This Privacy Policy was last revised on: 05 January 2022.

The Industrial Workers of the World (IWW) is committed to protecting the confidentiality and integrity of your personal data and will process all data in accordance with our responsibilities under the UK General Data Protection Regulation (UK GDPR), Data Protection Act (DPA) 2018, Privacy and Electronic Communications Regulations (PECR) 2003 and all other applicable laws.

 

This privacy policy explains who we are, the types of information we hold, how we use it, who we share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under current data protection laws.

 

Contents:

 

Who we are

The Wales, Ireland, Scotland and England Regional Administration of the Industrial Workers of the World (IWW WISE-RA) is the Data Controller of your personal Data.

 

The IWW is a certified independent trade union registered in the United Kingdom; Certification Officer List Number 790T.

 

As a Data Controller we are responsible for ensuring that we use your personal data in compliance with data protection laws, making sure that we (and any other data processor we may entrust with your data) respect all your data protection rights. As the Data Controller, we are directly answerable to you and to the Information Commissioner’s Office for how we process your data. As a Data Controller we have a set of specific responsibilities towards you, your personal data, and the supervisory authorities, that we spell out in this Privacy Policy.

 

The IWW WISE-RA’s Data Protection Officer is: John Niven.

 

IWW members can view, modify and download their membership data record directly by visiting the ‘My Membership’ page of the IWW Members’ Area website (access to this area is restricted to members only and requires a password).

If you have any questions or concerns about our Data Protection and Privacy Policy or would like to request access, deletion or restricted use of your personal data, you can contact our Data Protection Officer as follows:

 

DATA PROTECTION OFFICER

IWW

PO Box 111,

Minehead,

TA24 9DH

 

Personal data we may collect and process.

 

‘Personal data’, or ‘personal information’, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The personal data we collect, via our websites or via any other online or offline method, will only be used for the stated purposes (or closely related purposes) for which it was collected and according to the principles laid out in this Privacy Policy.

 

We may collect your personal information in the following ways:

    • Via website cookies, analytics tools, site logs, server logs, or other similar methods (see ‘Cookies’ section below).
    • Via our online or paper membership application forms.
    • Via online contact forms for submitting queries.
    • Via postal, email, SMS, mobile/online instant messaging, phone communications, or any other forms of communication you have with IWW role holders.
    • Via online or offline survey forms, questionnaire forms, email contact submission forms, casework consent forms, crowdsourcing or crowdfunding campaign forms, or petitions.
    • Via meetings or training sessions we may have with you, whether face to face or via video/voice teleconference.
    • Via any form of communication and documentation relating to payment processing for sending or receiving payments (for example, invoices, online payment forms, or phone calls where we collect payment details or bank account information), and via any online or offline payment platforms or payment methods, including third-party financial institutions such as banks and payment processors.
    • If you are an IWW staff member or contractor, or if you work for us in any other capacity, we may collect and process your relevant personal information as part of the normal purposes of administering your work for us.
    • When you log into and use the functionalities of the online platforms that we maintain for our members and role holders, and when you view, search, alter, post, send, save, or upload content containing personal or personally identifying information on/via those platforms. This includes usage logs, analytics data, or any messages or content that you post, upload, send or edit on/via:
      • The IWW.org.uk website and WordPress administration/editing platform for the website;
      • our online Members’ Area;
      • our chat.iww.org.uk Wobchat platform;
      • our forum.iww.org.uk Interwob forum platform;
      • our email accounts, webmail client site, email server, and email server management system;
      • our mailing lists;
      • our cloud.iww.org.uk cloud file storage platform;
      • our CiviCRM membership database and any online forms or data input sites linked to the database;
      • Our Matomo analytics system;
      • Any other online tool or platform we may use for our activites.
    • When you purchase items from our online shop.
    • From other unions or organisations with which we share formal organisational or collaborative ties with around the world, for example: if we have membership transferral agreements; or so that we can administer shared communications platforms (e.g., the Interwob forum). This will always be done in a manner that respects your data rights and privacy, and complies with UK and EU Data Protection laws as well as the data protection laws and standards of your organisation and country, if you reside outside the UK or EU.
    • From other potential third-party sources such as:
      • Your current or past employer (as part of the recruitment process for persons who work for the IWW or may potentially work for the IWW as staff, contractors or service providers; or in the case of our union members, only if and when the IWW supports you with casework or represents you to defend your rights and interests as a worker; we will never share your status as an IWW member with any third party without your prior consent).
      • Your current or past clients, other people you do business with, or your agent or representative, if you are a contractor or service provider we are looking to work with.
      • Public authorities, only if and when we must deal with public authorities to fulfil legal obligations.
      • Publicly available sources, only if strictly required to meet our legitimate interests as a trade union, or to fulfil our legal or contractual obligations. 

We may collect and process information about the following categories of persons or organisations: 

    • Visitors to our websites and users of our online platforms
    • IWW members and membership applicants
    • Current or prospective IWW staff members, contractors, service providers, advisers, consultants, or other persons working for the IWW.
    • Employers of IWW members.
    • Enquirers and complainants.

 

We may collect and process personal information in the following broad contexts:

    • Membership administration: As part of the membership application process and as part of administering union membership. We will refer to this context with the shorthand notation: “Membership“. Where we make it optional for members to provide the data in this context, we denote it with the additional shorthand notation: “[optional]“.
    • Communications: in contexts where persons may willingly provide those categories of personal data to us by communicating with us, or by using or posting or sending information via our online platforms. This includes responses to surveys or petitions, customers buying items from our online shop, and members using our members-only online spaces/platforms. We will refer to this context with the shorthand notation: “Comms“. Not all the categories of personal data listed in the next sub-section as collected in the “Comms” context are necessarily always collected in that context.
    • Union organising and representation: In contexts where the IWW provides organising support, advice and/or representation to our union members in individual or collective cases or campaigns regarding work issues. In particular, it is often necessary to collect detailed personal data for the casework involved in accompanying, representing and defending individual workers (e.g., at meetings with employers, supporting members’ workplace grievances, supporting members facing disciplinary processes). We will refer to this organising and representation context with the shorthand notation: “Repping“. Not all the categories of personal data listed in the next sub-section as collected in the “Repping” context are necessarily always collected in that context.
    • Staff administration: in the context of managing persons who work for the union as elected officers, role holders, accredited workers’ representatives, or as paid personel, including contractors and third-party service providers or data processors. We will refer to this context with the shorthand notation: “Staff“. Not all the categories of personal data listed in the next sub-section as collected in the “Staff” context are necessarily always collected in that context.

 

We may collect the following categories of personal information, in the following contexts:

    • IP addresses of visitors and users on our online platforms. We may also retain server logs that include the IP address of every request to our servers. (Comms).
    • Information about your use of our information and communications systems and online platforms, including but not limited to: cookies, usage logs, analytics logs, and any messages and other content and media that you post, upload, send or edit via our communications systems, websites or online platforms. (Comms).
    • The contents of any personal information that you provide us via our digital and analog information and communications systems (via joining forms, correspondence, email, messaging, voice calls, teleconferencing, meetings, training sessions, online chat or forum posts, online file sharing, queries or complaints submitted via online contact forms, surveys, questionnaires, petitions, payment processing). (Comms).
    • Personal contact details for example: name, addresses (postal/residential address and country of residence), telephone numbers, and personal or work email addresses. (Membership; Comms; Repping; Staff).
    • Date of birth, age. (Comms; Repping; Staff).
    • Gender. (Membership [optional]; Comms; Repping; Staff).
    • contact details of next of kin, guardian, carer, lawyer, representative or emergency contacts. (Comms; Repping; Staff).
    • Bank account, debit/credit card, or other details about means of payment. (Membership [optional]; Comms; Staff).
    • Information about general income bracket after tax. (Membership; Comms).
    • Information about income, salary or payments for services, payroll/invoice records, tax status information, annual leave, pension and benefits information. (Comms; Repping; Staff).
    • Compensation history. (Comms; Repping; Staff).
    • Employment/work status; employer; job title; Employer’s address. (Membership; Comms; Repping; Staff).
    • Work contract type and terms. (Membership [optional]; Comms; Repping; Staff).
    • Start and end date of employment/work. (Comms; Repping; Staff).
    • Location of employment or workplace. (Membership [optional]; Comms; Repping; Staff).
    • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter). (Comms; Repping; Staff).
    • Immigration status. (Comms; Repping; Staff).
    • Copies of or data from identity documents, driving licence, passport, birth and marriage certificates. (Comms; Repping; Staff).
    • Work performance and appraisal information. (Comms; Repping; Staff).
    • Workplace disciplinary and grievance information. (Comms; Repping; Staff).
    • Secondary employment and volunteering information. (Membership [optional]; Comms; Repping; Staff).
    • Skills and qualifications. (Membership [optional]; Comms; Repping; Staff).
    • family, lifestyle and social circumstances. (Comms; Repping).
    • goods and services provided. (Comms, Repping, Staff).

 

We may also collect the following categories of more sensitive personal information, in the following contexts:

    • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions. (Comms; Repping; Staff).
    • Trade union membership, including membership and roles in other trade unions than the IWW. (Membership [giving information about membership in other trade unions is optional]; Comms; Repping; Staff).
    • Information about your health, including any medical condition, health and sickness records, disability or accessibility requirements, accident book, first aid records, injury at work and third-party accident information. (Membership [information about disability status or accessibility requirements is requested but optional]; Comms; Repping; Staff).
    • information about criminal convictions/allegations and offences. (Membership [only in the context of Incarcerated members of our Prisoner Solidarity Network]; Comms; Repping; Staff).

 

We may use the personal data we collect as follows:

    • To administer our websites and online platforms.
    • To enable your use of the services available on the IWW websites and online platforms.
    • To enable the functionalities available on our websites and online platforms.
    • To improve your browsing experience.
    • To prevent or detect any abuse of our websites and data processing systems and ensure data security.
    • To enable third parties to carry out technical or other functions on our behalf to improve our data processing systems.
    • To deal with enquiries and complaints made by you.
    • To process membership applications and membership data/records.
    • To provide IWW members with information and updates about the IWW’s activities, campaigns, and services.
    • To conduct our organising activities and campaigns as a union.
    • To conduct union elections and ballots.
    • to administer IWW branches, departments, committees and other IWW bodies.
    • To provide support, advice and/or representation in an individual or collective case regarding work issues (e.g., meetings with employers, supporting your members’ workplace grievances, supporting members facing disciplinary processes).
    • To perform the union’s administrative work, and to administer our role holders and staff, including third party contractors or service providers.
    • To fulfil our contractual obligations with our members and users of our services.
    • To fulfil our contractual agreements with our staff, contractors or with third party service providers, data processors, or other organisations.
    • To serve or support our rights, property, legal obligations, contractual obligations and legitimate interests as a trade union organisation, as well as to serve or support the legitimate interests, legal obligations, contractual obligations, legal rights, property, and personal safety of our members, service users, role holders, staff, contractors, third party service providers, data processors or third party organisations with which we conduct business as part of our legitimate interests as a trade union.
    • To communicate with our members, service users, role holders, staff, contractors, third party service providers, data processors or third party organisations with which we conduct business as part of our legitimate interests as a trade union.
    • To process membership subscription payments.
    • To make and receive payments.
    • To process and ship anything you purchase from our shop.
    • To comply with legal requirements (e.g., annual audits of the union’s finances).
    • For research purposes to further the legitimate interests of the IWW.
    • To record any contact we have with persons whose data we process.
    • To process your personal data where we have collected your explicit and informed consent to do so.
    • For other trade union related purposes, objects or activities, including those set in the IWW Rule Book.

 

The lawful basis for processing this data is the IWW pursuing our legitimate interests as a trade union.

This principal lawful basis subsumes further lawful bases such as meeting our legal or contractual obligations (or in rare cases, where we may need to process data to protect someone’s life, i.e., on the lawful basis of vital interests).

The lawful basis of consent may be used instead in specific cases outlined further below.

We will process any personal data we collect according to the principles set out in this Privacy Policy.

We will only collect and process any of the personal information listed above if it is necessary to fulfil our legitimate purposes, especially for sensitive categories of personal data. This means that we will avoid using any personal data, or minimise, or pseudonymise the personal data that we process, if that is sufficient to adequately achieve our purposes. It furthermore means that we will only collect or process personal data if one or more of the following apply:

  • It is necessary to administer the union and fulfil our legitimate interests as a trade union; or
  • We are required to do so by law; or
  • it is necessary to comply with our contractual obligations; or
  • we have your explicit consent to do so; or
  • we have taken reasonable steps to make you aware of this Privacy Policy and you willingly provide the information to us, for example, through your correspondence and communications with us, or by transmitting, posting, sending, or uploading it on/via/to any of the websites, communications systems, or online web services that we maintain; or
  • it is necessary to protect someone’s life.

Whenever you submit your personal information to our role holders via postal, email, SMS, messaging applications, voice calls, or any other form of communication, we will assume that you consent to the IWW collecting and processing your personal information according to this Privacy Policy.

Whenever we solicit IWW members’ personal information via forms, we will clearly explain our purposes for collecting the data and explicitly refer to this Privacy Policy.

All emails sent by IWW role holders or persons contacting you on our behalf will contain a footer with a link clearly referring to our Privacy Policy.

Whenever we solicit personal data via forms, we will clearly explain our purposes for collecting the data.

When we solicit personal data from non IWW-members for the purposes of research, promoting the union (‘marketing’), surveys or petitions, we will ask the respondent to explicitly consent to the IWW processing their personal data according to this Privacy Policy and will therefore process their data on the lawful basis of consent. When we solicit, collect and process data for those same purposes but from existing union members or staff (including role holders, contractors and any third party service providers or data processors), we will process the data on the lawful basis of our legitimate interests as a trade union. 

Whenever we solicit personal data from IWW members or non-IWW members to subscribe them, share their data with, or process their data using third-party data processing platforms, we will clearly explain our purposes for collecting the data and ask the respondent to explicitly consent to the IWW processing and sharing their personal data according to this IWW Privacy Policy and the Privacy Policies of the third-party platform. In this context, we process the data on the lawful basis of consent.

By joining or working with the IWW you should understand that we may use some or all of the personal data you have provided for the above purposes. Where other purposes apply, we will notify you when you provide your data.

 

Statutory data requirements

As a trade union, we have a statutory requirement to keep an accurate register of members’ names and addresses. If you wish to be an IWW member, you must provide this information to us.

 

Automated processing, profiling and decision making

We may implement various limited forms of automated processing. This may involve automations for the purpose of:

  • Automations and automated analytics to organise, structure, manage and analyse various forms of personally identifiable and non-personal data, to save time on manual data processing, improve our administrative work, or to enable and improve the functionalities and security of the information technology tools we use or the online services we build and maintain.
  • We may employ automation to delete/destroy personal data that we no longer need to retain, after the data retention period expires. 

None of the automated processing currently employed by the IWW involves profiling in a manner that could result in legal effects or consequences that significantly affect any individual.

The IWW does not perform any automated decision-making, nor any form of himan decision making based on automated procesing or profiling that may result in legal effects or consequences that significantly affect any individual.

 

Cookies

On our websites, data may be stored on a ‘cookie’. This is a tiny element of data that our site can send to your browser, which may then be stored on your hard drive. This small amount of information does not contain any private information stored on your computer.

Like most websites, the IWW uses cookies to improve our users’ experience. Our cookies policy explains which cookies we use and why, along with where you can find more information about cookies.

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of websites. Therefore it is recommended that you do not disable cookies. 

 

Updating and accessing your information

You have the right to access the personal data we have kept on record about you. You also have the right to correct the personal data we hold on you or change how we process your data or contact you. You are entitled to restrict the data we use about you, and how we use it. You can also ask us to erase all the personal data we hold about you.

IWW members can view, modify and download their membership data record as well as your Wobchat, InterWob Forum, IWW Owncloud file repository and IWW Email account data directly by visiting the ‘My Membership’ page of the IWW Members’ Area website (access to this area is restricted to members only and requires a password).

You can also contact our Data Protection Officer to view or modify the data we have about you. Links and methods for contacting the Data Protection officer are provided in the first section of this Privacy Policy text, at the top of this page.

You have the right to complain to the Information Commissioner’s Office if you think the IWW has breached your Data Protection and Privacy rights.

 

Sharing of information

We may disclose information about you to IWW officers, staff, organisers, and workplace representatives, insofar as reasonably necessary for the purposes as set out in this privacy policy.

We may need to disclose limited information about you to Webarchitects, the web service cooperative that hosts our website, email list and email servers, in order to administer our websites and provide our online services for members.

If you make monthly recurring membership dues payments through our payment provider, you will be sharing your payment details with our third-party payment processor, GoCardless.

We may need to disclose information about you to third party contractors or services we use for any of the data processing purposes listed above; for example, to maintain or upgrade our IT systems and membership database. Where this is necessary, we ensure appropriate data protection measures are in place.

 

If you purchase items on our online shop, you may need to provide your payment details to PayPal or we may need to share your payment details with another card payment processor. We will also need to share your name and shipment address with the Royal Mail or other courier or postal services we might use to send you the goods you purchase.

 

The IWW will not disclose any of your personally identifiable information to any other third party unless it is justified by:

  • the lawful basis of pursuing our legitimate interests as a trade union;
  • or it is necessary to fulfil our contract with you as a member;
  • or we have your explicit consent to do so;
  • or it is necessary to protect someone’s life;
  • or we are required to do so by law.

 

Storage of data

We will keep your personal data only for the period necessary to enable us to fulfil the purpose(s) for which we collected it, to comply with our legal obligations and/or whilst we maintain a legitimate interest in retaining it.

By default, contents that you have emailed, posted or uploaded yourself via Wobchat, the InterWob Forum, the IWW Owncloud file repository, IWW email accounts and email lists, or any other IWW communications platform, will remain indefinitely  stored and visible on those platforms, even if you are no longer a member, unless you delete them yourself or explicitly request for their deletion.

 

Emails to members and promotional communications (‘direct marketing’)

We use the postal, email and telephone contact data we have about our members to provide them with information and updates about the IWW’s activities, internal democratic processes, internal discussions, campaigns, and services. We do this on the lawful basis of pursuing the IWW’s legitimate interests as a trade union.

General information emails that we send to our members from our membership database bulk mailer are tracked. This helps us to ensure that you only receive emails from us that are of interest to you. Members can unsubscribe from general information emails sent via our database mailer at anytime by clicking the email opt-out link at the bottom of our emails.

If you choose to opt out from general information emails, we will retain the right to send you important information that we are legally required to send to our members, or for the purposes of pursuing the legitimate activities and interests of the IWW as a trade union.

We may also occasionally engage in promotional communications with non-members who have explicitly opted-in or subscribed to receive updates and information from us, or who have contacted us in the past to enquire about our activities and services. When we do this, we will always explicitly offer the right to object to further promotional communications.

We will never share your contact details with any third-party service providers or data processors for promotional, marketing or advertising purposes.

 

Data security

We will keep your personal data confidential and will take appropriate measures to protect it against loss, theft or misuse and to safeguard your privacy.

IWW uses industry standard efforts to safeguard the confidentiality of your personally identifiable information, such as firewalls and SSL (secure socket layers). We make every effort to protect the loss, misuse and alteration of information under our control. However, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. Your IWW membership information is password protected so that only you can access it and view the information contained in your account. You are responsible for maintaining the secrecy of your passwords.

 

Transfers overseas

We do not routinely transfer your data outside of the UK or the European Economic Area. Where this is necessary, we ensure appropriate data protection measures are in place.

 

The IWW Interwob Forum is an online discussion platform whose use is shared with the membership of other IWW Regional Administrations (RA) and Regional Organising Committees (ROC) that are outside the United-Kingdom and European Economic Area (EEA). These non UK and non EEA based IWW RAs and ROCs are administratively separate from IWW WISE-RA but part of the same worldwide confederation of IWW unions.

Members of these non UK and non EEA IWW Administrations who access and use the Interwob Forum will be able to read the contents of posts made by IWW WISE-RA Interwob Forum users, and see their Interwob usernames and profiles.

Interwob users have the option of using personally non-identifying usernames, and default usernames and user profile settings do not expose personally identifying data.

The Interwob Forum is accessible only to members in Good Standing of IWW RAs and ROCs.

All Interwob Forum Administrators who can access personally identifying user data must sign an IWW WISE-RA Data Processor Agreement before they obtain administrator access, in order to ensure their compliance and accountability to UK and EU GDPR data protection laws and IWW WISE-RA data protection policies. 

 

User-posted contents and media

IWW members can post contents to the public facing website (which must be approved by site editors before it is published). Members can also post contents to internal members-only discussion areas, such as Wobchat, the InterWob Forum, or any IWW email lists they may be subscribed to. Members can upload files to the IWW Owncloud file repository. IWW roleholders may be granted IWW hosted email accounts from which they can send and receive emails.

All IWW members will be able to see and download any content that you post or upload to Wobchat, the InterWob Forum, the IWW Owncloud file repository or any other members-only IWW websites. IWW email list subscribers will be able to see and download any content that you post to those lists. Any content you post to the public website (once site editors publish it) will be publicly visible and can be downloaded by any visitor to the website.

Please only post content you are comfortable sharing with these audiences. Please do not post content revealing someone else’s personal data without their prior consent. When using IWW websites and communications tools, members are expected to abide by IWW rules concerning communications and data protection (access to that page is restricted to members only and requires a password). The IWW retains the right to revoke your access to any IWW email accounts and access its contents, including personal IWW email accounts.

If you upload images to the websites you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Please note that once you have sent an email, the recipient(s) of that email, including the subscribers of any IWW email list(s) you post to, will be able to read that email and download its contents, and this cannot be undone nor deleted from the IWW email list’s message archive.

By default, contents that you have emailed, posted or uploaded yourself via Wobchat, the InterWob Forum, the IWW Owncloud file repository, IWW email accounts and email lists, or any other IWW communications platform, will remain indefinitely  stored and visible on those platforms, even if you are no longer a member, unless you delete them yourself or explicitly request for their deletion.

Members can directly download, amend or delete any content they have posted on Wobchat, the InterWob Forum, IWW’s Owncloud, or that is stored in their IWW email accounts by visiting the ‘My Membership’ page of the IWW Members’ Area website (access to this area is restricted to members only and requires a password).

Public website contributors can amend their posts themselves and can contact website editors or the IWW IT Committee or IWW Data Protection Officer to publish the amended content.

Members can ask their local branch officers or contact the IWW IT Committee to subscribe or unsubscribe their email address(es) to/from their local branch’s email lists. IWW roleholders can contact the IWW Communications Administrator for support with subscription or unsubscription on IWW roleholder email lists.

If you require assistance with any of the above, including requests for your data to be completely wiped from Wobchat, the InterWob Forum, the IWW Owncloud file repository, or IWW Email accounts, please click here to submit a request via the contact form in the IWW Members Area website (select the ‘Personal data requests’ category). (Access to this area is restricted to members only and requires a password).

 

Social media

The IWW and its various bodies use social media websites such as Twitter, Youtube and Facebook to promote their activities. We do not collect any personal data from social media profiles. We do not use your member data to target our social media posts or any social media advertising. We do not provide or sell members’ data to third parties for the purposes of social media marketing or any other form of marketing or analytics.

Occasionally, posts on our websites may contain social media buttons or links to social media sites. When you click on these buttons or links, these sites will be registering that action and may use your information.

You should check the respective policies of each of these social media sites to see how exactly they use your information and to find out how to opt out, or delete, such information.

 

 

Amendments to this policy

We may amend this policy at any time by posting a revised version on the website at www.iww.org.uk/privacy