Privacy policy

This Privacy Policy (hereafter: the Policy) outlines the personal data collection and processing practices related to the Transnational Institute’s (hereafter: TNI) website, communications and community building objectives.

It replaces the previous version of the policy, which was published on 29 November 2006.

The Policy does not cover all of the personal data processing operations by TNI, for example data processed in connection to staff and human resourcing, which is covered by internal policies and procedures.

Data controller

The data controller for data collected and processed in accordance with this Policy is the Transnational Institute.

TNI is a Foundation under Dutch law (Algemeen nut beogende instelling (ANBI)). TNI’s address is:

Transnational Institute
De Wittenstraat 25
1052 AK Amsterdam
The Netherlands

Any questions regarding this Policy or any other data protection issue related to TNI should be submitted in writing to the above address or by email to webmaster@tni.org

Guiding principles

The Transnational Institute (TNI) is committed to human rights and social justice and respects fundamental rights to privacy and data protection accordingly.

TNI is also committed to disseminating the information it produces as widely as possible and wants to build a community of change that supports its work and broader struggles for social justice in which it is involved.

To meet these objectives TNI needs to collect and process some personal data. In accordance with these guiding principles, TNI limits the amount of data it collects to that which is needed to meet these objectives, and only ever uses the data that it collects for purposes that are related to those objectives.

TNI also engages third party service providers to help it meet its objectives. As far as possible TNI only uses service providers that are equally committed to protecting personal privacy.

TNI will never sell the personal data it collects, and does everything it can to protect that data against unauthorised access and misuse.

Data collection and processing

In order to meet its communications and community-building objectives, TNI collects and processes data from the following data subjects (you are the “data subject” if you fall into any of these categories):

• Web users
• Email list subscribers
• Campaign supporters
• Social media users
• Donors
• Bookstore customers
• Webinar participants

TNI collects as little personal data as is possible to meet its objectives and serve the needs of its web users and supporters. This is illustrated in the following table, which shows the data collected by TNI and who it is collected from.

Not all the data listed below is collected systematically. For example, TNI staff members may look at information relating to social media users who engage with the organisation on Twitter or Facebook, but does not routinely collect such information.

Data variables			Data subjects
	Web users	Email list subscribers	Campaign supporters	Social media users	Donors	Bookstore customers
Name		X	X		X	X
Email address		X	X		X	X
Home address					X	X
Delivery address						X
Phone number						X
Biographical information		Optional			Optional
Financial information					X	X
Donation history					X
IP  Address	X	X	X
Pages accessed	X
Cookie data (see below)	X
Alias (if applicable)				X
Profile  data				X
Survey data	Optional

 

Sensitive data

 

Although the Transnational Institute does not directly collect sensitive data, some of the data its supporters provide may indicate their political views. This is obviously the case when individuals support one of TNI’s political campaigns.

Users of TNI’s websites and communications platforms should also be aware that the “metadata” they generate when using services may reveal their political interests. This data may be retained by their internet service provider and may be made available to law enforcement agencies. Individuals concerned about this kind of surveillance are advised to take measures to protect their privacy by using TOR or a VPN.

Data use

TNI collects and processes personal data for the following specific purposes:

• To send emails about its work to its email subscribers;
• To administer its websites and monitor aggregate usage;
• To provide campaign supporters with updates;
• To respond to communications received via its website;
• To respond to requests for information about its services from data subjects;
• To receive and process financial donations;
• To receive and process orders from its bookstore;
• To conduct occasional surveys regarding its work or services;
• For related accounting and auditing purposes.

Information security

TNI takes all reasonable steps to ensure that personal data is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although TNI does its best to protect personal data, it cannot guarantee the security of personal data transmitted to any of its websites. Any such transmission is therefore at the data subject’s own risk.

For personal data in its possession, TNI implements various technical and organisational measures in order to prevent unauthorised access. Wherever possible it encrypts the data it collects, transmits and stores. Access controls within the organisation limit the number of people with access to personal information to those that need it in connection with their job responsibilities or contractual obligations.

TNI uses email service providers in the Netherlands. As a result its emails are susceptible to lawful access by the Dutch authorities, and possibly through unlawful means by the Dutch Government and by other governments and entities.

Data sharing

In order to meet its objectives, TNI works with a carefully chosen group of third party service providers to perform tasks on its behalf.

This includes the following service providers, who perform the following tasks.

Provider	Purpose
Getresponse	Manage email subscriber list
Limoengroen	Web development
Mollie Payments	To take payments
Google Analytics	Understand usage of our websites
Google Tag Manager	Understand usage of our websites
Survey Monkey	Surveys
Youtube	Video items
Deflect.ca	Security
Zoom	To facilitate webinars

 

TNI may also engage additional third-party service providers to provide services such as information technology support or work with partners on campaigns. These activities may involve access to the personal data held by TNI. In these instances we will seek to ensure as far as possible that any such data processing is carried out in accordance with this Policy. This includes conscientiously selecting service providers and only working with trusted partners.

Jurisdiction

As far as possible, the personal data that TNI collects is stored within the European Economic Area and therefore processed in accordance with EU data protection law. However, because TNI works globally, there may be occasions where personal data is processed outside of this jurisdiction, for example by staff or contractors working for TNI from other parts of the world. In these rare instances TNI takes appropriate steps to ensure that the recipients of personal data are bound by a duty of confidentiality.

Data retention

TNI retains personal data only for as long as necessary in accordance with the above purposes and applicable laws.

When personal data is no longer necessary for these purposes it is securely deleted.

Where financial information is concerned, TNI may be required to retain some personal data for up to seven years in order to satisfy legal or contractual obligations, or in order to establish, exercise or defend legal claims.

For consent-based services from which the data subject can opt-out at any time such as email updates, TNI keeps personal data until it receives instructions to the contrary.

Tracking and cookies

TNI limits the information it collects from its website users and the capacity of third parties such as social media companies to track their browsing.

The TNI website honours do not track requests and does not use third parties to track users of its website.

The TNI website does not include Facebook, Twitter or Google+ buttons (these enable “likes” and/or “shares” but also allow these companies to track users across websites that install these features).

TNI does however point from its website to these and other internet services that use cookies and other forms of tracking. This is the case with many multi-media services, and particularly the links that TNI posts on its Twitter and Facebook accounts.

TNI’s internet service provider may also process traffic data to support the provision of its services.

TNI also collects some data in order to understand how its websites are used. This data processing is primarily concerned with counting views and downloads of specific reports, articles and videos, and, if available, the geographical distribution of the views/downloads.

TNI also collects data on how people use its websites in order to understand the impact of its work and improve its communication and dissemination. This data processing is primarily concerned with recording the specific pages of the website that people enter and leave the site from, the sections of the website they visit, as well as the items they download.

TNI uses this data to report to staff, funders, its Board and partners about the impact of particular reports, campaigns and workstreams (e.g report X was downloaded Y number of times and reached people in Z countries).

TNI also makes limited use of services provided by Google Analytics, which uses “cookies”. These are small files which are placed on web users’ computer devices to administer content for visitors to a website. For more information about cookies see allaboutcookies and EFF’s guide.

TNI’s use of Google analytics enables the collection of traffic data but does not allow TNI to identify individual users or link web usage to other personal data.

TNI makes use of cookies to help the user navigate the website.  

Website visitors who don’t want their data used by Analytics can install the Analytics opt-out browser add-on. This add-on instructs the Analytics JavaScript (ga.js, analytics.js, and dc.js) running on websites to prohibit their information from being used by Analytics. Using the Analytics opt-out plug-in will not prevent site owners from using other tools to measure site analytics.

Social Media and other platforms

TNI uses social media and social networking to increase the reach and impact of its work. These applications require the use of third party service providers.

TNI has a Facebook page, Twitter feed, LinkedIn page, and a YouTube channel.

TNI’s Facebook page is administered by Facebook, in accordance with Facebook’s Data Policy, and is accessible by Facebook users who have already consented to Facebook’s Data Policy.

The Twitter account TNI uses is administered by Twitter, in accordance with Twitter’s Privacy Policy.

The YouTube account TNI uses is administered by YouTube, in accordance with YouTube’s Privacy Policy.

The LinkedIn account TNI uses is administered by LinkedIn, in accordance with LinkedIn’s Privacy Policy.

TNI uses zoom to facilitate webinars, in accordance with Zoom's Privacy Policy.

TNI’s social media accounts and pages are managed by TNI staff members. TNI does not import or export information on its followers or subscribers from or to the aforementioned platforms.

TNI may occasionally use direct messaging over social media if it is contacted this way by individuals or organisations. TNI aims to delete these messages as soon as it has responded to the queries.

Data subjects rights

Individuals whose personal data is processed by TNI have the following rights:

• The right to be informed as to whether TNI holds data about them;
• The right of access that information;
• The right to have inaccurate data corrected;
• The right to have their data deleted;
• The right to opt-out of particular data processing operations;
• The right to receive their data in a form that makes it “portable”;
• The right to object to data processing;
• The right to receive an explanation about any automated decision making and/or profiling, and to challenge those decisions where appropriate.

To make a subject access request or complaint contact webmaster@tni.org or write to:

Transnational Institute
De Wittenstraat 25
1052 AK Amsterdam
The Netherlands

Requests can be submitted at any time. TNI will provide a response to any such requests in accordance with Dutch data protection law.

Data subjects covered by EU law may also be entitled to lodge complaints in regard to data processing or the handling of subject access requests with data protection supervisory authority in their country of residence. Relevant supervisory authority names and contact details are listed here. In the Netherlands the relevant supervisory authority is the Dutch DPA.

Changes to the Policy

In the event that the Policy is changed at any time, the date and nature of the change will be clearly indicated in this document.

In the event that the change has a material impact on the handling of personal data, TNI will contact the data subjects to inform of the changes and where appropriate seek their consent.

Revisions

Updated April 8, 2020 to include TNI's use of Zoom for webinar broadcasting.

Last update 14 May 2018.