Privacy Policy

Focus on Labour Exploitation (FLEX)’s processing of your personal data is guided by the General Data Protection Regulation (“GDPR”), that came into effect on May 25th 2018. You can find more information on the GDPR here.

We are committed to respecting your personal information and protecting your privacy.

This Privacy Policy explains how we collect, use, disclose, and protect information that you provide to us when you:

Information We Collect and How We Use It

We collect personal information that you directly provide to us and information that is in the public domain. We also collect some personal information automatically.

Information We Collect Directly from You or From the Public Domain

If you subscribe to our newsletter. We collect your name, email address, location data, IP address and newsletter engagement. We use this information to update you on our work, interesting news, events, vacancies and different ways you can support us, including to guide our research and advocacy work, to invite you to participate in voluntary surveys or research, or to contact you for administrative or fundraising purposes. You can unsubscribe from our newsletter at any time by clicking the unsubscribe button on the bottom of our newsletter.

If you apply to work at FLEX. We collect your name, phone number, email address, and any other information you provide us in the context of your application. We only use this information to process your application during the recruitment stage.

If you call us with an enquiry or seeking support. We may collect your name, phone number, email address, the details of abuse and/or exploitation, disability details, employment details, ethnicity, nationality, immigration status, and any additional personal information that you would spontaneously provide us to describe your enquiry or explain why you seek our support. We will seek your verbal or written consent in order to record this information into our database. We use this information to provide you information and services that you have requested or that we believe could be of interest to you. We also use this information to refer you to the right service provider or to follow up on any queries if you called us with an enquiry or to seek support.

Information That We Automatically Collect

Google Analytics. Google Analytics sets and accesses cookies on your computer or other device to collect information such as the numbers of visitors to our websites, where visitors have come to them from and the pages they have visited on our websites. Our websites use Google Analytics to help collect and analyze certain information to engage in analysis, auditing, research and reporting. You may review Google Analytics’ security and privacy principles by clicking here, and opt out of the use of cookies in web browsers by Google Analytics by clicking here.

Cookies. Our websites collect information about your computer by using “cookies”. A cookie is a piece of data stored by a website within a browser which records information about your online preferences. We use cookies to help us assess how our websites are used and how they can be improved. We also store basic preferences if your browser has Java enabled. We do not use cookies to collect any other personal information or to track your personal surfing habits. You can change your cookie preferences by managing your browser’s settings. You can find out more about cookies here.

The table below provides more detail regarding the cookies we use, the information they collect, why we use them, and when they expire.

Social Media Policy. On some pages we use third-party embedded widgets, for example, to show videos from YouTube, or share on Facebook, Twitter or LinkedIn. These third-party services may set cookies for the purposes of displaying the embedded player or linking to the social media service on our website.

Facebook Like Button and FLEX Page.

  • Like Button. Our websites include a Facebook Like Button that uses cookies. Facebook uses such cookies to help show you a personalized experience on our websites as well as Facebook, to help maintain and improve its service, and to protect both you and Facebook from malicious activity. For more information, please visit this page. If you would like to review Facebook privacy policy, please click here.
  • FLEX Page. Our websites include a Facebook icon that redirects visitors to our Facebook Page. Our Facebook Page collects user data via cookies placed by Facebook through a function called “Facebook Insights” to help us learn more about our target audiences, including aggregate information about geography, demographics, page likes and Facebook usage. For more information, please visit this page. If you would like to review Facebook’s privacy policy, please click here.

Twitter Button and Twitter Account. Our websites include Tweet buttons and Twitter icons that redirect visitors to our Twitter account. These buttons and account use cookies. We understand from Twitter’s privacy policy that Twitter uses such cookies to receive Log Data that includes the web page you visited. Twitter uses this information to better understand the use of its services, to protect the safety and integrity of its platform, and to show more relevant content, including ads. Twitter does not collect this data from browsers that it believes to be located in the EU. If you would like to review Twitter’s privacy policy, please click here, and for Twitter’s cookie policy, please click here.

YouTube Videos and Channel. Our websites include video content from YouTube. These videos include cookies, which means that your web browser automatically sends certain information to Google. We understand from Google’s privacy policy that this includes the URL of the page you are visiting and your IP address. Google uses the information shared by our websites to deliver its services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and our websites. For more information, please visit this page.

Third-Parties’ Website

When you click on a link that redirects you to a third-party’s website, you are subject to that third-party’s privacy policy. We recommend you review it to get a better understanding of how that third-party’s website collects and uses your personal data.

How Long We Keep Your Information

We do not keep your personal data for longer than necessary. We keep your personal data for the following time periods.

If you subscribed to our newsletter. We keep your personal information until you unsubscribe from our newsletter.

If you apply to work at FLEX. If you are successful in your application, we will keep your personal information up to six years after the employment ceases. If you are unsuccessful in your application, we will hold your personal information for six months after we have finalized recruitment for the post you applied for.

If you call us with an enquiry or seeking support. We keep your information for one year.

Information that we automatically collect.

  • Google Analytics. You may review Google Analytics’ security and privacy principles by clicking here.
  • Cookies. Please review our Section on Cookies above.
  • Facebook FLEX Page, Twitter Account and YouTube videos and channel. Here are links where you can review Facebook’s, Twitter’s and YouTube’s privacy policies.

How We Disclose Information to Third Parties

We disclose your personal information to third parties in the following situations.

If you apply to work at FLEX. We may disclose the personal information we hold about you to someone outside of FLEX if we need a reference or if we need to run a Disclosure and Barring Service (DBS) check. We will always seek your preliminary consent before we do so, unless we are required to disclose your information by law.
Maintaining our Website. We may share your personal information with internet service providers, cloud service providers, or other processors in the information technology industry that process it on our behalf to maintain our website. In this case, we conclude an agreement with these processors to make sure they implement appropriate measures to meet applicable data protection legal standards. Here is the list of our current processors.

Cloudflare:      Provides Domain Name System services
Dropbox:         Provides file hosting services
Mailchimp:      Provides email marketing services
tsoHost:           Provides web hosting services for labourexploitation.org
WPEngine:      Provides web hosting services for accountabilityhub.org

Security of Your Information

We use appropriate, commercially reasonable, physical, electronic, and procedural safeguards to protect your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In particular, we use encryption, virus detection systems, and passwords to secure sensitive documents. All your details are kept safely on our secure database and only accessed by a limited number of trained personnel. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security problem.

Cross Border Transfer of Your Information

We may store your personal data into Dropbox, a provider of file hosting services. Dropbox’s storage servers are located in data centers across the U.S. We understand from Dropbox’s privacy policy that Dropbox complies with the EU-U.S. Privacy Shield to ensure it offers an adequate protection of your personal data even when it is transferred outside the EU. If you would like to review Dropbox’s privacy policy, please click here.

Your Rights to Access, Correction, and Deletion of Information

You have the right to access, review, correct, delete, or inquire about information that we hold about you. You also have a right to data portability, to oppose or limit the collection and processing of your personal information, or to revoke your consent. The exercise of some of these rights may affect your browsing experience.

If you would like to exercise your rights, you can send us a request at the address or e-mail provided in the “Contacting Us” section below. As highlighted above, please note that the possibilities to address your requests are more limited where such requests deal with Social Media.

You also have the right to lodge a complaint with a Data Protection Authority in the jurisdiction where you reside, work, or where the alleged infringement of your rights took place. 

Children’s Privacy

Our websites are not directed to children under the age of 13. We will never knowingly collect information from anyone under the age of 13. If you are under 13, please do not attempt to send us your personal information. If we learn that we have collected information from a child under age 13, we will promptly take all reasonable steps to delete the data from our system.

Notification of change of Privacy Policy

This Privacy Policy may be updated from time to time to reflect new legal requirements and changes to our internal procedures. Please visit this website section periodically to keep up to date with changes in our Privacy Policy.

Contacting Us

If you have any questions about our Privacy Policy, your rights under our Privacy Policy, or any other issue regarding the protection of your personal data, please contact us on 020 375 25516 or via email at [email protected].

Last updated February 2019