ON THE PROCESSING OF PERSONAL DATA BY THE ICRC RESOURCE MOBILIZATION DIVISION (REM)
This notice provides you with information about how we, the International Committee of the Red Cross (ICRC), in particular the Resource Mobilization Division (REM), as data controller, process your personal data with regard to our fundraising work, and how we respect your privacy and protect your personal data.
In case you want to know more about how the ICRC in general protects your Personal Data and maintains the privacy of its supporters, please refer to https://www.icrc.org/en/document/data-protection.
1. Our mandate and commitment
The work of the ICRC is based on the Geneva Conventions of 1949 and their Additional Protocols, the Statutes of the ICRC and those of the International Red Cross and Red Crescent Movement, and the resolutions of International Conferences of the Red Cross and Red Crescent. The ICRC is an impartial, neutral and independent organization whose exclusively humanitarian mission is to protect the lives and dignity of victims of armed conflict and other situations of violence and to provide them with assistance.
Safeguarding the personal data of individuals is an essential aspect of protecting people's lives, dignity and bodily integrity – which makes it a matter of fundamental importance for us. Data protection touches on all areas of the ICRC's activities, including our fundraising work. In light of this, the ICRC adopted the ICRC Rules on Personal Data Protection. We at REM have incorporated these rules into our daily work. They ensure that we carry out our activities in accordance with internationally recognized standards for protecting personal data. You can rest assured that we will take all reasonable steps to protect your privacy.
2. Data controller
Resource Mobilization Division
International Committee of the Red Cross (ICRC)
Avenue de la Paix 19
+41 (0)22 730 21 71
3. What are the ICRC's legitimate interests and purposes in processing my personal data and what kinds of personal data are processed?
The ICRC is funded by voluntary contributions, but the number of people affected by armed conflict is growing. It is vital, therefore, that our relationships with our supporters and partners is strong. By supporting or donating to the ICRC, you actively help us fulfil our mission.
In the course of our relationship with you, we will be processing your personal data under certain circumstances, as explained below. If we did not process your personal data, we would not be able to provide the services you request or accept your donations.
3.1 Keeping you up to date with our mission
We process your personal data in order to update you on the impact of our mission and on how your contributions and financial support make a difference. We also use your personal data to send you postal or electronic updates or information about upcoming events, projects and any opportunities we think will be of interest to you. We also update our donors on developments in international humanitarian law.
When the ICRC processes your personal data to keep in touch with you, for example through electronic newsletters, we rely on your consent. You may also receive, from time to time, specifically tailored communications that stem from our legitimate interest in cultivating our relationship with you. You can, however, opt out of our marketing activities at any time. If you no longer wish to receive electronic communications from us, you can unsubscribe by clicking on the link at the bottom of our newsletters. To unsubscribe from postal communications, please use our contact form or call us at +41 (0)22 730 21 71.
The personal data we process are your contact details, e.g. name, and postal and email address. If you request that we call you, your phone number may be included as well.
We may share your data with National Red Cross and Red Crescent Societies. Your data will only be shared with such National Societies if they help us to provide you with the services you have requested and such National Societies will only use your data for the same purposes as set out in this document. We may also share your personal data with external providers, such as email marketing service providers, printing companies and social media companies, which help us to spread our messages.
3.2 Processing and screening of donations
When you choose to contribute to the ICRC financially, we process your personal data in order to administer your donation, together with our payment providers or banks. In order to comply with certain legal requirements, we are obliged to ensure that donations from supporters and partners above a certain threshold are in line with the ICRC's ethical principles and do not contradict the Fundamental Principles of the Movement. If this is not the case, the donation will be rejected. To gain a full understanding of whether all ethical criteria are met and to assess risks associated with receiving the different forms of support, eligible supporters/partners and donations made above a certain threshold, whether from potential private supporters or from partners (both companies and foundations), are subject to an ethical screening process, which draws on reliable internal and external (i.e. public) sources. When we process your personal data in such a context, we do so only to administer your donation and fulfil our legal and ethical requirements with regard to fundraising.
When the ICRC processes your personal data in relation to the examination of proposed gifts, it is always in accordance with the legitimate interests of the ICRC, which require processing of such data.
The personal data we process are:
- the information you provide alongside your donation, such as your title, first and last names, country of residence, postal address, phone number and email address
- information we receive in the course of your payment, such as bank details
- the information we receive from external service providers, such as information that may indicate a conflict of interest.
We may need to share some information with external service providers that help us deliver the services you have requested, such as payment providers. We may also need to share some of the information with external service providers that monitor the sources of proposed contributions in support of the ICRC. Wherever possible, the ICRC relies on internal resources to assess the risks associated with receiving support from potential supporters and partners. Where necessary, the ICRC also consults reliable external sources. The information shared will be used solely for the purpose of providing the services requested.
We only share personal data with National Societies where it is reasonable and necessary to accomplish the purpose of your interaction with us or to develop our relationship. While we may share the outcome of the ethical screening process with National Societies (i.e. whether the donation is accepted or not), we do not share our analysis or its source materials.
3.3 Widen the network of our supporters
In order to widen our circle of supporters and partners, we reach out to individuals that we think may be interested in our mission and want to help fund our work. To gain a full understanding of the individuals, companies or foundations that may want to support our humanitarian movement, we draw on external sources, but only when we have compelling reason to believe that this adds valuable information to help us grow our circle of supporters and partners. Sometimes, we may also receive personal data from third-party suppliers that indicate you might have an interest in supporting us.
The purpose of processing your personal data in such a context is, therefore, to widen the circle of supporters and partners of the ICRC, to strengthen the exclusively humanitarian mission of the ICRC and to ensure compliance with the ICRC's ethical principles.
When the ICRC processes your personal data in relation to our efforts to widen our circle of supporters and partners, we do so only in accordance with our legitimate interest in strengthening our humanitarian movement with the backing of our supporters and partners.
The personal data we process are:
- contact details, such as your title, first and last names, country of residence, postal address, phone number and email address
- the information we receive from external service providers, such as any information that may indicate you have an interest in supporting our humanitarian movement, for example your previous engagement in fundraising, your background, your career or your interests.
We may need to share some information with external service providers that help us meet our goals, as set out above, and help us monitor the sources of proposed contributions. The information shared will be used solely for the purpose of providing the services requested.
3.4 Leaving a legacy to the ICRC
If you choose to remember the ICRC in your will, we process your personal data in order to administer your contribution. We also process your personal data to send you updates on how your bequest will be used.
Additionally, in order to uphold and protect our principled humanitarian action, all charitable bequests to the ICRC must comply with strict ethical principles – otherwise, they will be rejected. To know whether all criteria have been met, we need to make sure that eligible contributions above a certain threshold (cash, in-kind donations, estate, etc.) from potential private supporters and partners (individuals, companies, foundations, etc.) comply with our legal obligations and do not contradict our Fundamental Principles. Wherever possible, we rely on internal resources to assess the risks associated with receiving support from potential supporters. Where necessary, we also consult reliable external sources.
Whenever we process your personal data in relation to any gift or contribution, we do so only on the basis of our legitimate interest in strengthening our humanitarian movement with the backing and generosity of our supporters and partners. Sometimes, however, we are obliged to process your data to comply with legal obligations (i.e. respect your legacy wishes).
The personal data we process are:
- the information you provide before or at the time of your bequest, such as your title, first and last names, country of residence, postal address, phone number and email address
- the information you provide to any of our team members in the course of your relationship with the ICRC, such as background information, your education, professional experiences or personal interests
- the information we receive from you or any third parties involved such as notaries or banks, in order to be able to accept your contribution
- the information we receive from external service providers, such as any information that may indicate a conflict of interest.
We may need to share some of the information with external service providers that monitor the sources of proposed contributions in support of the ICRC. Information shared will be used solely for the purpose of providing the services requested.
3.5 Attending events hosted by the ICRC
We collect personal data and background information you may want to share with us, e.g. contact details, professional experiences, general interests or food preferences, when you complete a registration form to attend or take part in an ICRC-hosted event, guided tour or seminar. Personal data may also include photos or video footage taken during our events. Such processing is necessary if you attend any of our events or interact with our representatives as either a guest, speaker or participant. Sometimes we may receive and process personal data from third parties that indicate you may be interested in attending upcoming events.
We collect and process your personal data solely to maintain your contact information for administering our events, providing you with information about upcoming events and keeping in touch with you.
Please note that during events, filming and/or photography may take place. We may use the photos/videos on our website (www.icrc.org), in social media posts and in our printed material. If you prefer not to be photographed, please let our photographers know during the event.
Whenever we process your personal data in relation to organizing an event, we do so only in accordance with our legitimate interests and to increase our humanitarian impact. If we process your personal data during events, we do so only for administrative purposes. With regard to any filming or photography that may take place during our events, we process personal data only with your consent.
We may need to share some information with external service providers that support the ICRC and help us deliver services at our hosted events. The information shared will be used by such service providers solely for the purpose of providing the services requested. Additionally, we may share some information with National Societies, e.g. if one is hosting an event together with the ICRC.
4. Do you use profiling?
We do not take decisions based solely on profiling (meaning, in this case, any form of automated processing of personal data intended to evaluate certain personal aspects relating to you, or to analyse or predict your performance at work, economic situation, location, health, personal preferences, reliability or behaviour).
5. Who else do you share my personal data with?
We do not sell or trade our donor's personal data with any other entity, nor send messages or mailings to our supporters and partners on behalf of other entities or organizations. Within the ICRC, your personal data are only shared with staff members who need access for the processing purposes set out in this document. We only share personal data with National Societies where it is reasonable and necessary to accomplish the purpose of your interaction with us or for the purpose of developing our relationship, and with selected third-party providers to process personal data on our behalf and solely under our instructions.
6. How long will you keep my personal data?
We will keep your personal data only for as long as necessary to fulfil the purposes we collected them for, including for the purposes of satisfying any legal, accounting, or archiving requirements. To determine the appropriate retention period, we take into account the nature and sensitivity of your personal data, potential risks of harm from unauthorized use or disclosure of your personal data and the purposes for which we process your personal data.
When we no longer need your personal data, or you request they be erased or indicate in any other way that you no longer wish to support the ICRC, we will delete your data in accordance with our Data Retention Policy.
Under certain circumstances, personal data might be archived. The ICRC's archives are a fundamental resource for humanitarian inquiries and are a unique record of historical events and the humanitarian activities of the ICRC. Please contact us if you want to learn more about the ICRC's archives.
7. What are my rights regarding my personal data?
We are committed to treating your personal data with security, respect and confidentiality; all your personal data will be processed in compliance with the ICRC Rules on Personal Data Protection. In addition, you have certain rights with regard to your personal data. To exercise any of the rights set out below, please contact us (see contact details below).
Information and Access
You have the right to request information about the personal data we hold concerning you. Furthermore, under certain circumstances you may verify your personal data and access them. To make such a request, you will be required to answer two questions, necessary for us to verify your identity.
You are entitled to request the correction of any mistakes or inaccuracies in your personal data provided we are able to verify your identity. Please note that this does not apply in the event that your correction request relates to an assessment carried out by our staff and you are unable to provide sufficient proof of the assessment's inaccuracy, or respective data are contained in a record held by our archives. Please contact us to learn more about correction requests.
You are entitled to request that your personal data are fully deleted from our systems. However, please note that there may be certain circumstances under which we are obliged to retain your personal data.
You have the right to object at any time to the processing of your personal data on compelling legitimate grounds relating to your particular situation. Any objection of this kind will be accepted if your fundamental rights and freedoms in question outweigh our legitimate interest in processing your personal data.
You also have the right to opt out of receiving future information about the ICRC at any time. Please communicate your wish to unsubscribe using the contact details provided below or by clicking on the link at the bottom of each of our newsletters.
8. Contact details
We aim always to meet the highest standards to safeguard your privacy. If you wish to learn more about how we protect your personal data or would like to exercise any of the rights set out above, or if you have any questions, concerns or complaints, please see https://www.icrc.org/en/document/data-protection or contact us by using our contact form or call +41 (0)22 730 21 71.
If we fail to resolve your question or complaint, you may contact the ICRC Data Protection Office at: firstname.lastname@example.org.
Should a complaint not be resolved with the assistance of the Data Protection Office, the complaint may be escalated by the Data Protection Office to the ICRC Data Protection Independent Control Commission, in accordance with the ICRC Rules on Personal Data Protection.
Last updated: 23 July 2019