Introduction
This policy sets out how The Movement for Reform Judaism (which includes RSY-Netzer and Progressive Jewish Students), more commonly referred to as Reform Judaism, uses and protects your personal information.
Who are we?
The Movement for Reform Judaism is a UK registered charity (1139806) and company limited by guarantee (07431950).
Our objective is to promote and foster Judaism and to promote any charitable purpose that we consider will further the welfare of the Jewish people in the United Kingdom, in Israel or elsewhere in the world.
In the context of these activities Reform Judaism inevitably hold personal data about individuals, ranging from newsletter subscribers and synagogue members to RSY-Netzer event attendees, volunteers and many others. In relation to these ‘audiences’ as we shall call them, Reform Judaism is the Data Controller and therefore has to handle this personal data in compliance with data protection law. This is a responsibility which Reform Judaism takes seriously
Lawful basis for processing personal data
Organisations can only process personal data where there are legal grounds to do so, and these have to be specified. Accordingly, you may wish to note that our lawful basis for processing data relating to individuals is that we have their consent to do so, or else it is necessary for a contract (such as where you purchase something from us) or it is otherwise in our “legitimate interests” to do so. For example, this allows us to process personal data to contact you and keep you informed about Reform Judaism, to provide statistical analysis of the state of British Jewry and to be able to carry out our charitable functions. Occasionally it may be in our legitimate interests, or we may be under a legal obligation, to share details with relevant authorities.
Where you have given your consent for a particular purpose, it is always open to you to withdraw your consent. For example you could unsubscribe from an email newsletter that you had signed up for, either by clicking the unsubscribe link in the relevant communication or by contacting us directly.
Further detail about the reasons and our legitimate interests for processing personal data can be seen in our Audiences section below.
Processing special personal data
In addition, our status as a not-for-profit religious organisation permits us to lawfully process ‘special personal data’ (e.g. data that reveals a religious belief or data relating to health), as long as it relates to individuals who have a connection to us and we do not disclose personal data to other organisations without your consent.
The vast majority of our data pool will refer to individuals who have stated their religion by association – therefore, the data is classed as ‘special personal data’ and is not explicitly mentioned for each ‘audience’.
Direct Marketing
You will only receive marketing material from us if you have previously attended an event (here we use legitimate interest) or given your consent otherwise (e.g. tick box, via your Synagogue).
We do not sell contact details to unrelated companies for their marketing purposes.
Audiences
To find out…
• why we collect your data
• how long it is kept
• categories of personal data
• who we share it with
see sections below, as this can vary from one context to another…
Why we collect your data
We collect data in order to safely accommodate participants and leaders on our events, and to contact participants and their parent(s)/guardian(s) (for under 18s) with details needed for the event they are signed up for and in order to advertise future events
What categories of data we collect
• Contact and identification details
• Contact details of emergency contact
• Religious affiliations
• Health information
• Peer groups
• Photos (with permission)
How long we keep your data
• We keep all your data for the duration of the event, after which we keep only participant & parent(s)/guardian(s) contact details, date of birth, synagogue membership and school for marketing.
• You may opt-out of receiving marketing information at any time.
• Any welfare notes made prior to or during an event will be kept in order to refer back to, should you or your child attend future events. These notes are kept for 3 years after the most recent event attended.
With whom do we share your data
• We share the minimum data necessary with the sites and medics that we use for our events in order to create a safe environment; we share medical data with the local hospital in the event that you/your child has to visit during the event, and would share any safeguarding concerns in accordance with our statutory duties. We also share data with Reform Judaism’s student and young adult workers for future marketing.
How we collect your personal data
• General event applications are processed either using online, secure third party systems or on standard paper forms sent to our offices
• All online applications are then downloaded securely and processed internally
• Specifically for Israel tour – UJIA collect all personal data and share RSY applications with us for running event and future marketing as per points listed previously. See UJIA’s privacy policy for how they treat your data.
• Parental consent is required for all under 18 year olds. For further information from the ICO on consent from minors, please visit their website.
Why we collect your data
We collect data in order to safely accommodate participants on our events, and to contact participants with details needed for the event they are signed up for and in order to advertise future events
What categories of data we collect
• Contact and identification details
• Date of Birth of participant if under 18
• Health information
• Religious affiliations
• Photos on events (with permission)
How long we keep your data for
• We keep all your data for the duration of the event, after which we keep all but food allergy & accessibility requirements for marketing
• You may opt-out of receiving marketing information at any time.
With whom do we share your data
• General event applications are processed either using online, secure third party systems or on standard paper forms sent to our offices
• All online applications are then downloaded securely and processed internally
• We will share your name, food allergy and accessibility requirements with the event venue.
Why and how we collect your data
• We collect data through people subscribing to Reform Judaism’s newsletters via our website, registering to attend an event or consenting via a synagogue for Reform Judaism to send emails with information on news and events.
What categories of data we collect
• Contact details
• Record of interaction
What kind of data do we record
• We record data related to engagement with our newsletters. We can view if and when you opened and email, how many times you have opened it and which links you accessed.
How long we keep your data
• You may unsubscribe at any time either using the unsubscribe link on newsletters, or emailing us
• In that situation we still need to retain certain contact details to ensure you are not accidentally re-subscribed again
With whom do we share your data
• We will only share this data with our mailing house provider (who acts as a data processor) for them to process and store your data to send newsletters to which you are subscribed. We will not share data with any other third parties.
Why we collect your data
We collect data so that we can share information about special events, education material and bespoke training for members of synagogues.
What categories of data we collect
• Contact details
• Religious affiliation
• Family relationships and circumstances
• Employment details (dependent on synagogue)
How long we keep your data for
We keep this information for as long as you are a member of a Reform Synagogue and until you or your synagogue asks us to remove your details.
With whom do we share your data
We do not share your data with any third party
Why we collect your data
• Setup procedures to examine your Jewish status and where possible, enable a Beit Din to help you
• Provide long term evidence of Jewish status
What categories of data we collect
• Contact & identification details including partner’s
• Religious affiliations
• Family circumstances
• Family history
• Names of children (under 16) & birth dates
• Health information
How we collect your data
• The standard application form data is collected using paper form/document
• This is either posted to us or sent via email
• All supplementary/evidence/information is taken via post/email or over the phone
How long we keep your data
• Application data is kept for two years
• After two years, the basic registration form and notes of the court appearance are held permanently, but all evidence data is deleted (e.g. marriage certificate, birth certificates, etc.)
With whom do we share your data
• Candidate data is kept within the confines of the Beit Din department and is not shared with the general Reform Judaism database.
• Similarly, for those attending Beit Din events, data is not incorporated into the main Reform Judaism database
• Should a situation occur where the candidate be incapacitated, we may share evidence of Jewish status with immediate members of candidate’s family. Such evidence of incapacitation/disability would be required, such as a doctor’s note / solicitor’s letter.
• We share data with all Reform and Liberal Rabbis that request evidence of status and to ensure Beit Din procedures have been enacted.
• For the purposes of research, personal data is anonymised with annual reporting made to the Assembly of Reform Rabbis and Cantors, Reform Judaism Board and Council for statistical analysis.
Why we collect your data
• Your data is collected for governance and communication purposes.
• If you are on a Progressive Jewish Students or Chaplaincy residential event, your data is collected in order to ensure your physical and emotional wellbeing with us during this time, and in order to contact you with details needed for the event.
What categories of data we collect
• Contact & identification details
• Contact details of emergency contact
• Religious affiliations
• Health information
• Education details
• Photos on events (with permission)
How long we keep your data
• We will keep all your data for the duration of the event, after which we will dispose of and delete all medical details and history, as well as emergency contact details.
• You may opt-out of receiving marketing information at any time, and you may request your data is removed from Progressive Jewish Students and Chaplaincy’s database at any time.
With whom do we share your data
• Most of our student events are run in partnership with Liberal Judaism’s student fieldworker/chaplain and thus all relevant data that is strictly in regards to the particular event will be shared with the Liberal Judaism student fieldworker/chaplain, subject to your consent.
• We share
o the minimum data necessary with the sites that we use for our events in order to create a safe environment
o medical data with the local hospital in the event that you need to make an emergency visit during the event
o data with Reform Judaism’s wider database to keep you updated with any associated events and opportunities, subject to your consent
Why we collect your data
With your permission, Progressive Jewish Students and Chaplaincy collect your data in order to contact you and keep you updated with relevant events and opportunities during your time at university.
What categories of data we collect
• Contact and identification details
• Education details
How long we keep your data for
All data related to your university stay will be disposed of and deleted once you graduate.
With whom do we share your data
Progressive Jewish Students is a joint initiative of Reform Judaism and Liberal Judaism. All data is held in a shared database which is for student work only. We will also share data with Reform Judaism’s wider database to keep you updated with any associated events and opportunities, subject to your consent.
Council
Why we collect your data
• The data is used to inform the members of Reform Judaism’s Council of forthcoming governance meetings
What categories of data we collect
• Contact and identification details
• Family relationships
• Religious affiliations
How long we keep your data
• It is kept indefinitely on our database to keep a permanent record.
With whom do we share your data
• The data is not shared outside the organisation.
Board
Why we collect your data
The data is used to
- register their details with the Charity Commission and Companies House.
- notify Board Members of forthcoming meetings.
- circulate amongst the Board Members for them to keep each other informed of matters relating to their trusteeship.
What categories of data we collect
- Contact and identification details
- Profession
How long we keep your data
- It is kept for the duration of your service as a Board Member
With whom do we share your data
- This is shared with the other members of the Board, the Charity Commission and Companies House as required by law. .
Why we collect your data
• We use this information to contact lay leaders and Rabbis in relation supporting the running of your community
What categories of data we collect
• Contact details
• Position(s) held in the synagogue and dates
How long we keep your data for
The data is kept for the duration of your membership to a Reform Synagogue
With whom do we share your data
We may share your email address with lay leaders of other communities so that you can share ideas and work collaboratively
Why we collect your data
• To process your donations, to claim Gift Aid on your donations and verify any financial transactions
• To update you with important administrative messages about your donation or an event
• To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts, so we can assess any risks associated with accepting their donations
• To keep a record of your relationship with us
• To contact you about our work and how you can support Reform Judaism
• To invite you to specific Reform Judaism events, not limited to fundraising events
• To manage our events
If you do not provide this information, we will not be able to process your donation or sign you up for a particular event.
• We may sometimes carry out targeted fundraising activities by building profiles of our supporters using the information that we hold about you or general information about you that is publicly available. This is so that we can better understand our donors and your preferences. By better understanding the background of our donors, we will be able to make appropriate requests based on what may interest you and your capacity to give
• In the case of Legacy giving, we will use the next of kin details given to us by you to administer this
What categories of data we collect
• Contact and identification details
• Financial and economic status
• Banking details
• Personal information
• Where you have left us a legacy, we will collect any information regarding next of kin with which you may have provided us to administer this.
How long we keep your data for
We only keep your data for as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, the collection of Gift Aid).
With whom do we share your data
We do not share your data with any third parties. Your data is restricted to the Fundraising and Finance Departments.
Why we collect your data
• We collect data of those who express interest in our interfaith activities
What categories of data we collect
• Contact details
• Employment related information
• Educational and professional skills
How long we keep your data for
We keep data for as long as the project in which you have expressed an interest is still taking place.
With whom do we share your data
We may share your data with third parties, who are other interfaith organisations contracted to work on our interfaith projects.
Consent will be sought if such data requires sharing with third parties who act as Data Controllers.
Why we collect your data
If you apply to work for Reform Judaism, we will only use the information you give us to process your application. If your application is unsuccessful, we will destroy it within six months unless you have specifically given permission to retain your information for future vacancies.
If you work for Reform Judaism, we shall open up a file containing the information you provide us and we shall only use it for matters that apply directly to your employment. Upon leaving Reform Judaism, we shall retain only data needed for seven years for legal purposes. This means that your personal bank details, DBS and passport information will be destroyed when you leave.
What categories of data we collect
• Contact and identification details
• Contact details of emergency contact
• Financial details
• Health information
• Criminal record checks
• Employment related information
• Further details as required by employment law
How long we keep your data for
If you cease working for us, we will keep this file according to our record retention guidelines which are aligned to legal requirements.
With whom do we share your data
During the course of your employment we will need to share your details with the HMRC, Pension and Life Insurance Providers and where required, the Disclosure and Barring Service. Details on how we share your personal information with the Disclosure and Barring Service are available in a separate policy upon request.
Why we collect your data
In order to keep adequate accounting records in accordance with the Companies Act 2006 and enable the accounting function of the Company to be carried out accurately and efficiently.
What categories of data we collect
• Contact details
• Financial details
How long we keep your data for
Data must be kept for a minimum of 6 years from the end of the last company financial year in order to comply with company law.
With whom do we share your data
We do not share your data with any third parties.
We may use a data processor service called Google Analytics (GA) to track and analyse user interaction with our sites. The web code for GA installs data files (cookies) on your computer/device. This allows us to uniquely identify you and some information about you. You have the ability to turn off ‘cookies’ within your browser to prevent any tracking.
In addition to GA, companies hosting our sites also collect statistics about your visit to help us better understand our audience and our content.
There is also a means to contact our departments and staff directly via a contact forms system and sign-up to various newsletters.
Why we collect your data
This data is collected for a number of reasons from understanding how many visitors we receive to finding out how you got to our website in the first place.
What categories of data we collect
• Record of interaction
• Metrics as defined by Google Analytics
How long we keep your data
Data is kept indefinitely by Google to keep an analytical history of our sites.
With whom do we share your data
We do not share your data with other organisations. However, the data is not held by us, but by Google as a data processor – please see their privacy policy in the list of data processors.
Security measures / International transfers
Digital personal data is stored in either the EU or the USA.
For data stored in the US, all Data Processors are part of the EU-US Privacy Shield Agreement. This means that they provide a level of data security which meets EU standards. See following section on Data Processors we use.
Electronic access to your data is secured by authorisation and authentication along with logging.
Only authorised staff have access to specific types/sets of data. This is governed by the relevant Directors and HR staff and forms the authorisation to data.
Authentication comes in the form of a uniquely assigned username and password for each employee/volunteer/consultant and in some cases, additional multi-factor authentication is required.
Physical access to your data is secured by various means. Only authorised staff have access to areas where data is physically held (e.g. server rooms, filing cabinets). All personal data removed from our office is stored encrypted including notebooks/tablets/phones/removable drives/USB keys. No personal data is stored on workstations.
As regards security surrounding credit card payments made to RJ, note that we use a number of card payment providers and all are PCI-DSS compliant to ensure the security and confidentiality of your details. Only authorised staff have access to the card providers’ systems. See our data processor list for details of who we use and their own policies about the processing of your data.
The credit card data entered by you is always sent directly to the payment provider and not sent to our websites. Whilst the provider keeps your credit card data (for refunds, chargebacks, etc.), our access is limited and we cannot charge your credit details again. All card data is transmitted and stored encrypted by the providers.
Should credit card details be taken over the phone or via paper application/donation form – these details are not kept for longer than is necessary to process the payment. CVV codes are not kept for longer than 24 hours. Once payment has cleared, paper details are destroyed. No scans or digital copies are made and no details are held digitally.
Data Processors
A list of Data Processors (companies that process data on our behalf and subject to contracts requiring them to apply appropriate security measures) can be viewed below.
The list includes the type of information they process along with their privacy policies.
Reform Judaism Data Processors (GDPR)
List is updated from time to time to be kept relevant.
Changes to the Privacy Policy
Any minor changes will be published on our website.
For any significant changes, we may email our database with an informational message and link to the new policy.
Your rights
As an individual, whose personal data is processed by Reform Judaism you have the following rights:
• the right to be informed
• the right to access the data we hold about you
• the right to object to direct marketing
• the right to object to processing carried out on the basis of legitimate interests
• the right to erasure (in some circumstances)
• the right of data portability
• the right to have your data rectified if its inaccurate
• the right to have your data restricted or blocked from processing
If you are not happy with the way we have handled your data, and are unable to resolve the issue with us personally, you have the right to lodge a complaint with the Information Commission Office.
Contact information
If you have any questions or concerns about this, please contact:
Data Protection Team
The Movement for Reform Judaism
The Sternberg Centre
80 East End Road
Finchley
London
N3 2SY
United Kingdom
admin@rjuk.org
+44 (0)20 8349 5640
Last reviewed April 2022