Privacy policy

Last updated: January 2025

1. Who are we?

When we refer to “Liberty”, “we” or “us” in this privacy policy we are referring to our membership association and to The National Council for Civil Liberties (registration number 03260840), the company which runs our campaigns and employs staff.

Liberty is a controller of your personal data, which means we are responsible for deciding how we hold and use information about you. We are registered with the Information Commissioner’s Office with registration number Z9169103.

We work in parallel with The Civil Liberties Trust (CLT) when we carry out fundraising activities. CLT is a separate organisation with company registration number 02824893 and charity registration number 1024948. CLT is registered with the Information Commissioner’s Office with registration number ZA794587. This privacy notice explains how Liberty and CLT use personal data in connection with fundraising activities. When we work together in this way, Liberty and CLT act as joint controllers of your personal data.

If you have any questions about this privacy policy or about how we use your personal data, please contact contact@libertyhumanrights.org.uk.

2. What is personal data?

Personal data means any information from which you can be identified, such as your name or your email address. Personal data does not include information where your identity has been removed (anonymous data).

Special category data means personal data about your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation. These types of personal data require a higher level of protection.

Criminal offence data means personal data relating to criminal convictions and offences (for example, information about criminal activity, allegations, investigations and proceedings) and can include information about unproven allegations and information relating to the absence of convictions. It also covers related security measures, such as personal data about penalties and conditions or restrictions placed on an individual as part of the criminal justice process. Criminal offence data also requires a higher level of protection.

3. How Liberty uses your personal data

3.1 Members

When you apply to become a member of Liberty, we collect personal data from you to register you as a member and to manage our relationship with you, including your:

• first name, surname and title
• home and/or work address
• personal and/or work email contact details

We use this information to consider your application for membership and, if you become a member, to keep in touch with you about matters relating to membership, such as:

• information on how to vote in our Policy Council Elections;
• invitations to our AGMs;
• invitations to our members conference;
• sending you the Liberty Magazine by post.

If you become a member of Liberty, your personal data (your name, contact address, email address and membership status) will be shared with Civica for the purposes of administering the annual election of Liberty’s Council. Civica’s privacy policy is here.

We rely on the following lawful grounds to collect and use member personal data:

• it is necessary for us to enter into, or perform, a contract with you; or
• we have a legitimate interest to provide members with relevant information and we are satisfied that our interest does not override your rights and freedoms.

We may collect additional personal data from members, for example, if you decide to stand for election to one of Liberty’s committees and we ask you to provide a personal statement to support your candidacy. If this information includes special category data (for example, information about your political opinions, religious or philosophical beliefs, or trade union membership) we will ask for your explicit consent to use this information.

Liberty does not collect financial data, such as bank account or credit card details, directly from members. We use a third-party company, Stripe, to process membership payments securely. You can find Stripe’s privacy policy here.

3.2 Strategic Litigation

Liberty undertakes strategic litigation. If you are involved in a case, we will collect additional personal data about you for use in that process. This could include:

• personal data in documents or correspondence relating to the litigation
• taking a witness statement from you

We rely on our legitimate interests to collect and use personal data in connection with our legal information services or to conduct litigation. We always carry out a balancing exercise to ensure we are satisfied that our interests do not override your rights and freedoms.

If we use special category data or criminal offence data for these purposes, we will either ask for your explicit consent or we will ensure that the information is necessary in order to establish, exercise or defend legal claims.

3.3 Campaigns

We run campaigns to raise awareness of threats to our rights and to influence national debate. In order to publicise these campaigns, we keep a record of contact details for MPs, peers and other decision-makers. We also keep contact details of campaigners and of individual contacts at grassroots organisations. We use these contact details to let relevant people know about our campaigns. We rely on our legitimate interests to contact these people about our campaigns and we always ensure we are satisfied that our interests do not override their rights and freedoms.

If you sign up to one of our campaign petitions or pledges (unless stated otherwise) your name will be made public as part of the campaign. We rely on our legitimate interest to carry out our campaigning work and to use your personal data in this way.

You can also sign up to a campaign email list to receive more information about our campaigning work and to learn about how you can get involved or donate to our campaigns. We will only send these sorts of emails to you if you have given us consent. You can opt out of receiving these emails at any time by clicking the ‘unsubscribe’ link in any of our emails or you can contact contact@libertyhumanrights.org.uk to opt out or change your contact details.

Depending on the nature of our campaigns, we may collect special category data about you in connection with a campaign (for example, information about your beliefs). We will always ask for your explicit consent to use this kind of personal data for campaign purposes.

3.4 Events

If you register to attend an event that Liberty is running, we will usually ask for your:

• name
• contact details, including your email address and telephone number
• job title and employer (if this is relevant for the event)

We may also ask you to complete a survey or to give feedback.

We sometimes use a third-party to collect this information (for example, an online ticket website) and we may share your details with the venue if the event is being held at a third-party’s premises.

Liberty (or any third party acting on our behalf) will rely on the following lawful grounds in order to use your personal data in connection with events:

• it is necessary for us to enter into, or perform, a contract with you; or
• we have a legitimate interest to provide you with relevant information about the event and we are satisfied that our interest does not override your rights and freedoms.

Depending on the event, we may ask you to provide special category data about any relevant health or medication conditions (for example, for accessibility purposes or dietary needs). We will only use your special category data for event purposes if:

• you have given your explicit consent;
• it is necessary in order for us to establish, exercise or defend legal claims; or
• it is in your vital interests and you are not able to give consent (for example, if we need to give information to the emergency services).

3.5 Fundraising

Donations to The Civil Liberties Trust

You can make a donation to The Civil Liberties Trust (CLT), a charity that works in parallel with Liberty. Your donation will be processed by Liberty on behalf of CLT as CLT does not employ its own staff.

If you make a one-off donation to CLT, you will be asked to provide your name, email address, and postal address. If you are a UK taxpayer will also ask you to confirm that you are happy for CLT to claim Gift Aid on your donation. CLT does not collect financial data, such as bank account or credit card details, from donors. Payments are processed securely by a third-party company, Stripe, and you can find Stripe’s privacy policy here.

If you make a regular donation to CLT via Direct Debit, you will be asked to provide your:

• name
• address
• email address
• bank account details

A third-party payment processing provider, RSM2000, will set up the regular Direct Debit payment with your bank. CLT will retain your information in order to claim monthly or annual payments from your account as per your instructions. All transactions are covered by the Direct Debit Guarantee.

Donations direct to Liberty

If you choose to, you can make a donation direct to Liberty. If you make a one-off donation or a regular donation by Direct Debit to Liberty, we will ask you to provide the same personal data as set out above, but we will not share this information with CLT and we will not ask you about Gift Aid.

Donations via third parties

Liberty and the CLT also accept donations through a variety of payroll giving providers (including Charities Aid Foundation Give As You Earn) and other fundraising platforms (for example, JustGiving, Virgin Money Giving, CrowdJustice). If you donate through a third party, they will provide you with their own privacy policy. We will normally receive your name, address, donation amount and date of the donation. We will always use this personal data in accordance this privacy policy.

If you make a donation, we rely on our legitimate interest to provide you with information by post about the work that we are doing.

We may use personal data that we hold about donors on our systems, sometimes together with other publicly available information, in order to better understand the background and interests of our supporters and potential supporters.  We may also share your personal data with third party organisations who are completing this service on our behalf. We may ask for your consent to use your personal data in this way, or we may rely on our legitimate interests to ensure we allocate our resources more effectively and raise funds sooner and in a cost-effective manner collect. We will always carry out a balancing exercise to ensure we are satisfied that our interests do not override your rights and freedoms. If you would prefer us not to use your personal data in this way you can let us know by contacting contact@libertyhuamrights.org.uk.

Legacies

If you use the Free Wills service to leave Liberty a gift in your will, Free Wills will share your name and contact details with us.

We also receive notifications of legacies that have been pledged to Liberty from a third party, Smee and Ford, and you can find their privacy notice here.

If you contact us directly to let us know that you have pledged to leave Liberty a gift in your will, we will ask you to give us your name and contact details. We rely on our legitimate interest to provide you with information by post about the work that we are doing.

3.6 Marketing

We will only send you marketing communications by email, text or telephone if you consent to us contacting you in this way, including if you sign up to receive email updates via our website.

If you consent to receive electronic marketing communications from us, we will add your name and email contact details to our marketing database and we will share this information with any third parties that work for us to help send out emails or messages to our contacts.

You can opt out of electronic marketing by clicking the ‘unsubscribe’ link in any of our emails or you can contact membership@libertyhumanrights.org.uk at any time to opt out, change your contact details or to update your communication preferences.

If you have given consent to receive electronic marketing communications from us, we may provide your email address in an encrypted format to Facebook for the purposes of identifying people with similar interests to yours so that Liberty can reach a wider audience. This information is not retained by Facebook and is not used by them for any other purpose. You can opt out of your data being used in this way by contacting us at membership@libertyhumanrights.org.uk.

We send marketing communications by post to our members and other relevant contacts when we are satisfied that we have a legitimate interest to do so in order to let people know about the work we are doing and how they can become involved. You can contact us at membership@libertyhumanrights.org.uk at any time to tell us that you no longer wish to receive marketing by post or to update your contact details.

We may sometimes ask you to consent to us using your personal data (for example, your photograph or your personal story) in our promotional materials. We will ensure you understand how your information will be used before giving consent and you are always free to refuse consent to let us use your personal data in this way.

3.7 Using our website – www.libertyhumanrights.org.uk

You can access all pages on our website without telling us who you are and without revealing any personal data. We will only collect your personal data if you choose to share information with us when you use our website (for example, by filling out a form or contacting us via the website). We typically rely on our legitimate interests to process these sorts of requests, unless specified elsewhere in this privacy policy.

When you use our website, we collect technical data such as your internet protocol (IP) address, the time and date of your visits, which pages are most viewed, which other websites and search engines direct visitors to the Liberty website, your browser type and version. We collect this information to help us evaluate how our website is working and to make changes to improve it. We do not link any of this data with any personal information that you may provide to us.

The software that we use to analyse our website is Matomo. Unlike remote-hosted analytics services like Google Analytics, Matomo is hosted on Liberty’s own web servers and all data tracked is inside Liberty’s Mysql database. This ensures that visitor behaviour on the Liberty website is not shared with any third-party advertising companies. We have specifically configured Matomo to respect your privacy by anonymising the IP addresses of visitors to our site and by respecting any ‘Do Not Track’ settings that you may have selected within your web browsers.

Our website uses cookies. Cookies are small pieces of data sent from a website and stored on your computer by your web browser while you are browsing the website. For more information on cookies on our website, see our Cookie Policy.

Liberty reminds visitors that most internet service providers (ISPs) maintain records of all URLs visited by their customers. Visitors should contact their ISP for more information.

Our website is not intended for children and we do not knowingly collect data relating to children.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3.8 Enquiries, feedback or complaints

If you send a query, give us feedback, or make complaint to us, we will use the personal data that you provide (for example, your name and the name(s) of any other individuals involved) in order to process your query and to respond to you. We rely on our legitimate interests to use personal data in this way and we always carry out a balancing exercise to ensure we are satisfied that our interests do not override your rights and freedoms.

4. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or if we are permitted or required by law to use your personal data without your knowledge or consent.

5. Sharing your personal data

We may share your personal data with third parties, including:

• The Civil Liberties Trust
• external service providers such as our IT and website companies
• third parties that use personal data on our behalf to undertake functions such as processing payments, managing email communications, petitions, surveys and campaigns, managing elections, and to support us with collating and analysing publicly available information to better understand our donors and supporters
• our professional advisers such as our accountants, auditors, bankers, insurers and lawyers
• if we are under a legal duty to disclose or share your personal data (for example, if required by a court order or for the purposes of prevention of fraud or other crime)
• where we need to share your personal data with a regulator, for example, making returns to HMRC or reports to the Charity Commission
• as part of a transfer or reorganisation of parts of our organisation

In order to ensure your personal data continues to be protected when it is shared outside our organisation, Liberty enters into binding data sharing and data processing agreements with our external service providers.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your personal data to those employees, trustees, officers, agents, contractors and other third parties who have a need to know. They will only use your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Transferring personal data outside the UK

We may transfer your personal data to other countries outside the UK or European Economic Area (the Member States of the European Union, together with Norway, Iceland and Liechtenstein).

Whenever we transfer your personal data outside the UK, we ensure it continues to be protected by putting in place appropriate safeguards including:

• Binding data transfer agreements incorporating the current International Data Transfer Agreement (IDTA) or the standard contractual clauses adopted by the European Commission together with the UK International Data Transfer Addendum.
• The UK-US Data Bridge, which can be used to transfer personal data to an entity which has signed up to EU-US Data Privacy Framework.
• Transferring your data to a country where there has been a finding of adequacy in respect of that country’s data protection laws.

8. Data retention

We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a legal claim connected to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems.

9. Your rights

You have the right to:

• Request access to your personal data (commonly known as a subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
• Ask us to correct personal data that we hold about you which is incorrect, incomplete or inaccurate

In certain circumstances, you also have the right to:

• Ask us to erase your personal data from our files and systems where there is no good reason for us continuing to hold it
• Object to us using your personal data to further our legitimate interests (or those of a third party) or where we are using your personal data for marketing purposes
• Ask us to restrict or suspend the use of your personal data, for example, if you want us to establish its accuracy or our reasons for using it
• Ask us to transfer your personal data to another person or organisation

You also have rights in relation to automated decision making which has a legal effect or otherwise significantly affects you. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces significant legal effects concerning you.

If you want to exercise any of these rights, please contact contact@libertyhumanrights.org.uk.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you have given your consent to us processing your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact contact@libertyhumanrghts.org.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your data securely.

10. Queries or Complaints

If you have any questions about this privacy policy or how we handle your personal data, please contact contact@libertyhumanrights.org.uk.

Terms and Conditions can be found here.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.