Data Protection Policy

Version 2.0  |  Reviewed and updated: July 2026  |  Next review due: July 2027

About this Policy

1.1:  Justice First Ltd collects personal data for a variety of purposes relating to its charitable functions. It is the duty of the charity’s trustees to ensure that the personal data we hold is appropriate and sufficient for these purposes.

1.2:  We may collect, use and store personal data, as described in this Data Protection Policy and as described when we collect data from you.

1.3:  We may change this policy from time to time. The current policy can be obtained from www.justicefirst.org.uk

1.4:  We will always comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 when dealing with your personal data. Further details on the UK GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the UK GDPR, Justice First Ltd will be the “controller” of all personal data we hold about you.

Who are we?

2.1:  We are Justice First Ltd. We can be contacted at Justice First Ltd, 133 Norton Road, Stockton-on-Tees TS18 2BG. Phone: 01642 601122. You can contact us by email using our website www.justicefirst.org.uk

What information we collect and why

Type of information

Client name, address, telephone numbers, email address(es), identity information, personal data, immigration status, Home Office reference numbers, immigration records and correspondence

Employee name, address, telephone number, identity details in relation to right to work, DBS report.

Volunteer name, address, telephone number, email address(es).

Trustee name, address, telephone numbers, email address(es), DBS record.

Donor name, address, email address(es) when available.

Purposes

Data is collected to support any applications we make on your behalf to government agencies or departments, including the Home Office, and to provide immigration legal advice and casework.

To be able to fulfil our responsibilities as an employer.

Contacting volunteer.

Contacting trustees and ensuring that they can legitimately act as trustees.

To provide donors with information about the activities of the charity and good relationships with our donors and to collect Gift Aid where permission has been provided.

Legal basis of processing

Legitimate interest in support of our clients in line with our charitable registration. Legal obligation where we are required to share information with the Home Office or other statutory bodies.

Fulfilment of employment contract. Duties under employer liability insurance arrangements.

Legitimate interest in support of the charity’s activities.

Legal requirement.

Legitimate interest in maintaining good relationships with our donors. Legal requirement in relation to Gift Aid.

Special Category Personal Data

3.1:  In the course of providing immigration legal advice and casework, Justice First Ltd necessarily processes special category personal data as defined under the UK GDPR. This may include information relating to a client’s racial or ethnic origin, religion or belief, health, and criminal convictions or offences. Such data is treated with the highest level of care and confidentiality.

3.2:  We only process special category data where it is necessary for the purposes of providing legal advice and casework support, and where we have either obtained explicit consent or are relying on another lawful basis under Article 9 of the UK GDPR, such as the establishment, exercise, or defence of legal claims.

3.3:  We recognise the particular sensitivity of immigration-related personal data, including Home Office records, immigration history, and correspondence with government agencies. All such data is stored securely, accessed only by authorised staff, and shared only where necessary and lawful to do so.

How we protect your personal data

4.1:  We will not transfer your personal data outside of the United Kingdom without your consent.

4.2:  We have implemented generally accepted standards of technology and physical security to protect personal data from loss, misuse, or unauthorised alteration or destruction.

4.3:  If you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

4.4:  We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

Who else has access to the information you provide us?

5.1:  We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs 5.2 and 5.3 below.

5.2:  We may pass your personal data to third parties who are service providers to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to manage payroll services). We do this to fulfil our legitimate interests in operating the charity and for supplying services to our clients. However, we disclose only the personal data that is necessary for the third party to deliver the service and we only use a service that ensures information is kept securely and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub-processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.

5.3:  We will also pass on personal data of our clients to government agencies or departments, including the Home Office, when providing appropriate support with immigration applications, appeals, or other casework. We will only provide sufficient information in pursuit of our clients’ legitimate interests. It is the duty of government agencies and departments to ensure that any data is held securely.

How long do we keep your information?

6.1:  We will hold personal data on our systems whilst providing support and for as long afterwards as it is in Justice First Ltd’s legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will hold data in respect of employees, trustees and volunteers for as long as it is necessary to comply with legal obligations and to fulfil contractual duties in relation to employer liability. We will review personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.

Your rights

7.1:  You have rights under the UK GDPR:

  • to access your personal data
  • to be provided with information about how your personal data is processed
  • to have your personal data corrected
  • to have your personal data erased in certain circumstances
  • to object to or restrict how your personal data is processed
  • to have your personal data transferred to yourself or to another organisation in certain circumstances

7.2:  You have the right to take any complaints about how we process your personal data to the Information Commissioner: https://ico.org.uk/concerns/

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF
Tel: 0303 123 1113

For more details, please address any questions, comments and requests regarding our data processing practices to the Trustee who oversees our processing of data, Fred Hutchinson, at Justice First Ltd, 133 Norton Road, Stockton-on-Tees TS18 2BG. Phone: 01642 601122. You can contact him by email using our website www.justicefirst.org.uk

Reviewed and updated: July 2026.
Next review due: July 2027