Privacy Policy


Start Network is hosted by Save the Children UK. You can access the Terms & Conditions of our website here.

Save the Children is a registered charity in England and Wales (213890) and in Scotland (SC039570), and it is a registered company in England and Wales (178159).

The processing of your personal information is carried out by Start Network c/o Save the Children UK.

HOW CAN YOU CONTACT US?

If you have any questions regarding our Privacy Policy, or you would like your data to be removed, please contact:

The Data Protection Officer, Save the Children, 1 St John’s Lane, London, EC1M 4AR. Email: dataprotection@savethechildren.org.uk.

Or The Digital Officer, Start Network 1 St John’s Lane, London, EC1M 4AR. Email: communications@startnetwork.org

NOTIFICATION OF CHANGE OF PRIVACY & COOKIE POLICY

This Privacy & Cookie Policy may change from time to time. For example, we will be updating it to reflect new legal requirements in advance of the EU General Data Protection Regulation coming into force in the UK on 25 May 2018. Please visit this website section periodically in order to keep up to date with the changes in our Privacy Policy. 

Our Privacy Policy takes into account several legal instruments, insofar as they are relevant to Start Networks activities, including:

  • The Data Protection Act 1998
  • The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
  • Directive 2009/136/EC of 25 November 2009 (“The European Union Cookie Directive”).

All personal information submitted by users outside of the UK to the Start Network will be processed in accordance with this Privacy Policy.

CONSENT

By using our website and/or registering as a user you agree that we can place the types of cookies as set out in the section ‘Types of Cookies we use’ on your device.

EMAIL TERMS OF USE

Emails aren’t always secure, and they may be intercepted or changed after they have been sent. The Start Network does not accept liability for any damage or loss caused or suffered in connection with any such communications. The contents of emails reflect their author’s views and not necessarily those of the Start Network.

Please do not send the Start Network any confidential information, financial or other sensitive personal data through email.

The information in emails is confidential, so if you’ve received one by mistake, please delete it without copying, using, or telling anyone about its contents.

WHY DO WE COLLECT INFORMATION?

The Start Network takes a proactive approach to user privacy and ensures that adequate steps are taken to protect the privacy of its users. Information collected is used to:

  • Determine your location
  • Provide you with content tailored to your needs and interests
  • Monitor how the site is used in so that we can continually improve it.

Our Privacy and Cookie Policies takes into account several laws, including:

  • the Data Protection Act 1998
  • the Privacy and Electronic Communications (EC Directive) Regulations 2003
  • General Data Protection Regulation (EU) 2016/679, which will come into force in the UK in May 2018 and replace the Data Protection Act 1998.

Generally, our processing of your personal information as described in this policy is allowed by these laws because we have a legitimate need to carry out the processing for the purposes described above. Some processing may also be necessary so that we can perform a contract with you or because it is required by law. We only use your information to send you marketing communications by email or text with your consent, and you can always opt out of receipt of marketing communications by post or telephone, see section ‘How you can contact us’.

HOW DO WE COLLECT INFORMATION?

We may collect information about you whenever you interact with us. For example, when you contact the Start Network regarding our activities, register as a user on our Start Fund portal, subscribe to our newsletter, send or receive information, you specifically and knowingly provide us with your personal information.

We may also receive information about you when you interact with third parties with whom we work - but only if you’ve given them permission to share your information.

We may supplement what we know about you with information that is available to the public. For example, in order to ensure that our communication with you is relevant and tailored to your background and interests, we may collect information about you from publicly-available sources either directly or through third-party subscription services or service providers. See section, 'How will we combine and analyse the information we collect about you?'

WHAT INFORMATION DO WE COLLECT?

When you register with us, we may collect personal and employment information such as name,  email address, the organisation you work for, and other similar information. We do not use cookies to collect this type of information.

When you contact us through other means or use our website, we may collect some or all of this information, depending on how you contact us or use the site. We monitor how people use our website, so we can improve it. However, you can use our website anonymously without giving us any information. We collect this information anonymously.

If you visit our website as a guest, we may record information about:

  • The areas of the website you visit
  • The amount of time you spend on the site
  • Whether you are new to the site, or have visited it before
  • How you came to our website – for example, through an email link or a search engine
  • The type of device and browser you use.

We do this by using cookies, which you can learn more about in the ‘What are cookies’ section.

If you visit our website as a logged-in, registered user via our Start Fund portal, as well as the information you provide when registering, you will have the opportunity to provide additional data such as interests, profile picture, or additional contact details through your profile page.

HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?

We are committed to communicating with you using an approach that is right for you. This means that we carefully manage the communications we send you to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications.  In order to do this, we may combine the information that we collect about you and analyse what we know about your interests, preferences and the level of potential engagement. We may also use statistical analysis to analyse this data and understand the likelihood that you will be interested in or responsive to a campaign or message.

We may use third party service providers to assist us in this process.  We enter into contracts with all of these service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.

For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.

You can opt out of your data being combined and analysed for marketing purposes by contacting the Data Protection at the Start Network. However, this may mean that you stop receiving marketing communications from us more generally.

We may collect aggregated or anonymous information when you visit our website or interact with our content.  For example, we may collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our website or view and interact with our ads and content.  Please see our section, ‘Categories of Cookies we use’ for more detail.

HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?

We may pass your information to our service providers, partners, professional advisers, associated organisations and other relevant organisations which may share the aims and objectives of the Start Network.

We enter into contracts with all of these service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.

We may also need to disclose your information if required to do so by law, a regulator or in the course of legal proceedings.

HOW LONG WILL WE HOLD YOUR PERSONAL INFORMATION?

We will hold your personal information on our systems for as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with the Start Network (including, but not limited to, any Terms and Conditions of Use for a website).

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as it is reasonable and necessary.

Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk.

For financial and technical reasons, we may, on occasion, need to use the services of a service provider outside the European Economic Area (EEA) – this may include a country which does not have the same level of data protection as in the United Kingdom.  However, unless they are located in a country which has been assessed by the European Commission as ensuring an adequate level of protection for personal data, we will only use a service provider outside the EEA on the basis of an agreement with the service provider, designed to protect your data, in the appropriate form approved for this purpose by the European Commission. 

We will take steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.  The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

- Start Network associates

We may pass your information to our service providers, partners, professional advisers, associated organisations and other relevant organisations which may share the aims and objectives of the Start Network.

- Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

- Third party organisations that otherwise assist us in providing goods, services or information

- Auditors and other professional advisers

- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

JOB APPLICANTS AND CURRENT AND FORMER EMPLOYEES

As the Start Network is currently hosted by Save the Children, if you apply to work with us (through Save the Children), we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside the Save the Children – for example, if we need a reference, or need to get a ‘disclosure’ from the Criminal Records Bureau – we will make sure we tell you beforehand, unless we are required to disclose this information by law.

When recruiting for a post based in another country, Save the Children will sometimes need to transfer your personal information to that country to progress the recruitment. It may be that that country does not provide the same level of data protection as in the European Economic Area.

If you are unsuccessful in your job application, we will hold your personal information for six months after we’ve finished recruiting the post you applied for. After this date we will destroy or delete your information.

If you begin employment with us, we will put together a file about your employment. We keep the information in this file secure and will only use it for matters that apply directly to your employment. Once you stop working for us, we will keep this file according to our record retention guidelines. You can contact us to find out more about this.

If you apply for a job or volunteering opportunity we will also collect information so we can assess your suitability for the role.
Please refer to Save the Children’s Data Protection, Privacy, and Recruitment Statement for further information.

WHAT ARE COOKIES?

Cookies are small files, typically of letters and numbers, downloaded on to a device when you access certain websites or emails, including the Start Network website. Cookies allow a website to recognise your device and provide the user with a more tailored experience within the website.

For more information see: www.allaboutcookies.org

DO WE USE COOKIES?

Yes.

TYPES OF COOKIES WE USE

There are two broad types of cookies - 'first party cookies' and 'third party cookies':

First party cookies are cookies that are served directly by the website operator to your computer and are often used to recognise your computer when it revisits that site and to remember your preferences as you browse the site. Basically, these are our cookies.

Third party cookies are served by a service provider on behalf of the website operator and can be used by the service provider to recognise your computer when you visit other web sites. Third party cookies are most commonly used for web site analytics or advertising purposes.

In addition, cookies may be either 'session cookies' or 'persistent cookies'. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached. We use both session and persistent cookies.

We have assessed our cookies based on the International Chamber of Commerce Cookie Guide (http://www.iccwbo.uk/pages/privacy).

CATEGORIES OF COOKIES WE USE

  1. Strictly necessary cookies: These cookies are essential for the user to move around the website and to use its features, e.g. logging in to our Start Fund portal.
  2. Performance cookies: These cookies collect information about how the user makes use of the site, e.g. which pages the user visits most. These cookies do not collect information that identifies the user.
  3. Functionality cookies: These cookies remember choices made by or attributes of the user and enhance the features and content you experience during your visit to our website, e.g. language, appeals visited or user’s location. This cookie is also used to remember a user's preferences for a font size, or customisable parts of a web page.
  4. Targeting or advertising cookies: These cookies collect information about the users' browsing habits. This may also include your use of social media sites, e.g. Facebook, etc. or how you interact with our website which then shows you relevant content elsewhere on the internet. NB. These may also be used to choose the advertisements that are displayed to you on our website and other websites.

We have assessed our cookies based on the ICC Cookie Guide. The majority of our cookies fall into the first two categories. However, we also use cookies on our webpages which are in categories 3 and 4.

WHAT INFORMATION DO WE COLLECT USING COOKIES?

We may collect some, or all, of the information available from cookies when you visit our website, depending on how you use it. We monitor how people use our website, so we can improve it. We collect this information anonymously.

However, you can choose to use our website anonymously without giving us any information.  Please see the ‘Changing your cookie preferences’ section.

If you visit our website, we may use cookies to record information about:

  • Areas of the website you visit;
  • The amount of time you spend on the site;
  • Whether you are new to the site, or have visited it before;
  • The country, region, city and/or borough associated with your IP address or device;
  • How you came to our website – for example, through an email link or a search engine;
  • The type of device and browser you use;
  • How you use the website and the quality of your experience – for example we may track your bandwidth when viewing videos;
  • How you interact with our sign-up forms – for example what you select as your communication preferences
  • Any error messages that you receive on the site

HOW DO YOU DISABLE COOKIES?

If you are using Microsoft Internet Explorer and you wish to block the Start Network website cookies, you can perform the following:

  1. On your browser tools menu, select ‘Internet Options’
  2. Click on the ‘Privacy’ tab and then on the ‘Sites’ button
  3. Type the following into the ‘Address of website’ field: “www.startnetwork.org”
  4. Click on the ‘Block’ button
  5. Click on the OK button

Other browsers:

IN EMAIL

Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously; we don’t share this information.

WEBSITE STATISTICS ANALYTICS

We use Google Analytics, as well as other appropriate systems, to understand how people use our website so we can make it more effective. Google Analytics collects anonymous information about what people do on our website, where they’ve come from, and whether they’ve completed any tasks on the site, for example, signing up to our newsletter. Google Analytics tracks this information using cookies and JavaScript code.

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.  For more details please read Google’s Analytics overview.

You can always opt-out of Google Analytics cookies by Google’s opt-out tool.

CAN YOU GAIN ACCESS TO YOUR PERSONAL INFORMATION?

To the extent applicable under the UK Data Protection Act 1998, you may request a copy, or to have any inaccuracies corrected, of the personal information relating to you which is held by the Start Network (for which we may charge a small fee) by contacting the Company Secretary of the Start Network by writing to:

The Data Protection Officer, Save the Children, 1 St John’s Lane, London, EC1M 4AR. Email: dataprotection@savethechildren.org.uk.

Or The Digital Officer, Start Network 1 St John’s Lane, London, EC1M 4AR. Email: communications@startnetwork.org

We will use reasonable efforts to supply, correct or delete any personal information about you held by the Start Network, upon request.

HOW TO UPDATE YOUR INFORMATION OR CHANGE YOUR CONTACT PREFERENCES

If you want to update the information we hold for you, or you think any information we have about you is incorrect or incomplete, please get in touch as soon as possible. If you want to have your details removed from our marketing mailing lists, or to change your marketing preferences, please contact us. See section ‘How can you contact us’.

CHILDREN’S DATA

When you register with us, you are stating that you are over 18 years of age or are a minor acting with parental consent. You agree that any information you provide to us about yourself upon registration or at any time is true. See the Terms and Conditions of Use for more information.

CONFIDENTIALITY

We cannot be held responsible for the privacy of data collected by websites not owned or managed by the Start Network, including those linked through our website.

WHAT OTHER DATA PROTECTION RIGHTS DO YOU HAVE?

You can make a complaint or raise a concern about how we process your personal data by contacting our Data Protection Officer.  In some circumstances, you have the right to object to our processing of your personal data or to stop us from continuing to make active use of personal data that we retain in our records.

If you are not happy with how we have handled your complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in the UK.


Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first. You also are entitled to request a copy of the personal information relating to you which is kept on file by Start Network (for which we may charge a small fee) by contacting our Data Protection Officer.

NOTIFICATION OF CHANGE OF PRIVACY POLICY

We reserve the right to amend this privacy statement. You are advised to visit this website section periodically in order to keep up to date with the changes in our privacy policy.

May 2018

 

Last modified: 17 May 2018