PRIVACY POLICY

Teach For All Privacy Notice

Effective Date: February 2021

Teach For All, Inc. (US) and Teach For All Network (UK) (collectively, “Teach For All”) are committed to respecting your personal data protection and privacy rights throughout the world.  Therefore, this notice is meant to provide you with a clear understanding of the types of personal data we may collect in our role as a data controller, the purposes for which we may use the information, the circumstances in which we may share the information and the steps we take to safeguard this information. This notice applies to personal information that Teach For All collects and processes via or in connection with our website (https://teachforall.org/) including the activities and services detailed on the website. This notice does not apply to personal information we collect in a work or employment context.

There may be different circumstances where you provide personal data to Teach For All. The types and amount of personal data you provide will depend on the reasons you are communicating with Teach For All.  In some instances, this personal data may only be basic contact information. In other instances, it may be more in depth such as professional qualifications, financial information, or data about members of your staff.  Regardless of the specific type of information you are providing, Teach For All takes your data privacy seriously. 

After collecting personal data from you, Teach For All may sort through and process that data.  Because Teach For All determines the means and purpose for processing the data it collects, it qualifies as a “data controller” under applicable law, such as the EU General Data Protection Regulation and the UK General Data Protection Regulation (collectively “GDPR”).  Teach For All’s status as a data controller obligates it to adhere to certain practices and disclosures in its data security mechanisms, and the manner in which it respects your rights.

Data We Collect 

Teach For All will collect and process a variety of personal data from various parties with which it interacts.  We collect personal information: (1) directly from you (for example, when you contact us through the website or otherwise); and (2) through automated technologies and interactions (for example, as you interact with and use our website). The types of personal data that Teach For All may collect from you, depending on the purpose for which you are providing the information, include:

  • Basic contact information such as name, address, email address, and telephone number;
  • In certain limited circumstances, documents to verify address, such as invoices or billing statements from governmental, municipal entities or utility companies;
  • Identifying information, including nationality and year, or sometimes date, of birth;
  • Financial information associated with donations;
  • Online training and test information such as date assigned, date started, training score, completion date, training language, and type of course taken; and
  • Voluntarily-provided information through surveys, questionnaires and other communications with us.
  • Usage and technical data, such as your browser type, operating system, and your IP address (a unique address that identifies your computer on the Internet), where you have come from on the internet and where you go to, date and time, when you enter our website or your device type, operating system and how you use the website.

This is a broad description of the types of personal information we may process.  To understand how your own personal information is processed in particular circumstances, you may need to refer to any personal communications you may have received from us, check any privacy notices we may have provided to you or made available on our site, or contact us to ask about your personal circumstances.

We also collect, use and share aggregated or anonymized data such as statistical or demographic data for any purpose. Aggregated or anonymized data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. If we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this notice.

Why We Collect Data

There are several purposes for which we will collect the information above:

1. Newsletters and email to you.  We use contact information that you voluntarily provide to us, for example through the Subscription Link, to send you the newsletters and email messages that you request us to send.  By participating in Teach For All campaigns, you will be given the opportunity to “opt in” to receive email updates from us.  At any time, you can withdraw that consent and opt-out of receiving additional newsletters or updates from us by clicking the "unsubscribe" option when updating your contact information in the email communications you receive.

Where the GDPR applies, our legal basis for this purpose is your consent.

2. Communications with Teach For All. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this privacy notice.  Also, we may archive this information and/or use it for future communications with you.

Where the GDPR applies, our legal basis for this purpose is our legitimate interests in efficiently managing our operations, providing excellent customer service and responding to communications sent to us. 

3. Donations. Through our third party partners, we use personal data collected when you make a donation on our website to process your donation, and we may also archive your contact information and/or use it for future communications with you.  We do not archive your financial information.

Where the GDPR applies, our legal basis for this purpose is our legitimate interests in receiving and recording donations and/or compliance with our legal obligations.

4. Programmatic support to you and your organization. If you are a staff member, participant, or alumnus/a of a Teach For All partner program or early stage organization, Teach For All may process personal data as part of our effort to support your and your partner program’s impact. Such data may include contact information and professional information that you provide on our Partner Learning Portal.

Where the GDPR applies, our legal basis for this purpose is legitimate interests in providing such support and services.

5. Event management. Teach For All may process personal data in order to facilitate your attendance at a Teach For All event. Typically, this data will come from information that you provide via our online event registration websites.

Where the GDPR applies, our legal basis for this purpose is our legitimate interests in organizing and providing the event and/or the performance of a contract with you.

Automated Interactions and Web Technologies

We also use or may use cookies and other similar web technologies (“Cookies”) to help us determine, without limitation, the type of content and sites to which a user of our website links, the length of time each user spends at any particular area of our website, and the specific functionalities that users choose to use. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). Essentially, Cookies are a user’s identification card for the Teach For All servers. Cookies allow Teach For All to serve you better and more efficiently, and to personalize your experience at our website.  

You can find more information about cookies and how to manage them at www.allaboutcookies.org.

Our website uses the following types of cookies for the purposes set out below:

  • Essential Cookies: These cookies are essential to provide you with services available through our website and to enable you to use some of their features. Without these cookies, the services that you request via our website may not be possible to provide. We only use these cookies to provide you with those services.
  • Functionality Cookies: These cookies allow our website to remember choices you make when you use our website. The purpose of these cookies is to provide you with a more personalized experience and to avoid you from having to re-select your preferences every time you use our website.
  • Analytics and Performance Cookies: These cookies are used to collect information about traffic to our website and how users use our website. The information gathered may include the number of visitors to our website, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before and other similar information. We use this information to help improve our website and operate it more efficiently, to gather demographic information and to monitor the level of activity on our website. (We use Google Analytics for this purpose. You may opt out of its cookies here.)

You should be able to control how and whether Cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject Cookies in the "Help" section of the toolbar. If you reject our Cookies, certain of the functions and conveniences of this website may not work properly, but you do not have to accept our Cookies in order to productively use many functionalities of the website.

Your browser may deliver a “Do-Not-Track (‘DNT’) signal,” or similar mechanism for exercising choices about the collection of information about your online activities to this website.  We do not currently make any guarantee that we will honor DNT signals or similar mechanisms. 

Who We Share Your Information With

We will not share your personal information with third parties, except as described herein, in separate data notices that you may receive from us or as authorized by you. 

  1. Teach For All. Teach For All Inc. and Teach For All UK may share personal and other information with one another in the course of and for the purpose of providing services such as those described above to their members and partners. 
  2. Partner Organizations and Service Providers. We may also share some of your information with our partner organizations (see https://teachforall.org/network-partners) and with companies that perform support services to Teach For All, such as accounting or legal firms, firms that provide data hosting or database management services, and other technical support.  These third parties are required to maintain the confidentiality of your personal information and to use your personal information only in providing services to Teach For All. 
  3. Government Authorities, Legal Rights and Actions. Teach For All may share your personal data with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law.  In such cases we reserve the right to raise or waive any legal objection or right available to us.  We also may share your personal data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Teach For All, the website, our users, customers, or others; and in connection with our other agreements.
  4. Business Transactions.  We may also share your personal data in the course of, or relating to, a transaction for the sale, merger, or other reorganization of our business, or a transfer to a successor organization.  If such a transfer occurs, the successor organization’s use of your personal data will still be subject to this Privacy Notice and the consents and preferences you have expressed to us.

Any other disclosure of your personal information will be pursuant to your express consent.

Where Your Information Will Go 

Regardless of the physical location, any of the data subject to this notice may, at any time, be transferred to the United States of America or in other jurisdictions where Teach For All operates where data privacy laws may be less stringent than the laws in the your country. We will process your personal information in accordance with applicable law and with this notice regardless of where your personal information is stored or accessed.

By providing your personal information through or in connection with the website, you acknowledge that your personal information is transferred to and accessed by our personnel in the United States. Where the GDPR applies, and where our partner organizations or service providers or other third parties (identified above) based outside the UK (or the European Economic Area, where applicable) receive personal information, we ensure the transfer is either (a) to a country deemed to provide an adequate level of protection by the UK government (or the European Commission, where applicable) or (b) pursuant to specific contracts approved by the UK government (or the European Commission, where applicable). 

How Long Your Data Will Be Kept

Typically, we retain your data for the period necessary to fulfill the purposes for which you provided the information.  However, Teach For All may decide to delete your data if Teach For All believes that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties.  When we delete personal data, it will be removed from our active data storage platforms, but it may remain in archives where it is not practical or possible to delete it.  In addition, Teach For All may keep data as needed to comply with its legal obligations, resolve disputes, and/or enforce any of our agreements.

While the terms of this notice do not specify a particular length of time for which data may be kept, Teach For All will, where applicable, always comply with its legal obligations under the GDPR to keep data for only so long as it has a permissible purpose for processing it. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your Rights

Teach For All will respect and adhere to your data rights under applicable law.  

Where the GDPR applies and subject to any exemption under the GDPR or other applicable law, you have the following rights with respect to your personal data:

  1. The right to request access to, and a copy of, your personal data that Teach For All holds;
  2. The right to request that Teach For All correct any personal data if it is inaccurate or out of date;
  3. The right to request that your personal data be erased where it is no longer necessary for Teach For All to retain such data;
  4. The right to request a restriction on further processing where there is a dispute in relation to the accuracy or processing of your personal data;
  5. The right to lodge a complaint with your local supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/);
  6. If Teach For All has relied on your consent to process your data, the right to request that Teach For All provide you with the personal data that Teach for All possesses, and where possible, to transmit that data directly to another data controller;
  7. If Teach For All has relied on your consent to support its processing of your data, the right to withdraw your consent to the processing at any time;
  8. If Teach For All has relied on its own legitimate interests, including its direct marketing efforts, to support processing your personal data, the right to object to the processing of your personal data.

Should you have any questions about this notice or desire to exercise any of the rights listed above, you should contact Teach For All at generalinquiry@teachforall.org or at the following addresses:

In the US:
Data Protection Officer
Teach For All
25 Broadway, 12th Floor
New York, NY 10004
United States of America

In the UK:
Data Protection Officer
Teach For All
14 Gray's Inn Road,
London, WC1X 8HN
United Kingdom

In addition, California law permits our users who are California residents to request certain information regarding our disclosure of Personally Identifiable Information to third-parties for their direct marketing purposes.  To make such a request, please send an email to us at generalinquiry@teachforall.org. 

Protecting Children’s Privacy

Teach For All welcomes children to learn more about our organization and about the global educational inequity issues presented on the Teach For All site, and we are particularly respectful of the privacy of our young users. We encourage parents to monitor their children's use of the Internet and to help us protect their privacy by instructing them never to provide personal information on this site or any other without permission. We will never attempt to extract unnecessary information from our users, regardless of age. Consistent with the Children's Online Privacy Protection Act of 1998 ("COPPA") and the UK Data Protection Act 2018, we will never knowingly request personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. If we become aware that a child under 13 has provided us with such information without consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that a child under 13 has provided such information to us, he or she should contact us at generalinquiry@teachforall.org.

Further Processing

If Teach For All wishes to use your personal data for a new purpose, not covered by this notice, Teach For All will explain to you such use and set out the relevant purposes and processing conditions prior to commencing the processing. Where and whenever necessary, we will seek your prior consent to the new processing.  You may always withdraw your consent at any time.

Third Party Links

Our website may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to read the privacy notices of other websites that collect personal information. 

Updates

We may update this notice to reflect changes to our information practices. If we do this and the changes are material, we will endeavour to notify you a reasonable period prior to implementing the changes and we will indicate the date these terms were last revised at the top of the notice. Any revisions to this Privacy Policy will become effective on the date stated in the notice.

 

Teach For All Mass Mailings Policy   Last revised: January26,2022


1. About this policy

1.1. This policy provides important information about Teach For All’s rules on marketing. Unlessexpressly provided otherwise, this policy does not form part of any contract of employment orengagement for services.

1.2. This policy supplements and should be read in conjunction with our other policies and proceduresin force from time to time, which are available in the Teach For All staff handbook..

2. Responsibility for this policy

The Data Protection Officer has overall responsibility for the effective operation of this policy. The DataProtection Officershall be responsible for reviewing and updating this policy to ensure that it meets legalrequirements and reflects best practice.

3. Purpose and scope of this policy

3.1. The purpose of this policy is to establish procedures for sending marketing communications (mostnotably mass mailings), including honouring recipients’ requests to no longer receive such emails.

3.2. This policy applies to all personnel who are involved in Teach For All’s mass mailing activities .

4. Definitions

In this policy, the terms below have the following meanings:

“Business Contact”

a business or organisation (including a Teach For Allnetwork partner organization) or an individual in theirprofessional capacity who is an employee of such abusiness or organization

 “Individual Contact” an individual in their personal capacity (for example, anindividual supporter of Teach For All but who is notemployed by or formally affiliated with the Teach For Allglobal network)
“marketing” the communication of advertising or marketing materialwhich is directed to particular individuals (primarily viamass email systems) and which includes all activities whichlead up to, enable or support sending thosecommunications not just the communication itself (forexample, lead generation, data enrichment, data cleansing,matching or screening, audience segmentation andprofiling and contacting individuals to obtain their consentto marketing);
“Opt-In Basis” engaging in or sending marketing to a recipient that (1) hasexpressly consented, (2) where such consent is freely given,informed, specific, affirmative and unambiguous, and (3)Teach For All has stored evidence of that consent;
“Opt-Out Basis” engaging in or sending marketing to a recipient who has notnotified Teach For All (by any means) that he or she objectsto and does not wish to receive marketing, and whensending marketing to such a recipient, Teach For All informsthem of their right to opt-out and provides a mechanism forthem to do so;
“Soft Opt-In” an exception that allows marketing communications to besent to Individual Contacts without their express, opt-inconsent provided (1) the Individual Contact’s details wereobtained during the course of a sale or negotiations for thesale of a product or service to that Individual Contact; (2)the communication is in respect of Teach For All’s similarproducts and services only; and (3) the Individual Contact isgiven a simple means of opting out at the time of datacollection and in every further communication.

5. General rules

5.1. When sending marketing communications, Teach For All must:

5.1.1. Upload the intended recipient toTeach For All’s centralized marketing database (as well as anyrelevant preference services – see Appendix) to ensure Teach For All has not already receivednotice that the intended recipient has opted out of marketing communications;

5.1.2. reference and link to Teach For All’s GDPR-compliant privacy notice/policy in your marketingcommunication;

5.1.3. notify the recipient of, and provide a mechanism to exercise, their right to opt-out of Teach ForAll’s marketing.

5.2. Where Teach For All is permitted to send marketing communications to Business Contacts on anOpt-Out Basis, Teach For All must ensure that the personal data collected and used for marketingpurposes:

5.2.1. is proportionate to its purpose (i.e. that we do not collect more information about a marketingcontact than we reasonably need);

5.2.2. has a minimal impact on the recipient’s privacy; and5.2.3.is within the reasonable expectations of the recipient (i.e. the recipient would not be surprisedor otherwise object to the marketing communication).

5.3. All individual recipients have an absolute right to opt-out of electronic marketing which Teach ForAll must respect at all times.

5.4. Where a recipient exercises their right to opt out of marketing communications:

5.4.1. Teach For All must action this request as soon as possible (to the extent not automatic) andwithin 28 days at the latest; and

5.4.2. Teach For All must not subsequently send a communication to him or her asking for theirconsent to marketing. Applicable law regards this type of communication as a marketingcommunication which, if sent, would breach Teach For All’s legal obligations.

5.5. Without the prior written approval of the Data Protection Officer, Teach For All, and any of itspersonnel, must not in any circumstances:

5.5.1. sell or share Teach For All’s marketing database or other marketing-related personal data withany non-Teach For All third party;

5.5.2. purchase or make use of any marketing list or database from a third party;

5.5.3. engage in any co-marketing initiative with a third party using Teach For All’s marketingdatabase or other marketing-related personal data;

5.5.4. engage any third party to send marketing communications on Teach For All’s or your behalf.

6. UK specific rules

6.1. Please refer to the Appendix for a summary of the UK’s specific rules in relation to specific forms ofmarketing communication.

6.2. You may also refer to the UK Information Commissioner’s direct marketing guidance availablehere: https://ico.org.uk/media/1555/direct-marketing-guidance.pdf

7. Further information

If you have any questions regarding this policy and how it may apply to you, please contact the DataProtection Officer.

Appendix – Summary Of UK Marketing Rules

Form of Marketing UK GDPR UK Privacy and Electronic Communications Regulations (“PECR”
  Individual Contacts (otherwise known as individual subscribers) Business Contacts (otherwise known as corporate subscribers)
Email or text 

Compliance with the UK GDPR’s general data processing principles, including that processing must be fair and lawful and connected to a specific lawful purpose. Any marketing activity that involves processing personal data requires a lawful basis. “Consent” and “legitimate interests” being the most relevant for marketing purposes.

Consent must be a freely given, specific (including sender-specific), informed, an unambiguous indication of the data subject’s wishes and be by way of a clear statement or affirmative action signifying agreement to the processing of personal data for marketing purposes. Pre-ticked consent boxes are prohibited.

Legitimate interests may only be relied upon if processing is proportionate, has a minimal impact on privacy, and people would not be surprised or likely to object to such processing for marketing purposes.

Data subjects have the right to object to direct marketing at any time.

Consent required on Opt-In Basis (except where Soft Opt-In applies). 

The sender of emails or texts must identify itself and provide contact details.

Such emails or texts may be sent on Opt-Out Basis.

Although purely corporate subscribers (e.g. procurement@business.com have no opt-out rights, the UK Information Commissioner advises that it is good practice to offer an unsubscribe option on each communication and to respect their request to stop.

Individual employees, whose business email address incorporates personal data (for example, emma.peters@business.com) may exercise their opt-out rights as individuals.

The sender of emails or texts must identify itself and provide contact details.

Online

 

Teach For All must comply with the UK GDPR where it targets online adverts at individual users using their personal data. For example, where we display personalised adverts based on browsing history, purchase history, or log-in information. See above for general principles.

 

The PECR does not set out any specific rules on direct marketing online, but it does contain rules on the use of cookies and other similar tracking technologies which are often used to profile users or target behavioural advertising.

The use of cookies and/or similar tracking technologies for such purposes requires Opt-In Consent.

The PECR does not set out any specific rules on direct marketing online, but it does contain rules on the use of cookies and other similar tracking technologies which are often used to profile users or target behavioural advertising. The use of cookies and/or similar tracking technologies for such purposes requires Opt-In Consent.

 

Post

See above for general principles. Data subjects may object to direct marketing at any time, in which case such marketing should cease as soon as possible.

 

Such postal communications are not strictly subject to the PECR but are subject to the GDPR. Accordingly, such postal communications may be sent to Individual Contacts on Opt-Out Basis. Individual Contacts have the right to opt-out. It is mandatory to screen the recipient against the Mail Preference Service (https://www.mpsonline.org.uk/). Such postal communications are not strictly subject to the PECR but are subject to the GDPR. Accordingly, such postal communications may be sent to Business Contacts. Individual employees have the right to opt-out. It is good practice to screen the recipient against the Mail Preference Service (https://www.mpsonline.org.uk/).
Fax

See above for general principles. Data subjects may object to direct marketing at any time, in which case such marketing should cease as soon as possible.

 

Consent required on Opt-In Basis.

All marketing faxes must include the name of the sender and a contact address or freephone number.

Such fax communications may be sent to Business Contacts.

It is good practice to screen any recipient numbers against the Fax Preference Service (http://corporate.fpsonline.org.uk/).

All marketing faxes must include the name of the sender and a contact address or freephone number.

Live telephone calls

See above for general principles. Data subjects may object to direct marketing at any time, in which case such marketing Such calls may be made on an Opt-Out Basis. Individuals have the right to opt-out. Such communications may be sent on Opt-Out Basis. Corporate subscribers have the right to opt-out. 5 should cease as soon as possible. The UK GDPR may not apply to every act of calling, e.g. if telephone numbers are called at random. However, the PECR will still apply in such cases.

 

Such calls may be made on an Opt-Out Basis. Individuals have the right to opt-out.

Calls must not be made to Individual Contacts registered on the Telephone Preference Service (http://www.tpsonline.org.uk/) (and so numbers should be screened appropriately prior to making such a call).

For every marketing call, the telephone number (or an alternative contact number) must be displayed to the person receiving the call.

Such communications may be sent on Opt-Out Basis. Corporate subscribers have the right to opt-out.

Calls must not be made to Business Contacts registered on the Corporate Telephone Preference Service (https://corporate.tpsonline.org.uk/) (and so numbers should be screened appropriately prior to making such a call).

For every marketing call, the telephone number (or an alternative contact number) must be displayed to the person receiving the call.

Automated calls/ communications

See above for general principles. Data subjects may object to direct marketing at any time, in which case such marketing should cease as soon as possible. The UK GDPR may not apply to every act of calling, e.g. if telephone numbers are called at random. However, the PECR will still apply in such cases.

 

Consent required on Opt-In Basis.

For every marketing call, the telephone number (or an alternative contact number) must be displayed to the person receiving the call.

Consent required on Opt-In Basis.

For every marketing call, the telephone number (or an alternative contact number) must be displayed to the person receiving the call.

 

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