Privacy Policy
Babylon Migrants Project
1. Introduction
Babylon Migrants Project is a community-led organisation led by and for young people from refugee, asylum-seeking, and migrant backgrounds. We provide creative and community-building activities to help young refugees and asylum-seekers gain creative skills, confidence, and support networks they need to thrive. This notice tells you what to expect when we collect, use, and protect your personal information.
We understand that many of our participants come from vulnerable backgrounds and may face unique risks. Therefore, we take exceptional care to protect your privacy and safety. You have the right to participate in our programs using a pseudonym if you prefer, and we implement additional security measures specifically designed to protect those who may be at risk.
Contact Details:
Email: info@babylonproject.co.uk
Website: https://www.babylonproject.co.uk
2. Information We Collect and Why
When you participate in our programmes, we collect information necessary to deliver our services effectively and safely. This typically includes your name and contact details, though you may use a pseudonym if you prefer. We also collect your age and preferred language to ensure we can communicate with you appropriately and provide age-suitable activities. For safety reasons, we require emergency contact information, and we maintain attendance records and track your participation in various activities to monitor engagement.
We also collect recorded images of participants with their express consent for documentation and promotional purposes. To help us understand the impact of our programmes and support our fundraising efforts, we may collect your stories and experiences about your time with Babylon, but only with your explicit consent. This might involve asking you questions about your Babylon experience to build case studies that help us demonstrate our impact to funders.
We collect information about any specific support needs or accessibility requirements you may have to ensure we can support you effectively. Country of origin and immigration status information is only collected when you voluntarily provide it, and we use this information to help us support you as much as possible and understand who is in the room. We never pressure anyone to provide this sensitive information.
For fundraising and donation purposes, we collect names and contact details of supporters, along with payment or banking details for processing donations and maintaining donation history records. This helps us acknowledge contributions appropriately and comply with financial regulations.
When we communicate with supporters or promote our work, we may collect names and contact details for service updates and marketing purposes. Any recorded images such as photos or videos are only collected with explicit written consent from participants, and you can withdraw this consent at any time.
Our recruitment processes require us to collect standard employment information including contact details, National Insurance numbers, employment history, right to work documentation, and details of any criminal convictions through DBS, Access NI or Disclosure Scotland checks. We may also collect information about racial or ethnic origin as special category data, but only when necessary and with appropriate safeguards.
When handling queries, complaints, or claims, we collect relevant correspondence and contact details, along with any special category information that pertains directly to your inquiry.
Our website automatically collects certain technical information including IP addresses and browser details, and we use analytics to understand how visitors use our site. We also use cookies to improve your browsing experience and remember your preferences.
3. Special Protections for Vulnerable Participants
Recognizing that many of our participants face unique challenges and potential risks, we have implemented enhanced protection measures beyond standard data protection requirements. You are welcome to use a pseudonym throughout your participation in our programmes if using your real name could put you at risk. We never share immigration status information with authorities unless we are legally compelled to do so by a court order or similar legal requirement.
All our staff receive specialized training on confidentiality, data protection, and the particular safety concerns that may affect refugees, asylum-seekers, and migrants. When we prepare reports for funders or use data for evaluation purposes, we always anonymize the information so that individuals cannot be identified. Our physical and digital file storage systems have enhanced security measures, and we can arrange alternative communication methods if standard contact methods might compromise your safety.
4. Legal Basis for Processing Your Data
Under UK data protection law, we must have a lawful basis for collecting and using your personal information. For delivering our programmes and services, we rely primarily on legitimate interests as our legal basis, as supporting vulnerable young people aligns with our charitable purposes and serves the public good. For sensitive information such as photos, videos, stories, and immigration status details, we always obtain your explicit consent before processing this data.
In emergency situations where someone's physical or mental wellbeing is at urgent or serious risk, we may process information based on vital interests to ensure safety and provide necessary support. For donations and fundraising activities, marketing communications, and handling queries or complaints, we rely on your consent, which you can withdraw at any time.
Our recruitment processes operate under multiple legal bases depending on the specific information involved. We use consent for voluntary information, contract basis for employment-related processing, legal obligation for mandatory employment law compliance, and vital interests for urgent health and safety situations.
5. Your Rights
You have comprehensive rights regarding your personal data under UK GDPR. You can request access to copies of your personal information and ask for details about where we obtained it and who we share it with. If any information we hold about you is inaccurate or incomplete, you have the right to ask us to correct it. You also have the right to request that we delete your personal information, though this may be subject to certain legal limitations.
You can ask us to restrict how we process your information, object to certain types of processing, and request that we provide your data in a portable format that you can transfer to another organization. When we process data based on your consent, you always have the right to withdraw that consent, and we will respect your decision immediately.
Importantly, you can exercise any of these rights without it affecting your ability to participate in our programmes. We are committed to responding to your requests promptly and in any event within one month of receiving them.
6. Data Sources
Most of the personal information we hold comes directly from you when you choose to engage with our services, apply for programs, make donations, or contact us with inquiries. Sometimes we receive information from family members or carers who are supporting your participation, but only with appropriate consent and safeguards in place.
We may also receive information from other charities or voluntary sector organizations when services are transferred or when organizations work together to support participants. Occasionally, we obtain information from publicly available sources for research or funding purposes, and during recruitment processes, we may contact previous employers for reference checks.
7. Data Retention
We keep your information only for as long as necessary to fulfill the purposes for which it was collected. For active participants, we maintain records throughout your engagement with our programmes. Programme records are typically retained for up to seven years to meet funding, evaluation, and regulatory requirements.
Photos and videos are kept until you withdraw consent or request their deletion, whichever comes first. Donation records are maintained for seven years to comply with financial and tax regulations. For recruitment, we keep unsuccessful candidates' information for six months, while successful candidates' records are retained for the duration of employment plus six years afterward.
Safeguarding records are maintained according to our safeguarding policies and legal requirements, while general correspondence is typically kept for three years unless ongoing issues require longer retention. We conduct regular reviews of all stored information and securely delete data that is no longer needed.
8. Information Sharing
We only share your personal information in specific, limited circumstances. When there are child protection or vulnerable adult safeguarding concerns, we may need to share relevant information with appropriate authorities. We also share information with relevant regulatory authorities such as the Charity Commission when legally required, and with external auditors or inspectors for organizational oversight purposes.
Courts, law enforcement agencies, or other organizations may legally compel us to share information, but we only do so when we have a clear legal obligation. For joint programmes with partner organizations, we only share information with your explicit consent. During recruitment processes, we may contact current or previous employers for reference checks.
With your explicit written consent, we may share photos, videos, and other promotional content on our website, social media platforms, or in marketing materials. However, we maintain strict commitments about what we will never do with your information. We will never sell your personal information, share immigration status information without legal obligation, provide participant lists to authorities, or share any information that could put you at risk.
9. International Data Transfers
We primarily store all data within the United Kingdom to maintain the highest level of protection under UK law. When we occasionally use international services such as cloud storage providers, we ensure that adequate protection measures are in place and that your rights remain fully protected under UK GDPR standards.
10. Children and Young People
For participants under 18 years of age, we follow enhanced procedures to ensure appropriate protection. We obtain parental or guardian consent where required by law, though young people aged 13 and above can usually consent to most data processing themselves. We implement enhanced safeguarding procedures for all young participants and provide age-appropriate privacy information to ensure they understand how their information is being used.
11. Cookies and Website Analytics
Our website uses cookies to ensure proper functionality, understand how visitors interact with our site through anonymized analytics, and remember your preferences for future visits. You maintain full control over cookies through your browser settings, though some essential cookies are necessary for the website to function properly.
12. Policy Changes
We may update this privacy policy periodically to reflect changes in our practices or legal requirements. When we make significant changes, we will notify you through email or prominent notices on our website. The updated policy will always be posted on our website with a revised date, and you retain the right to withdraw from any new uses of your data that you do not agree with.
13. Making a Complaint
If you have concerns about how we handle your personal data, we encourage you to contact us first using the contact details provided at the beginning of this policy. We are committed to addressing your concerns promptly and transparently.
If you remain unsatisfied with our response, you have the right to complain to the Information Commissioner's Office. You can contact the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, call their helpline on 0303 123 1113, or visit their website at https://www.ico.org.uk/make-a-complaint/ to submit a complaint online.
14. Your Safety Is Our Priority
Your safety and privacy are fundamental to everything we do. If you have any concerns about privacy or safety related to your participation in our programmes, or if your circumstances change in a way that affects your privacy needs, please contact us immediately. We are here to support you and can adapt our approach to ensure your continued safety and wellbeing.
Last updated: 1 Aug. 25