DIRECTORS CHARITABLE FOUNDATION PRIVACY, DATA USE & COPYRIGHT STATEMENT
ABOUT THIS PRIVACY NOTICE
At the Directors Charitable Foundation (DCF) we respect your privacy and commit to protecting your personal data. This part of our privacy notice explains what we do with your personal data, why we want to use it, how we protect it and what rights you have to control or use of it.
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).
This privacy notice applies to the personal data that we process through our interactions with individuals in the course of running our charity. It applies to direct communications and to our website.
INFORMATION ABOUT US
This privacy notice is for the Directors Charitable Foundation (charity number 1168715) collectively referred to as “DCF”, “we”, “us” or “our” in this privacy notice. We collect, use and are responsible for certain personal data about individuals. When we do so we are regulated under the General Data Protection Regulation (“GDPR”), which applies across the European Union (including the United Kingdom) and we are responsible as “data controller” of that personal information for the purposes of the law.
If you want to contact us about any of the points on this notice, or just generally about how we protect your privacy, please email us at email@example.com.
INFORMATION WE MAY COLLECT FROM YOU
We will usually collect the following information: Your name, contact address, email address, telephone number and any other details required for contact.
For the purposes of specific charitable projects and applications we may collect:
Your date of birth;
The names and contact details of individuals connected to the project;
Whether you’re eligible for certain discounts or schemes;
Information about any health or medical conditions that you may have;
Any other relevant information or documentation that you provide us with as part of of a project or application;
In some cases we may have sourced information from publicly available sources, such as LinkedIn and internet searches.
IF YOU VISIT OUR WEBSITE
We may use Google Analytics on our website to track visitor numbers and user activity. We record your computer’s IP address so we can tell how each user and repeat visitor is using our website (your IP address is also a piece of your personal data) as well as browser type and information about technology on the devices you use to access this website. (We may track this data by using cookies)
THE PURPOSE AND LAWFUL BASIS FOR USING PERSONAL DATA
We use personal data for several different purposes, each with its own “lawful basis”. This section describes these in detail and we are required by law to explain this to you.
Where we process personal data for the following purposes:
To contact you regarding our projects and services as a charity.
To ensure that your contact details are correct, so that we are able to comply with our requirements.
To respond to requests for information.
To resolve any disputes.
To comply with our regulatory requirements.
To assess financial vulnerability.
To maintain records for vulnerable applicants, such as those with specific health or medical conditions
To meet legal obligations to verify your identity.
To manage payments or other financial transactions.
To interact with our suppliers to procure and pay for goods and services.
To interact with relevant organisations and individuals to run and develop the charity.
For the detection and prevention of crime, including any investigations into potential fraudulent activity.
For management information reporting purposes.
- we do so on the “lawful basis” that this processing is necessary as part of our work as a charity in order for us to act together for a legitimate interest, to comply with a legal or regulatory obligation and to provide you with information about our work in accordance with any contact or marketing preferences of which you may have advised us.
Subject to your marketing preferences, or where you have otherwise expressly consented, we may send you relevant information about the DCF and its activities that we think you’d benefit from.
We will never sell your data to third parties for marketing purposes. However, subject to your marketing preferences, we may send you recommendations about third party products and services that could be of interest to you. This information could be sent to you via text, telephone, email or post. You can opt in or opt out and update your marketing preferences at any time by contacting us (see “how to contact us” below) or by other methods such as by clicking on “unsubscribe” or “preferences” links in emails, or by visiting an online account if set up.
WHETHER INFORMATION HAS TO BE PROVIDED BY YOU AND IF SO WHY?
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a service or payment). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may use a number of different service providers (acting as ‘data processors’) who provide services to enable us to operate our charity and the services we may provide to you. Your personal data may be anonymised and is only transferred to (and stored by) these service providers (as our ‘data processors’) under the following categories:
Website and data hosting;
IT and system administration;
Email, contacts and calendar;
CRM, client services and billing or payments;
Engineering and metering.
These ‘data processors’ only process data on our behalf, they won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law.
OTHER THIRD-PARTY RECIPIENTS
We may also share your personal data with the following third parties in certain circumstances:
Credit reference and debt collection agencies;
Law enforcement or regulatory authorities (such as tax authorities) if required by applicable law;
Professional advisors such as lawyers, bankers, accountants or auditors in order to provide legal, finance, accounting or auditing services.
For security reasons we do not name our service providers or other third-party recipients in this privacy notice. The types of personal data we hold about you (and that may be transferred to our data processors) are set out above. Please contact us (see below) if you want further information on specific data processors, other third-party recipients or the types of personal data they process for us.
INTERNATIONAL TRANSFERS OF PERSONAL DATA, AND SAFEGUARD MEASURES IN PLACE
We do not directly transfer any of your personal data outside the European Economic Area (EEA). However, some of our data processors may do so and this section explains the impact of these international transfers and how your information is protected.
Some of our data processors operate “cloud-based systems”, which means the information is held in information data centres in different locations. Most of them reserve the right to hold copies of your personal information outside the EEA. Please note that the reason companies may choose to do this is to hold back-up copies, so they can guarantee recovery.
In each case our processors employ one or more of the following mechanisms that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of abuse:
Certain processors may only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
Providers storing data in the US, may be self-certified to the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield;
Certain service providers may use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We’ll only store your personal data for as long as is necessary to fulfil the purposes outlined in this privacy notice or for as long as reasonably necessary to establish, exercise or defend our legal rights. Some data may be retained in line with statutory and regulatory requirements such as:
To comply with the minimum regulatory retention requirements as set by industry regulators, grant giving bodies or government departments;
To comply with the statutory retention periods for accounting records, as set by the legislation and HM Revenue & Customs;
To comply with the retention periods set by the TRAS Fraud Prevention Agency.
Our retention periods are not governed by statutory or regulatory requirements, they are based on practical justifications, which have been set in accordance with the principle of retaining personal data for no longer than is necessary for the purposes for which it is processed. These include enabling us to support projects, supply you with services, allowing us to resolve any disputes or complaints and for detection and prevention of fraud.
YOUR PERSONAL DATA RIGHTS
The personal data we hold about you is your data, so you have certain rights over the data under the GDPR. This section summarises your rights and how you can exercise them (generally free of charge).
You have the right to request a copy of all personal data we hold relating to you. You also have the right to require us to correct any mistakes in the personal data we hold relating to you.
Where we are processing your data based on your consent you can withdraw that consent and we must immediately stop processing your data. Please note that up to that point, we’re acting lawfully with your consent, withdrawal of consent cannot be backdated.
Where we process your data based on a “legitimate interest” (see the section on “purpose and lawful basis”, above) you still have the right to object to our processing of that data if you feel it impacts on your fundamental rights and freedoms. From the point of that objection, we must stop processing your data until we have determined whether your rights override our interests.
You also have the right to object where we are processing your personal data for direct marketing purposes. The easiest way to do this is to contact us directly, or if available, to use an unsubscribe link at the bottom of all marketing emails.
In certain situations, you have the right to require us to erase personal data where there is no good reason for us continuing to process it. However, note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following situations:
(a) If you want us to establish the data’s accuracy;
(b) Where our use of the data is unlawful but you do not want us to erase it;
(c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
(d) Where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Finally, you have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated processing of information about you, which we carry out based on your consent or whre it is necessary to perform a contract with you.
For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of these rights, the easiest way is to email us (see “How to contact us” below).
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 try to respond to all legitimate requests quickly but in any event within 30 days. Occasionally it may take us longer 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.
At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office (ICO). Please refer to the ICO at https://ico.org.uk/concerns/ or by calling them on 0303 123 1113. Of course, we hope that we can resolve your issue quickly and fairly ourselves.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, Trustees and other directly related third parties who have a specific need to know. They alone process your personal data and they are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
OTHER PURPOSES FOR PROCESSING PERSONAL DATA
We don’t process your personal data for any other purpose than we’ve described here. We won’t pass on or sell your personal data to anyone else.
As we develop our activities and services, we might add new data processes that use your personal information. Should we decide that we want to develop a new processing purpose, we will contact you to let you know what we intend to do, the lawful basis we will use, and your rights over our intended new processing. We’ll also publish information about it here.
The DCF does not track or identify public individual users of the website and no data pertaining to public individual users is held or disclosed for any purpose, except where users are sending emails or entering data in forms or other communications to or via this website. Such communications are subject to the GDPR and also to general and specific conventions and laws pertaining to abuse, slander, libel & etc and all rights are reserved to remove communications that may breach such conventions and laws.
HTTP requests are logged, identifying the originating IP address of user agents requesting a URL only for the purpose of maintenance and an anonymised statistical log file analysis which may be used or published.
From time to time we may run competitions on our website. As part of such competition, we may ask you for contact information. You may opt-out of receiving future mailings as above. Where appropriate the website will offer opt-out from receiving promotional/marketing information from our partners and from us.
The website may contain links to external websites. We are not responsible for the privacy policies or the content of external websites, nor for their security - the use of external links is at your own risk.
We make every effort to secure data held on this website but the DCF cannot guarantee the security of your data during transmission to or from our website and such transmission is at your own risk.
The information on the website is provided without warranty of any kind, either express or implied and neither the DDCF nor any of the contributors to the site can accept any responsibility or liability for any loss which may arise from any reliance on such information nor for any typographical or other errors or omissions within any web page. The content of the website is for general guidance only and should not be regarded as constituting legal or business advice or opinion. Legal and business advice should be sought and taken in relation to the specific circumstances of each case and nothing appearing on this site is intended to be a substitute for obtaining specific legal and/or business advice from a competent professional.
The DCF makes every effort to ensure the accuracy and truthfulness of material it publishes and will correct mistakes if notified. Personal views expressed in articles on this website are not necessarily those of the DCF.
All content supplied by the DCF including pages and content on the website are protected by copyright. Pages and content may be downloaded or printed for personal use but shall not be distributed or copied for any commercial purpose or used in any other work or publication without permission.
This privacy notice was updated on 22nd May 2018.
If you have any questions, concerns or just want some more information about our privacy management, drop us a line at firstname.lastname@example.org
The Directors Charitable Foundation is a charitable incorporated organisation, Charity No. 1168715. Registered Office: 3rd & 4th Floor, 22 Stukeley Street, London, WC2B 5LR.