Who We Are
Open Britain Ltd is a company limited by guarantee registered in England and Wales (09641190). It was previously known as The In Campaign limited and operated as ‘Britain Stronger in Europe’, the lead campaign for Remain in the EU Referendum 2016.
Open Britain’s registered address is Millbank Tower, 21-24 Millbank, London, England, SW1P 4QP.
Open Britain’s Purpose
Open Britain's purpose and overall mission is to campaign for a People’s Vote on the final Brexit deal.
Our supporters help us to achieve this in a variety of ways, primarily by:
- Fundraising, donating money, and donating or purchasing goods (such as leaflets, mugs, etc) for sale in Open Britain shops (such as our online shop) in order to support our programme of work.
- Campaigning for change, through signing petitions, writing letters, and taking part in other campaigning actions.
- Volunteering at events and in our offices.
We take active steps to make sure that our supporters are aware of the ways in which they can help us achieve our overall purpose.
What personal data might Open Britain collect about you?
We may collect the following types of personal data: your name, email address, postal address, telephone or mobile number, bank account details to allow our payment processers to process donations, details about payments to and from you and other details of products and services you have purchased from us.
Special Categories of Personal Data
We do not collect "special categories of personal data" about our supporters (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), unless we have your express consent. Clear notices will be provided on application forms for such events so that it is clear what information we need and why we need it.
All special categories of personal data are stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
Why does Open Britain use your personal data?
We may process your personal data for a number of reasons, and Open Britain will only use your personal data where it has an appropriate legal basis, such as: (1) where the processing is in our own legitimate interest; (2) it is in compliance with a legal obligation; (3) it is necessary to perform a contract between us and you; and/or (4) you have consented to our use of your personal data.
1) Legitimate interest:
We may rely on our own legitimate interest to process your personal data for the following reasons:
- To keep a record of donations made and actions taken by our supporters and our communications with them.
- To support volunteers at their events.
- To record campaigning actions by supporters.
- Service administration, such as administering any donations you have made, to confirm receipt of donations (unless you have asked us not to do that), and to say thank you and provide details of how your donations might be used.
- In relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide.
- For internal record keeping, so as to keep a record of your relationship with us.
- To use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries.
- For market research.
- To analyse and improve the activities and content offered by Open Britain website to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
- For the dissemination of relevant information to journalists.
2) Legal obligation:
We may also need to comply with legal requests where disclosure is required or permitted by law. For example, to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing.
We may process your personal data where it is necessary for the performance of a contract with you, such as for completion of transactions you have entered into with Open Britain or the activity or online content you have signed up for.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you make online purchases or donations). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We will only process your personal data for the following reasons with your consent:
- To send you marketing information about our projects, fundraising activities and appeals.
- To invite you to participate in surveys or research about Open Britain or our work.
Data processed outside of the EU
Your data is only processed outside the EU where Open Britain has verified that appropriate standards and safeguards are in place. Open Britain uses NationBuilder as a service provider that operates outside of the EU but they ensure that any transferred personal data remains protected and secure. You can find out more about how NationBuilder keeps data secure here.
When and why we will send you personalised marketing communications
Open Britain will only contact you for marketing purposes, for example to keep you up to date with our work and our campaigns, or let you know of ways in which you can support that work, where we have your consent or we are otherwise allowed to do so.
We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information (post, email, SMS and phone). You can withdraw your consent at any time, and we will not send you marketing material if you tell us that you do not wish to receive it.
How and when we collect personal data about you
Open Britain may collect your personal data in the following circumstances:
When you give it to us DIRECTLY:
You may give us your personal data directly when you make a donation, sign up for one of our events, purchase products from the Open Britain online shop, or when you communicate with us.
When you give it to us INDIRECTLY:
You may give us your personal data indirectly when you sign up at events such as community meetings or street stalls, or via a sponsored petition campaign on a third-party website. These independent third parties will pass your data to Open Britain where you have indicated that you wish to support Open Britain and have given your consent to Open Britain processing your personal data or it is a necessary part of completing a contract with you.
When you access Open Britain's Social Media:
We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn among others, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), Open Britain may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device).
Will Open Britain share your personal data with anyone else?
We will only use your personal data within Open Britain for the purposes for which it was obtained. Open Britain will not, without your consent, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
Open Britain's Suppliers
We may need to share your personal data with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These "data processors" will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing data protection clauses that protect your personal data. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
Facebook and other Social Media Sites
We may also use your email address and phone number to match to your account on Facebook or other social media sites in order to show you Open Britain content while using these services. We only do this where you have opted in to marketing emails or phone calls and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
In addition, we may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Open Britain, and we may then show them Open Britain content. No data we hold about you is retained by the third party.
There are two ways to prevent this use of your data, you can either update your preferences at Open Britain by opting out of the relevant channel of communication or you can do this via the social media site.
Updating your preferences with Open Britain will not guarantee that you never see Open Britain content on social media, since the social media site may select you based on other criteria and without your data having been provided by Open Britain.
How long will Open Britain keep your personal data?
We will hold your personal data on our systems for as long as is necessary for the purposes described above, and in accordance with applicable laws.
Where you contribute material to us, e.g. user generated content or in response to a particular campaign, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
What are your rights?
Where Open Britain relies on your consent to process your personal data, you can withdraw this consent at any time. If you wish to withdraw your consent please contact us via our email or address provided below.
You are entitled, in accordance with applicable law, to object to or request restriction of processing of your personal data, and to request access to, rectification, erasure and portability of your own personal data. The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest. If you are aware of changes or inaccuracies in your personal data you should inform us of such changes so that the personal data may be updated and corrected.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
If you wish to change how we communicate with you, or update the information we hold, then please contact us:
- amend your preferences on our website here.
- email us at email@example.com
- write to us at: Open Britain, Millbank Tower, 21-24 Millbank, London, England, SW1P 4QP.
Additionally, you can opt out of email separately:
- Email - You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from Open Britain.
How long will it take for these changes to be effective?
We endeavour to meet the following service levels where supporters opt-out of receiving marketing information:
- Email - 24 hours from receipt of email
- SMS - 24 hours from receipt of request to opt out
- Telephone - 24 hours from receipt of request to opt out
- Mail - 28 days from receipt of 'do not mail' request. This period is longer than for other channels due to the production times for mailing campaigns, and in most cases, we would expect the change to be effective much more quickly.
How Open Britain keeps your data safe
We ensure that there are appropriate technical controls in place to protect your personal details. Where possible, our online forms use industry standard encryption and our network is protected and routinely monitored.
We undertake regular reviews of who has access to information that we hold to ensure that your personal data is only accessible by appropriately trained staff, volunteers and contractors.
We use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect on our behalf, or have access to. We have a robust partner monitoring framework to ensure these contractual obligations are met.
How to make complaints about this policy or raise privacy concerns
If you would like more information, or have any questions about this policy, please contact our team by email at firstname.lastname@example.org, or write to us at: Open Britain, Millbank Tower, 21-24 Millbank, London, England, SW1P 4QP.
To make a formal complaint about Open Britain's approach to data protection or raise privacy concerns directly with our data protection team, please contact:
Data Protection Team, Open Britain, Millbank Tower, 21-24 Millbank, London, England, SW1P 4QP.
You also have the right to make a complaint direct to the UK's data protection authority, the Information Commissioner's Office (ICO). The ICO can be contacted at: https://ico.org.uk/global/contact-us/
Concerns can be also be logged via the ICO website.
This version was last updated on 22nd May 2018.