Charles S French Charitable Trust

 

PRIVACY POLICY

WHO WE ARE AND WHAT WE DO
The Charles S French Charitable Trust (referred to as "the Trust", "we", "us" or "our" in this privacy policy) has a principal objective of providing grant giving support to a wide range of charitable activities, primarily within Essex and North East London, whilst maintaining and developing the value of the Trust's investments and assets.

The Trust is a data controller and responsible for your personal data.

Our data protection lead is Jamie Foster, one of our trustees, who can be contacted at office@csfct.org.uk. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data protection lead.

We respect your privacy and is committed to protecting your personal data and the personal data of anyone on whose behalf you contact us. This privacy policy will inform you as to how we look after personal data and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Your visit to our website (which is referred to as the "Site") and any communication with us is subject to the terms set out in this privacy policy. Please read the following carefully to understand our views and practices regarding personal data and how we will treat it.
This policy is updated from time to time. The latest version updated on 25 May 2018 is published on this page of the Site. All updated versions of the policy will be published on the Site.

INFORMATION WE MAY COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our Site or correspond with us in person or by letter, phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of.
We may collect, use, store and transfer different kinds of personal data which we have grouped together follows:

a. Identity Data which includes the first name, last name, username or similar identifier, marital status, title, date of birth and/or gender of you and others you are acting on behalf of.
b. Contact Data which includes your email address and telephone numbers
c. Health Data which includes any information about a person's health on whose behalf you contact us including medical history and/or current health status.
d.

Technical Data which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.

e. Marketing and Communications Data which includes your preferences in receiving marketing from us and third parties and your communication preferences.

We may collect Special Categories of Personal Data (as defined in GDPR). This includes details about individuals' health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation. We do not collect any information about criminal convictions and offences.

It is important that the personal data we hold about you and individuals on whose behalf you contact us is accurate and current. Please keep us informed if any personal data changes during your relationship with us.

KEEPING PERSONAL DATA SECURE
We know that data security is important to you and it is therefore important to us. We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those trustees, employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions in accordance with this policy and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW WE WILL COLLECT PERSONAL DATA
You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us by letter, phone, e-mail or otherwise. This includes personal data you provide when you:

-
visit our Site;
-
make a request for a grant from us;
-
give us information to enable monitoring of grants provided;
-

give us information as a supplier or tenant of the Trust;

-
request marketing communications to be sent to you;
-
give us some feedback.

WHY WE WILL USE PERSONAL DATA
The lawful bases for processing personal data are set out in Article 6 of the General Data Protection Regulation (GDPR). We may process personal data on more than one lawful ground depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal ground we are relying on to process any personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data:

a. Consent: you have given clear consent for us to process personal data for a specific purpose.
b. Contract: the processing is necessary for a contract we have with you or because you have asked us to take specific steps before entering into a contract.
c. Legal obligation: the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations).
d. Vital interests: the processing is necessary to protect someone's life.
e.

Legitimate interests: the processing is necessary for our legitimate interests (for example to administer and maintain our website) or the legitimate interests of a third party unless there is a good reason to protect personal data which overrides those legitimate interests. We make sure we consider and balance any potential impact on you and anyone on whose behalf you are acting (both positive and negative) and your and their rights before we process personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden by the impact on you or anyone on whose behalf you are acting (unless we have relevant consent or are otherwise required or permitted to by law).

We rely on the following legitimate interests when processing personal data:

- To make grants in accordance with our charitable objects;
- To manage the Trust and comply with our obligations to our tenants and suppliers;
- To protect our proprietary and commercially sensitive information;
- To protect our proprietary and commercially sensitive information;
To administer and maintain our Site.

We also need to satisfy specific conditions for processing certain Special Categories of Personal Data, in particular which we may receive about individuals for whom grant funding is requested. We rely upon the following grounds in this regard:

f The data subject has given explicit consent to the processing of their personal data.
g Processing is necessary in the course of our legitimate activities as a not for profit body in accordance with article 9(2)(d) of GDPR.

Click here to find out more on the Information Commissioner's Office website about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing personal data. However, where we do ask for consent we will do so in order to comply with the principle that any processing must be lawful, fair and transparent.

DISCLOSING PERSONAL DATA
We may have to share personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow our third-party service providers to use personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Examples of our third parties include:

a. Sub-contractors for the performance of any contract we enter into with them or you;
b. Service providers acting as processors who provide IT and system administration services,
c. Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.

We do not transfer your personal data outside the European Economic Area (EEA).

COOKIES
Consider whether you want a digital log of your visit to our Site to be recorded in your browser. If you don't want a record to be kept, you can choose to delete your browser history afterwards or view our pages in incognito mode / private browsing, which won't store your browser history, cookies, or search history after you've closed your browsers. However, you are not invisible. Using incognito mode / private browsing does not hide your browser history from your internet service provider, us or your employer (if you are using a company device).

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.

CHANGE OF PURPOSE
We will only use personal data you provide us with for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing for the purpose of contacting you about the Trust's activities.

We may use your Identity, Contact and Technical Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

HOW LONG WE WILL KEEP YOUR DATA
We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain personal data in accordance with our policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to access the Information Commissioner's Office website to find out more about these rights:

a.   Request access to your personal data.
b.   Request correction of your personal data.
c.   Request erasure of your personal data.
d.   Object to processing of your personal data.
e.   Request restriction of processing your personal data.
f.    Request transfer of your personal data.
g.   Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us. If you are unhappy with how we are processing your personal data, you have the right to complaint to the Information Commissioner Office. The Information Commissioner can be contacted at:

 

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

  https://ico.org.uk/concerns/

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Charles S French Charitable Trust - Charity number: 206476