Privacy Policy គោលនយោបាយឯកជនភាព
Reconnecting Cambodia ("RC", "we", "us") helps people separated from their Cambodian families to find and reconnect with their relatives. We are a charitable incorporated organisation in England and Wales [registration with the Charity Commission pending / registered charity number XXXXXXX].
Address: Flat 27, St Marys Mansions, St Marys Terrace, London W2 1SQ, United Kingdom
Privacy contact: privacyreconnectingcambodia@gmail.com
RC is one of three independent organisations that work together as the Reconnecting Cambodia Project. The others are DNACambodia in the Netherlands, which runs the DNA testing and family-tracing programme, and the Khmer Family Charity Organisation (KFCO) in Cambodia, which provides local outreach and support. Each organisation is responsible for the personal information it handles.
This notice in brief
This notice explains how RC uses personal information when you contact us, sign up to our newsletter, donate, come to our events or visit our website.
If you take part in DNA testing, DNACambodia decides how your DNA information is used. Its privacy notice explains this in full. When we collect samples at our UK events we do so on DNACambodia's behalf and keep no copies.
We never sell your information. We only share it as described in section 5.
You can ask us at any time what we hold about you, and ask us to correct or delete it.
What we collect and why
What you do
Contact us by email or through our website form
Give a DNA sample at one of our events in the UK
Sign up to our newsletter
Join our Cambodia’s Lost Children Facebook group or message us on Messenger
Make a donation to RC
Come to one of our events
Work with us as a partner, supporter or professional contact
Visit our website
What we collect
Your name, email address, and anything you choose to tell us, which may include your family history
Your completed consent form and your DNA sample, linked to a testing kit. We photograph your consent form to send it to DNACambodia. If you agree, we also take a photograph of you holding a sheet with your name and kit number, so DNACambodia can check your sample is linked to the right person. You can say no and still take part. If you ask at an event for DNACambodia to contact you, we pass your details on in the same way.
Your name and email address
Your Facebook name and profile, your posts and messages, which may include your family history
Your name, contact details, the amount and date, and your Gift Aid declaration if you make one. Card details are handled by our payment provider and we do not see them.
Your name and contact details if you sign up. Photos or video of the event.
Information about how you use the site, collected by Google Analytics cookies: pages viewed, time on page, device type and approximate location
Your name, organisation, role and contact details
Why we use and our lawful basis
To reply to you and, if you are searching for family, to put you in touch with the right organisation. Lawful basis: legitimate interests in responding to people who contact us. If you tell us about your family history or Cambodian origin, we use that only with your explicit consent, which you give by sending it and can withdraw at any time.
Note: enquiries about DNA testing made through the website form go directly to DNACambodia, which handles them under its own privacy notice.
We collect these on behalf of DNACambodia, which runs the DNA testing programme and decides how this information is used. DNACambodia is the controller and we act as its processor, following its instructions.
DNACambodia’s privacy policy explains how your DNA information is used, shared and kept: [link to DNACambodia privacy notice].
To send you news about our work, events and appeals. Lawful basis: your consent. Every email has an unsubscribe link. We keep a record of when and how you signed up. At events, signing up is always separate from giving a DNA sample.
To process your gift, claim Gift Aid and thank you. Lawful basis: legal obligation for Gift Aid and accounting records. Legitimate interests for thanking you and keeping in touch, which you can stop at any time.
Until RC is registered: donations made through the Donate page are received by DNACambodia in the Netherlands, which handles your details under its own privacy policy: [link]. Gift Aid cannot be claimed on these donations.
To run the group and reply to you. Lawful basis: legitimate interests. Anything you share about your family history or origin is used only to help with your search. Facebook (Meta) also processes your information under its own privacy policy.
To organise the event and keep in touch afterwards if you ask us to. Lawful basis: legitimate interests. We ask before we publish a photo or video in which you can be identified, and we remove it if you change your mind. Event photos are separate from the identification photographs taken for DNA testing, which we never publish or keep.
To understand how the site is used and improve it. Lawful basis: your consent. Analytics cookies are only set if you accept them in our cookie banner. You can change your choice at any time.
To manage our relationship and cooperate on our work. Lawful basis: legitimate interests.
How long we keep it
[24] months after our last contact with you
Photographs are sent to DNACambodia within [3] working days of the event. Samples go to the laboratory within [10] working days. Original forms are posted to DNACambodia within [10] working days of the event.
We delete all photographs and keep no copies within 5 working days of DNACambodia confirming it has received the photographs.
Until you unsubscribe
Messages: [24] months after our last contact. Posts: until you delete them or the group closes.
Six years after the end of the financial year of your last gift, as HMRC requires for Gift Aid
Sign-up details: [12] months. Published photos: until you ask us to remove them.
[14] months (Google Analytics setting)
For as long as we work together, then [2] years
Sensitive information
Some information is especially sensitive under data protection law. In our work this can include information about your ethnic origin, your family history and your genetic relationships.
We do not hold DNA results or DNA profiles. These are held by the testing providers and managed by DNACambodia.
If you tell us about your family history or origin, we use it only to help with your enquiry, and only with your explicit consent.
Only RC trustees and volunteers who need it to help you can see it.
Who we share information with
DNACambodia (Netherlands): when you ask about DNA testing or family tracing, and for DNA samples and consent forms collected at our events.
KFCO (Cambodia): only if you are in Cambodia, ask for local help, and agree to us passing on your details.
Service providers who run systems for us under contract and only on our instructions: Squarespace, Google Workspace, and Canva.
HMRC, when we claim Gift Aid on your donation.
Regulators, the police or the courts, only where the law requires it or to protect someone from serious harm.
Sending information outside the UK
DNACambodia is in the Netherlands. The UK recognises countries in the European Economic Area as protecting personal information to the same standard, so no extra safeguard is needed.
Some of our service providers store data in the United States. We use providers covered by the UK–US data bridge or by contract terms approved by the Information Commissioner.
We only pass your details to KFCO in Cambodia if you ask for local help and agree to it.
Your rights
You have the right to:
ask for a copy of the information we hold about you
ask us to correct information that is wrong or incomplete
ask us to delete your information
ask us to limit how we use your information, or object to our using it
stop us sending you newsletters or appeals, at any time
withdraw your consent where we rely on it, without affecting what we did before
ask us to send information you gave us to another organisation in a common format
To use any of these rights, email privacyreconnectingcambodia@gmail.com. We will reply within one month. For your DNA information and DNA testing records, contact DNACambodia, which holds them. If you contact us about them, we will pass your request to DNACambodia within 5 working days.
Complaints
If you are unhappy with how we have handled your information, please tell us first at privacyreconnectingcambodia@gmail.com. We will acknowledge your complaint within 30 days and tell you the outcome as soon as we can.
You can also complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint, telephone 0303 123 1113. For complaints about DNACambodia, you can contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Keeping your information safe
Access to personal information is limited to the trustees, volunteers and administrative assistant who need it. Our accounts use multi-factor authentication. Paper consent forms collected at our events are kept locked and in the care of a named RC representative until they are sent to DNACambodia. Photographs of consent forms are sent securely to DNACambodia and deleted from our devices and accounts within 5 working days of it confirming receipt. We keep no copies.
Children
Our website, newsletter and events are aimed at adults. DNACambodia’s DNA testing programme is for adults aged 18 or over, so we do not collect DNA samples or consent forms from anyone under 18.
If you are under 18 and thinking about searching for your family, you are still very welcome to talk to us. We can give you general information and advice, and explain how you can take part when you turn 18. We encourage you to involve a parent, guardian or another adult you trust. We keep only the details we need to reply to you.
Changes to this notice
We review this notice at least once a year and whenever our activities change. The date at the top shows when it was last updated.