There has been a lot of hubbub around wealth screening and we know many people are still confused about what it is and how you can do it and be ‘GDPR’ compliant.
The most important thing to remember is that wealth screening is not and has never been illegal. Like any other data processing, you just need to carefully plan your approach to minimise the privacy impacts and be very clear with your supporters about what you are doing.
Here are three things to consider to ensure any wealth screening or prospect research you undertake is up to scratch.
Put privacy by design at the heart of your relationship with your supporters
Building open and honest relationships with your donors and supporters is the way forward when it comes to best practice fundraising. Transparency is key.
Open communication about why research and wealth screening is a fundamental part of good fundraising will build strong and loyal relationships and allow you to explain to your supporters the importance of philanthropy.
Review and document your legal basis for the research
The most common legal grounds for processing data for fundraising-related purposes
- Legitimate interest which must be balanced against the rights of the individual and is normally combined with the provision of fair processing.
- Consent in which the data subject has given their consent to your processing of their data.
One is not legally better than the other, they are simply appropriate to rely on at different times.
Most organisations are relying on Legitimate Interest for prospect research and wealth screening.
If you are going to rely on legitimate Interest, make sure you do a Legitimate Interest Assessment which includes a balancing test to ensure that your research won’t infringe the rights of the individuals that you are researching.
Be clear in your Privacy Notice about the prospect research and wealth screening you are doing
Make sure your privacy policy is fit for purpose and informs your supports how their data might be processed in line with GDPR guidelines. Your privacy notice needs to be clearly accessible to your supporters via your website and on any sign-up forms or mailing lists that collect their data. Keep your supporters in the loop when you make any changes to your privacy notice and make sure it’s easy for them to opt out of any specific aspects of your processing.
When describing your research and wealth screening, make sure you cover the following points:
- Why you do the research and the importance of it for your fundraising
- The types of research you undertake eg. wealth screening, financial analysis
- Your data sources, including a brief outline of any public information you use
- Any use of third parties, possibly naming them and specifying the activities they undertake for you
- Your legal basis for the activity, ie a summary of your legitimate interest
- Details of how people can opt out of the processing
We’re experienced in managing day to day compliance with data protection and other fundraising regulation. Get in touch with us at info@prospectingforgold.co.uk and we’ll assist you with practical advice and guidance.