Privacy, data use, cookies and other terms.

Privacy and data

1. Definitions and credit
1.1 In these provisions: “we”, “us” and “our”  refers to DAFSC Ltd as owner and manager of the Best Free Speech Practice (“BFSP”) project and website (and related databases and email and newsletter functions) (“this website”) and campaign (for more information about us, see Section 14 and elsewhere in this website), and where relevant includes all persons appointed by us as administrators or managers of any campaigns; “members” means people who have registered their details with BFSP through this website; “our campaign” means activities connected with promoting, serving and protecting free speech in universities and elsewhere, and fundraising activities for our campaigns.

1.2 Credit: this document was created using a template from Docular ( Thank you.

2.   Preliminary

2.1 We are committed to safeguarding the privacy and data of BFSP members and website visitors.

2.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

2.3 Our reputation for integrity and protecting our community’s privacy are important to us. We use cookies on our website. Insofar as those cookies are ones that we consider not strictly necessary for the appropriate provision and functioning of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

3. The personal data that we collect and process

3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

3.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address. The source of the contact data is you.

3.3 We may process BFSP membership registrations. This data will include name, email, and any other information provided by you from time to time (“membership data”). The source of this data is your registering through our website and database functions, which operate using a small number of external service providers, such as our newsletter function.

3.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“), including in respect of free speech related campaigns and activism. The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website registration functions.

3.5 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

3.6 By registering with us and by using our website, you consent to our retaining the information you provide and using it for these purposes. Please do not register if you do not wish to give this consent. If you want to withdraw this consent, you may unsubscribe at any time by [provide information] giving the email address you want removed, and we will delete that email and all associated information.

4.  Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2 Relationships and communications and our campaigns – We may process contact data and/or communication data for the purposes of communicating with you (excluding communicating for the purposes of direct marketing, which is dealt with below) by email or by other means if you have provided those means. The legal basis for this processing is our legitimate interests, namely communications with our members and website visitors, the maintenance of relationships, the establishing, promoting, managing and supporting the Association and its member campaigns, and the proper carrying on and administration of our website and campaigns.

4.3 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our campaigns. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and campaigns generally.

4.4 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our campaigns in accordance with this policy.

4.5 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.6 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others
5.1 Your personal data held in our website database will be stored on the servers of our hosting and/or website support services providers (Mailchimp) and Google analytics ( and such other such providers as we may use from time to time. If you donate to BFSP using an independent service provider, we will not receive any information you provide to them, and we are not responsible for the provider’s use of any data you provide to them.

5.2 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect our or your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.3 Protecting your privacy and data are important to us, and we will not otherwise pass your data to other third parties.

6. Retaining and deleting personal data
6.1 We will retain your personal data to the extent required by law, but subject to that our intention is not to hold it for longer than necessary and to delete it as soon as appropriate following your unsubscribing from this website.

7. Your rights
7.1 In this Section 7, we have listed the rights that you have under data protection law.

7.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent in respect of future use.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting the Information Commissioner’s Office website.

7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.


8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use
9.1 We use a limited range of cookies for the following purposes:
(a) authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;
(b) analysis – we use cookies to help us to analyse the use and performance of our website and services; and
(c) cookie consent – we may use cookies to store your preferences in relation to the use of cookies more generally.

10. Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. These are for the functioning as intended of our website and related databases and other functions.

10.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting and you can review Google’s privacy policy at

11. Managing cookies; consent
11.1 We regard all the cookies we use as essential to the proper functioning of BFSP and our website and campaigns, and of legitimate interest to us. You can disable or block cookies as described below, but blocking all cookies will have a negative impact upon the usability of many websites and if you block cookies, you will not be able to use all the features on our website. If you browse or use our website and services without disabling cookies on your browser, you are consenting to the presence and operation of all cookies on the BFSP website and other websites we use to provide our services, and (so far as we are concerned but without prejudice to your rights against those other sites) on any other websites you visit using links from our site. Please do not use the BFSP website or become a member of BFSP or join or receive our campaigns or those of third parties if you do not want to proceed on this basis.

11.2 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) (Chrome);
(b) (Firefox);
(c) (Opera);
(d) (Internet Explorer);
(e) (Safari); and
(f) (Edge).


12. Amendments
12.1 We may update these policies and terms from time to time by publishing a new version on our website. By joining BFSP and/or using this website, you agree that the revised version of these policies and terms from time to time will apply as between, and be binding on, us and you.

12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

13. Our details
13.1 The BFSP website is owned and operated by us.

13.2 You can contact us (including about data protection matters) by email, using the email address published on our website.

14. Terms and Information

14.1 By using this website and having access to the information and functions in it, you:

(a) acknowledge and agree that: (i) we have not verified and are not responsible for third party information on this website, (ii) we have not created and therefore have limited knowledge of and no responsibility for the functions created or supplied by third parties we are using in connection with this website (or for the workings or effects of those functions), (iii) we have no knowledge of, and are not responsible for, the policies and behaviour of third party websites (and their owners, controllers and managers) to which there are links on this website, in respect of privacy, data management cookies or any other matters, and (iv) we do not control and have limited influence over the behaviour of Association member campaigns, which are independent parties;

(b) acknowledge and agree that: (i) information provided on this website is being provided for free, and that no kind of agreement or contract is created between you and us by virtue thereof or by your visiting or use of this website; and (ii) we have no responsibility or liability to you for any information in or in respect of, or any other matter or event relating to, BFSP or this website or any information or documents provided by BFSP and any associated databases and other functions by virtue of your visiting and use of this website, and actions consequent on or connected with such visiting or use, or otherwise howsoever;

(c) agree not to use or misuse any intellectual property (whether registered or unregistered) of DAFSC’s in connection with this website, including without limitation the BFSP and DAFSC names; and in respect of the documents which we are making available accept and agree to the provisions and obligations on the users’s part specified in our Copyright and Permissions page [link].

(d) agree to use this website responsibly and not to use it so as to cause other persons (whether DAFSC or others) harm or damage; and

(e) acknowledge and agree that this website relates to free speech in the United Kingdom, and does not purport to have relevance to free speech or relevant laws in any other jurisdiction.