Context

Kwajo Tweneboa’s campaign and campaign website (www.ourhomeourfutures.org and www.ourhomeourfutures.com) is backed by Breakthrough. This means that the campaign is in the network of campaigns that receive support, including digital infrastructure and data handling, from the non-profit Breakthrough (registered company name Impact Accelerator Ltd, company no. 13065812) 

If you consented by opt-ing in on signing the campaign you will receive campaign updates directly from Kwajo Tweneboa as leader of this campaign and from Breakthrough. You can unsubscribe from these updates at any time using the unsubscribe links in every email. 

The data controller is Breakthrough (registered company name Impact Accelerator Ltd). As controller we are committed to keeping your personal information secure and to be transparent about how we collect and use your data so you can have confidence when supporting us and other campaigns in the ‘backed by Breakthrough’ network. 

The purpose of this policy (set out below) is to help you understand what personal information Breakthrough collects, how we use it and what your rights are. We take care to ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. 

Please read the following policy to understand how your personal information will be treated. It may change from time to time, so please check back periodically.

1. The Information Breakthrough collects about you and how it is collected and used.

Breakthrough collects personal information about you in a number of ways:

When you support us or one of our ‘backed by Breakthrough’ campaigns by;

• Signing up to one of back by Breakthrough campaigns or campaign actions 

• Signing up directly to hear from us on the Breakthrough website

• Signing up to make a donation to Breakthrough or a backed by Breakthrough campaign 

• Engaging with our social media and digital advertising

• Applying to, or taking part in our Accelerator or other training programmes 

As well as

• When you apply for a job at Breakthrough 

• When you visit our website or backed by Breakthrough campaign websites 

• When you contact our team

To comply with UK data protection rules Breakthrough will always ensure we have legal justification for collecting and using your personal information.

The legal basis that we rely on will depend upon the circumstances in which we collect and use your personal information. In almost all cases, our processing of your personal information will fall into one of the following categories:

• Where you have provided your consent to allow us to use your data in a certain way.

• Where it is necessary for us to process your data in order to comply with a legal obligation.

• Where it is in our legitimate interests to contact you in order to raise funds and support one of our backed by Breakthrough campaigns achieve their objectives. Where we rely on a legitimate interest to use your information, we will always ensure that this is done in a way so as not to be intrusive or cause distress, and that respects your rights.

• Where it is necessary for us to process your data in order to carry out the performance of a contract with you.

Pixel trackers

We use ‘pixel trackers’ to provide us with insights about the way you interact with emails, so we can learn about the effectiveness of our communications. For example, these tools tell us if and when you open an email from us and whether you click on a link within the email. This is useful because it allows us to decide what kind of content you are interested in receiving.

We may then change the type of emails we send to you, or stop sending you emails at all if it seems you are no longer interested to hear from us. These tools also protect our communications from being incorrectly flagged as ‘spam’ by email providers. If you use an email client that allows it, you can ‘block’ pixels by changing your settings to block images being loaded by default.

2. What personal information do we collect?

We may collect, store and use the following kinds of personal information:

(1) Your name and contact details, including address, telephone number, e-mail address, and social media identity. We may ask for other information where it is appropriate and relevant, for example

• Details of why you have decided to contact us or support a campaign;

• Details of your opinion on a particular issue or campaign;

• Details of campaigns you have supported, details of topics/areas of interest to you, responses to surveys you have completed; 

(2) information about your computer and about your visits to and use of this website including your IP address, geographical location, browser type, referral source, length of visit and number of page views;

(3) information about any of the campaigns you have supported and any marketing and/or communication preferences you give; and/or

(4) any other information shared with us as per clause 1

Do we process sensitive personal information?

The law recognises certain types of personal information as sensitive and requiring more protection, including health information, ethnicity and political opinions. This is known as ‘special category’ information. In limited cases, we may collect special category information about you because it is relevant to the particular campaign or survey in which you are participating.

We may also use certain special category information you provide us in surveys, such as your political opinions. We will generally seek your explicit consent before collecting this information for these purposes.

It may also be necessary for us to process special category information for purposes in the substantial public interest like the prevention or detection of a crime or safeguarding children or adults who are at risk. We may also process information which relates to potentially criminal activity for the same purposes.

If you are applying to us for employment we may carry out checks to ensure that you are suitable to work with our members. In the event this involves processing information relating to criminal investigations or convictions then we will be relying on the substantial public interest condition relating to the safeguarding of children or adults who are at risk.

3. How and why will we use your personal data?

We use your personal information to:

• Enable you to use and/or learn about all of the services we offer;

• Send you information about our work, campaigns, organisations and any other information, products or services that we provide (this will not be done without your consent);

• Send you surveys (see section 8 below) including for the purpose of conducting supporter research (see section 6 below);

• Provide you with the services, products or information you have requested;

• Improve your browsing experience by personalising your interaction with our website;

• Handle the administration of any donation or other payment you make via credit/debit card, cheque, standing order or BACS transfer;

• Collect payments from you and send statements and/or receipts to you;

• Handle the administration of your employment;

• Conduct research into the impact of backed campaigns;

• Deal with enquiries and complaints made by or about you relating to the website or us in general;

• Make campaign submissions to third parties, where you have signed a Breakthrough backed campaign and the third party is a target of the campaign;

• Incorporate your personal data into our promotional activities but only with your consent; and/or

• Audit and/or administer our accounts.  

4. Signing a ‘backed by Breakthrough’ campaign

When you sign any campaign that is backed by Breakthrough on one of the campaign sites in our network, we ask for some personal information. We will take reasonable steps thereafter to ensure that your personal information remains accurate and up to date. 

Campaigns indicate your public support for an issue or cause. Please be aware that when you sign a campaign on one of campaign sites in our ‘backed by Breakthrough’ network

• your name, post code and (if you have supplied it) your mobile phone number will be made available to the creator of the campaign;

• the creator of the campaign may ‘export’ the campaign, together with any information you have posted on the campaign website in connection with the campaign (which could include your name, post code, phone number and comments), and send it to the individual or organisation being petitioned and/or otherwise publish, broadcast, communicate and display publicly your involvement in the campaign.

5. Supporter surveys

From time to time we may contact you (if you are a supporter) to ask you to complete surveys.

Your participation in surveys is entirely voluntary and you do not need to provide us with any personal information you do not want to. We may ask you questions about your background, behaviours, and attitudes. We will then use this personal information for the purposes set out in this Policy, including to understand our supporters better.

6. Communications, fundraising and marketing

Where you have given appropriate consent, we may contact you via e-mail with targeted communications to let you know about our events and/or activities that we consider may be of particular interest; about the work of Breakthrough and backed by Breakthrough campaigns; and to ask for donations or other support.

In particular, if you have provided consent after signing a campaign, you will receive messages from the creator of the campaign you have signed and from us in relation to other campaigns which are part of the backed by Breakthrough network.

You can choose to stop receiving such emails from us and our trusted partners at any time by clicking the “unsubscribe” link at the bottom of our emails, or by contacting us using the details below. 

Or, if you’d like to opt-out of hearing from us by post, please email info@breakthroughimpact.org 

7. Members of Parliament

We collect and use some information in relation to MPs. This includes the following

• Information from publicly available sources regarding MPs’ voting history.

• Contact details.  

• Information from members of the public about how MPs have responded to issues they have raised.

• Information provided to us directly from MPs clarifying their positions in relation to specific issues.

We use MPs’ contact information to ask them questions, send them briefing notes on issues for which we are campaigning and to allow members of the public to contact them through our systems.

We rely on our legitimate interests to undertake data processing for these purposes.

8. Children’s data

We do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are 15 and under and we are holding your personal information, we will delete that information within a reasonable period and withhold our services accordingly.

9. Security of and access to your personal information

We aim to ensure that there are appropriate and proportionate technical and organisational measures to protect your personal information from loss, destruction, misuse, alteration, or unauthorised disclosure or access.

Your information is only accessible in Breakthrough by appropriately trained staff, contractors and by the campaign leaders of the specific campaigns you have signed up to. Each of these campaign leaders receives appropriate training.

We also use agencies and/or suppliers to process data on our behalf. We may also merge or partner with other organisations and in so doing transfer your personal information to a successor organisation.

In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this policy, we may disclose your information to regulatory and/or government bodies and/or law enforcement agencies. But only if we need to do so to satisfy a legal obligation.

10. Your rights

Under data protection legislation you also have a number of additional rights which are outlined below:

• You have the right to be informed about how Breakthrough uses your data.

• Where we are processing data based on your consent, you have the right to withdraw this at any time.

• You have the right to change your personal information if it is incomplete or inaccurate.

• You have the right to request the deletion or removal of your personal information in certain circumstances, including where it is no longer necessary for us to hold it for the purposes for which we are processing it.

• You have the right to restrict our processing of your data if there is disagreement about its accuracy or legitimate usage.

Subject Access Requests

You have a right to ask for a copy of the information we hold about you, which Breakthrough will supply to you within one month. Breakthrough will ask for proof of identity and may charge a fee should any request be unusually complex or time-consuming. If you would like to request a copy of the personal information Breakthrough holds on you, please contact us at info@breakthroughimpact.org 

You can also make a complaint about us or the way we have processed your personal information to the Information Commissioner’s Office. The contact details of the ICO can be found here.

11. Our lawful basis

We are required to have one or more lawful grounds to process your personal information. The following four are most relevant to us:

(1) Consent

We will ask for your consent to use your information to send you electronic communications such as newsletters, campaign updates, marketing and fundraising emails.

(2) Contractual relationships

Most of our interactions with subscribers and website users are voluntary and not contractual. However, sometimes it will be necessary to use personal information so that we can enter contractual relationships with people. For example, if you apply for employment or to volunteer with us.

(3) Legal obligations

Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when necessary.

(4) Legitimate interests

The law allows organisations to use personal information if it is reasonably necessary for legitimate activities, and as long as its use is fair, balanced and does not unduly impact individuals’ rights.

We will rely on this ground to process your personal data when it is not practical or appropriate to ask for consent. 

Our legitimate interests include achieving our purposes. These include (but are not limited to) promoting any philanthropic or benevolent purpose including to ensure communities who are most affected by under representation, disadvantage or injustice are supported to bring about change to improve their lives and the lives of others.  

When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.

Special category data

In addition to having to have a lawful basis, where we are processing special category data we are also required to meet one of the special conditions as follows:

(1) Legitimate activities

As a non-profit body with a political or philosophical aim, we may process special category data which you provide to us in order to achieve our goals and purposes, where this is allowed under data privacy law.

(2) Explicit Consent

Where we have obtained your consent in order to use your special category data for specified purposes, for example where you provide this type of information when completing a survey. 

12. How long we keep your personal information

In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time.

If you ask us to stop sending you direct marketing/fundraising/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.

13. Sharing your information

We use third-party service providers to assist us in delivering our services. Where necessary, we will share your personal information with those service providers. This will always be governed by a contract with the relevant service provider which prevents them from using your information in any way which goes beyond our purposes, as stated in this Privacy Policy. We share that information based on our legitimate interests in delivering our services to supporters.

We may also share your personal information with third parties such as public authorities where we have a legal obligation to do so or where it is necessary for reasons of substantial public interest such as the prevention or detection of a crime.

Where you have consented, we may also share your personal information for the purposes of making campaign submissions to third parties or for the purposes of our promotional activities.

By submitting your details you agree we may share limited personal information with decision makers on a campaign, for example, when handing in petitions, we share names and postcodes, and may share your comments with the decision maker.

14. Changes to this policy

We keep this Policy under regular review and will sometimes update it by posting an updated version on our website, to reflect changes in the law or in our practices. We recommend that you check this Policy occasionally to ensure you remain happy with it. Where reasonably possible, we will notify you of significant changes to our privacy policy by email.

15. Contact us

For queries relating to how we use your data you can contact us at info@breakthroughimpact.org or by writing to us at the following address:

Impact Accelerator Ltd

Gather Round

15-16 Brunswick Square

Bristol, England, BS2 8NX

Last updated: 10/03/2025