by contacting Eileen McHenry at email@example.com or by calling U.S. 508-303-6299. In Romania, the contact is Valentina Maghirescu at 0751-242282, firstname.lastname@example.org.
The Charity is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals.
- collected for specified, explicit and legitimate purposes of supporting The Charity, and not further processed in a manner that is incompatible with those purposes.
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the
personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”
2. General provisions
- This policy applies to all personal data processed by The Charity.
- The Responsible Person is responsible for the Charity’s ongoing compliance with this policy.
- This policy shall be reviewed and approved by our Boards of Directors at least annually.
- In Europe, Fundatia Inocenti are authorized by the The Romanian National Supervisory Authority For Personal Data Processing.
- In the United States, Romanian Children’s Relief complies with data security requirements for non-profit charities in the State of Massachusetts.
3. Lawful, fair and transparent processing
- To ensure our processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually. The systems are currently:
– excel spreadsheet, password protected, backed up in hard drive.
– Constant Contact, password protected, backed up in cloud based Constant Contact.
- Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- The Charity shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data on Constant Contact.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent appears at the bottom of all newsletters and marketing information sent via our online email system, Constant Contact.
5. Data minimization
- The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Charity will not sell this data to any third party or share this data with any third party.
- The Charity shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
- The Charity currently relies on the U.S. postal service for updating addresses in our direct mail postal database used in the U.S.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy is currently to keep enlisted supporters on the Charity lists until the end user chooses to remove his or her name from our lists.
- The Charity ensures that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security, including password protections, are in place to avoid unauthorized access to information.
- When personal data is deleted this is done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions are in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
10. Webpage / Online / Cookies
The online traffic registered by inocenti.ro and rcr.org webpage is monitored with Google Analytics. It can collect data (anonymous or personal if logged in with a google account) about visits to this Inocenti – RCR webpage.
This policy was edited and approved by the following: (Copies of Approval available upon request.)
Romanian Children’s Relief, Board of Directors, June 8, 2018
Fundatia Inocenti, Board of Directors, June 8, 2018