1. The Joint Clean Air Parents’ Network Project
1.1 ClientEarth and British Lung Foundation (the BLF) are working together on a joint project to combat air pollution (‘Clean Air Parents’ Network Project’). This project will see the formation of ClientEarth and the BLF ‘Clean Air Parents’ Network’ where parents in key cities will come together to take ambitious actions to combat air pollution. In this regard, ClientEarth will collect your personal information via their website and will provide the BLF access to your personal data for the specific purposes listed under section 3 below.
ClientEarth and the BLF (jointly referred to as ‘We’, ‘Us’, ‘Our’) are committed to safeguarding your privacy; this policy sets out the basis on which the personal data you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.2 For the purpose of applicable national data protection legislation (the Act), the data controllers are:
(a) ClientEarth of Fieldworks, 274 Richmond Rd, London E8 3QW, bearing registered charity number 1053988 and
(b) The British Lung Foundation, of 73-75 Goswell Road, London EC1V 7ER, bearing registered charity number 326730.
1.3 Our representative(s) for the purpose of this Project is/are Andrea Lee from ClientEarth and Sarah MacFadyen from the BLF.
2. Information ClientEarth will collect from you via their webpage
2.1 ClientEarth will collect the following data about you:
2.2 Information you give when you sign up. This is information about you that you give ClientEarth by filling in the form on ClientEarth’s webpage in relation to the Clean Air Parents’ Network Project www.cleanairparents.org.uk (ClientEarth’s webpage). The information you give may include your e-mail address, post code, confirmation whether you are a parent or legal guardian of a child, your personal interest in the Clean Air Parents’ Network Project and other information.
2.3 Information ClientEarth collect about you. With regard to each of your visits to ClientEarth’s webpage and website generally, ClientEarth will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version.
• information about your visit, including the full Uniform Resource Locators (URL), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
3. How ClientEarth and the BLF will use your personal data for the Clean Air Parents’ Network Project
3.1 In this Section 3 we have set out:
(a) the specific purposes for which we may process your personal data;
(b) the legal basis of the processing and
(c) in the case of personal data that was not obtained directly from you, the source and specific categories of that data.
3.3 We may process the information that you provide to us for the purpose of sending electronic updates on the ClientEarth and BLF Clean Air Parents’ Network related activities. The updates may include news on air pollution, clean air campaigns, other environment related actions being taken by the Network. The legal basis for this processing is consent.
3.6 We may process the information that you provide to us for the purpose of direct engagement by our project coordinators with yourself to gather relevant information to bring your case to the attention of local decision makers The legal basis for this processing is consent.
3.7 We may process the information that you provide to us for the purpose of sending electronic updates to you on ClientEarth and the BLF’s wider clean air campaigns. The legal basis for processing is consent.
3.8 We may process data about your use of ClientEarth’s webpage and website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. The source of the usage data is ClientEarth’s analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
3.9 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.10 Please do not supply any other person’s personal data, unless you are prompted to do so.
4. Access to your personal data
4.1 ClientEarth will provide the BLF access to your personal data insofar as reasonably necessary for the purposes set out in Section 3, and on the legal bases, set out in this policy.
4.2 We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. International transfers of your personal data
5.1 In this Section 5, you will find about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for ClientEarth’s website are situated in the United Kingdom. The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries] OR [ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention procedure, which is designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of your personal data.
6.2 We will keep your personal data for the minimum duration of the Clean Air Parents Network Project and for a maximum period of 5 years from the start of the Clean Air Parents Network Project.
6.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 This policy may be updated from time to time by publishing a new version on ClientEarth’s webpage.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under the Act. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under the Act are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person;
8.7 You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
8.8 Where the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.9 If you consider that our processing of your personal information infringes the Act, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence or your place of work or the place of the alleged infringement.
8.10 You have the right to withdraw consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by written notice to us.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that ClientEarth use
(a) authentication – to identify you when you visit ClientEarth’s website and as you navigate
(b) status – to determine if you are logged into ClientEarth’s website
(c) security – to protect user accounts, including preventing fraudulent use of login credentials, and to protect ClientEarth’s website generally
(d) analysis – to analyse the use and performance of our website
11. Cookies used by ClientEarth’s service providers
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(d) https://support.apple.com/kb/PH21411 (Safari); and
(e) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on ClientEarth’s website.
13. Website owner details
13.1 The website, including the webpage is owned and operated by ClientEarth.
13.2 ClientEarth’s principal place of business is at Fieldworks, 274 Richmond Rd, London E8 3QW.
13.3 You can contact ClientEarth:
(a) by post, to the postal address given above;
(b) by telephone, on the contact number published on the website from time to time; or
(c) by email, using the email address published on the website from time to time.
14. Representative(s)’ details of the Project
14.1 The contact details of ClientEarth’s representatives are: Andrea Lee, Senior Campaigner, Clean Air team, at email@example.com.
14.2 The contact details of the BLF’s representatives are: Sarah MacFadyen, Policy and public affairs manager, British Lung Foundation, Sarah.MacFadyen@blf.org.uk