GENERAL PRIVACY NOTICE
YOUR PERSONAL DATA – WHAT IS IT?
“Personal data” is any information about a living
individual which allows them to be identified from that data (for example a
name, photographs, videos, email address, or address), such individual being a
“Data Subject “. Identification can be by the information alone or in
conjunction with any other information. The processing of personal data is
governed by the Data Protection Act 1998, the Data Protection Act 2018, the
General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation
relating to personal data and rights such as the Human Rights Act 1998. The
GDPR came into effect on 25 May 2018.
WHO ARE WE?
We are the current Charity Trustees of The Athlone
Trust CIO (“the CIO”) which is a Charitable Incorporated Organisation set up
under the Charities Act 2011 and the Charitable Incorporated Organisations
(General ) Regulations 2012 and incorporated and registered with the Charity
Commission under no 1188225 on 27 February 2020. On 17 August 2020 under a
Transfer Agreement of this date and with the consent of the Charity Commission
the CIO acquired all the assets and liabilities of The Athlone Trust (“the
Trust”) a charitable trust registered with
the Charity Commission under no 277065, with the intention being for the Trust to be
merged with the CIO, once all the assets
have been transferred to the CIO, and
then removed from the Charity Commission’s register of charities .The CIO
intends to take over all the obligations of the Trust in as seamless a manner
as possible.
Like the Trust the CIO is a small grant-making charity
with limited funds and the objects of the CIO are to provide financial
assistance for adopted children with special needs. We consider applications
for funding twice a year in May and November and award grants on merit. We also
engage in fund raising each year. We are governed by the CIO’s Constitution and under this the CIO is
administered by the Charity Trustees of which the present Charity Trustees are listed at the end of this
Notice. The CIO is regulated by the Charity Commission. The Charity Trustees as
a body are the Data Controller for the purpose of the GDPR and as required by
the GDPR this Privacy Notice is provided by the Charity Trustees.
WHAT PERSONAL INFORMATION DO WE HOLD?
We hoid
A. Personal Information relating to the beneficiaries
of the CIO and the Trust
B. Personal information relating to donors to the CIO
and the Trust
C. Personal information relating to fund raisers
NB For convenience we have prepared three sub-notices one
for each of the above sections of this main Notice to be sent out to each
category of data subject.
A. Personal information relating to the beneficiaries
of the CIO and the Trust
1. What does the information comprise?
Personal information is provided by each applicant in
the Application Form required to be completed for every application for funding
comprising
* the names, ages and marital status of each applicant
and their addresses, email addresses and telephone numbers
* the names, ages, and sexes of each adopted child for
whom the applicant seeks assistance and of any other children in the family of
the applicant
* the adoption certificate or order for the adopted
child the subject of the application
* the details of the schools and academic records of
such adopted child
* details of disabilities, physical and mental, for
such child and other members of the family; medical , social and educational
records;
* details of such child’s earlier life and relevant
family history
* financial details – income and expenditure and
assets and liabilities of the family and such child with evidence of income
* particulars of the schools where assistance with
fees is requested and details of other grants and bursaries;
* the amount of the grant requested and for what
period;
* full reasons for the application
2. How do we use and process this information?
The Application Forms and the accompanying papers are
intended to provide us, the Charity Trustees, with all the information necessary
to enable us to decide whether to award a grant and if so how much and for what
period of time. The applications are all carefully considered by us at meetings
of the Charity Trustees held twice a year in May and November. As Charity Trustees
we have to exercise our powers properly and fairly and as we have a complete
discretion our decisions have to be made unanimously and awards of grants are
made according to the merits of each application. Once made the Chairman writes
to the applicants with the decision of the Charity Trustees in each case. No
reasons are given for the decision in each case.
No applications will be considered unless the
following conditions are satisfied
* The child for whom financial assistance is required
is adopted in the United Kingdom or overseas in an adoption process recognised
in the United Kingdom. Original adoption certificates or orders must be
produced before any grant is awarded
* the child for whom funding is sought is under the
age of 18 or if older in fulltime secondary education. A child at university
would not be eligible;.
* the child should have some disability, physical or
mental , such as emotional or behavioural problems. Evidence in the form of
reports must be provided.
For a grant to be awarded it must be for educational
purposes for the benefit of the child such as for tuition fees or towards fees
for schools providing for special educational needs, or for special educational
equipment, computer equipment, musical instruments, or therapy sessions. This
list is for illustration purposes only and not intended to be exclusive or
limited. The grants awarded towards school fees are generally in the
region of £200 to £750 per child per term for one to two academic years. If, at
the expiry of a grant, further funding is required a further application must
be made.
All applicants’ financial positions are examined
closely and the details of income and expenditure, assets and liabilities must
be clear and fully supported by bank statements, letters re benefits from the
DWP, PAYE slips or tax assessments. Full details of bursaries, other grants or
assistance from other members of the family must also be provided.
When an offer of a grant is accepted the applicant is
requested to ask the school in question to send invoices to the Chairman at the
beginning of each term. These will then be settled by cheque or by online
transfer. In cases of tuition fees or purchases of equipment the applicant will
be reimbursed by cheque the cost against receipted invoices.
The Application Form and accompanying papers are
shared only between the Charity Trustees. The Chairman and the Treasurer keep
schedules of children for whom grants are awarded with details of amounts,
duration, schools, payments made and payments due. The schedules are kept both
in paper form and electronically in order to control the grants and payments of
invoices and these are updated as new grants are awarded and grants expire.
These are referred to at our Charity Trustees’ meetings when we consider our
financial position and our commitments.
3. Sharing of information outside the CIO and the Trust
The names, ages of each applicant, their schools, the amount of grant and details of invoices paid are shared with the Independent Examiner for accounting purposes as required by law. Some of the information namely the name, addresses and schooling may be shared verbally or in emails with other grant making charities also assisting the child considered by us for funding. The names of applicants and child at school with their addresses, email addresses and amounts of a grant will also be shared with the schools attended by the child.
4. Security of information provided by applicants
The completed application form and papers are scanned
and filed electronically in the Chairman’s secure and password protected
computer files. The original application form and papers are kept in folders in
a locked cabinet in the Chairman’s study. Original adoption orders and
certificates and other original papers are returned by Signed for Post to the
applicants. Any information provided separately is also dealt with in the same
way. Any personal information which has to be emailed between the Charity Trustees
is sent in password protected attachments. All schedules of grants in payment
are kept in locked cabinets or electronically in password protected computer
files.
5. How long do we retain this personal information?
We retain the completed application form and
accompanying papers for the duration of the grant awarded and for two years
after its expiry. The form and papers will then be destroyed and all electronic
copies deleted.
We should nevertheless like to keep in touch with all
applicants and intend to keep a data base of names, addresses and email
addresses of all applicants and name of the child supported by us.
6. What is the legal basis for the retention by us of
this personal information?
We have a legitimate interest in such information
contained in the application form in order that we can carry out our duties as Charity
Trustees to consider whether to award a grant and if so for how much in a
proper and fair way. Nevertheless we need each applicant’s written consent to
using and retaining this information in the manner specified. This Privacy
Notice is therefore printed at the end of the application form and each
applicant is advised at the beginning to read the Notice before completing the
form and that by signing the form will be giving their written consent
accordingly.
Each form will also request that each applicant give
their consent to us retaining their name, address and email address and the
name of the child supported by us in order that we can keep in touch after the
expiry of any grant.
7. Children
Furthermore we recognise that each child ‘s personal
information includes sensitive personal information and deserves special
protection. This Notice is designed to be understood by children and we check
the age of the child when considering the application for grants. Once they
have attained the age of 18 a child will be asked to sign a form of consent to
the information contained in the application form being used and retained by us
in the above manner.
8. What rights do data subjects have?
Each applicant and a child of 18 who is the subject of a grant shall have the following rights
* to check the data we are holding is correct and
request us to correct it or complete it
* to request us to erase any part so long as this is
not information we need to retain
* to request us to restrict our use of the information
so long as this does not prevent us from administering the grants
* to withdraw your consent at any time after the
expiry of the grant. If the consent is withdrawn during the existence of the
grant the grant will have to be revoked and payments will cease.
* the right to complain to the Chairman of the CIO representing the Data Controller and to the
Information Commissioner at the addresses given at the end of this Notice
B the Donor’s Personal Information
1. What does the information comprise ?
a) names and amounts donated on-line via justgiving
b) names and addresses and amounts donated off-line
given in the Gift Aid Declaration Forms completed by Donors
c) names and addresses and amounts given by donors
off-line but without completion of a Gift Aid Declaration comprised in
schedules of off-line donations made each year.
d) Amounts payable under old covenants derived from
the former National Childrens Adoption Association
2. How do we use and process this information?
a) the information from justgiving we retain for
financial records only
b) We retain the Gift Aid Declaration forms in order
to obtain Gift Aid from HM Revenue and Customs .
b) & c) the schedules of off-line donations we
retain so that we can write to the donors individually when we carry out a fund
raising campaign or as part of a mail shot to an area which includes the names
of previous donors. They are also retained for financial and annual accounting
purposes
d). The amounts are recorded in the CIO and the Trust’s
annual accounts but we have no details of the covenantors and would have to
ascertain this through our bank.
3. Security of information provided by donors
a) as we have a password protected account with
justgiving all the donations made via justgiving are kept in this account but
downloaded by us electronically from time to time to the Chairman’s and
Treasurer’s computers for financial purposes.
b) We keep the original completed Gift Aid
Declarations in a lever arch file in the locked cabinet in the Chairman’s study
and copies are provided to the Treasurer for the purpose of obtaining gift aid
from HM Revenue and Customs.
c) the Schedules of off-line donations are kept both
in paper form in the lever arch file of Gift Aid Declarations and
electronically in the Chairman’s password protected computer.
d) the amounts appear in the CIO and Trust’s bank
statements which are kept by the Chairman and the Treasurer in locked cabinets.
4. Sharing
None of the above information is shared with anyone
other than the Charity Trustees , the Independent Examiner and HM Revenue and
Customs.
5. How long do we keep this information?
We shall retain the Schedules of off-line donations
for as long as we have the consent of the donors.
So far as the Gift Aid Declarations are concerned we
shall retain them for so long as is necessary to reclaim the gift aid but
otherwise for as long as we have the consent of the donors.
6. What is the legal basis for retention of this
information?
As a charity with limited funds and commitments to
meet, we have to raise funds each year and we consider we have a legitimate
interest in the information provided by our donors but at the same time we
accept that apart from retaining gift aid forms for reclaiming gift aid we need
the donor’s consent to hold information relating to them.
7. What rights do donors as Data Subjects have?
Each donor has the following rights
* to check the data we are holding is correct and to
request us to correct it or complete it
* to request us to erase any part so long as this is
not information we need to retain
* to withdraw your consent at any time
* the right to complain to the Chairman of the CIO representing the Data Controller and to the
Information Commissioner at the addresses given at the end of this Notice
C Personal information relating to fund raisers
1. What information do we hold?
We hold the names, addresses, email addresses and
telephone numbers , ages and occupations of those persons who have been engaged
by us to take part in sponsored runs such as the British !0 K London Run or
other sporting activities to raise money for the Charity.
2. How do we use this information ?
We use the information in order to contact the runners
to see if they will run again and to communicate with them in the process of registering
for the Run and preparing for and
participating in the Run. The names and occupations
also appear in appeal letters and letters of thanks.
3. Security of such information?
The information is retained by the Chairman in a
folder in the locked cabinet in the Chairman’s study and electronically in
emails and Run registration forms stored in the CIO and Trust’s files in the
Chairman’s password protected computer.
4. Sharing
The names and occupations of each sponsored runner
appear with their consent in the appeal letters sent out to prospective
sponsors and their names also appear in letters of thanks sent to donors after
the sponsored Run. Apart from these cases, the information is not shared with
anyone other than the Trustees.
5. What is the legal basis for us holding this
information?
As we have to take steps to raise funds we have a
legitimate interest in the runners who are prepared to take part in sponsored
runs for this purposes. Nevertheless we realise that we need their consent to
retain the information.
6. What rights do the runners as Data Subjects have ?
The runners and others engaged in sponsored activities
have the following rights
* to check the data we are holding is correct and to
request us to correct it or complete it
* to request us to erase any part so long as this is
not information we need to retain
* to withdraw your consent at any time
* the right to complain to the Chairman of the CIO
representing the Data Controller and to the Information Commissioner at the
addresses given at the end of this Notice
HOW DO WE MANAGE OUR DATA PROTECTION COMPLIANCE UNDER
THE GDPR?
1. We ensure that written consents by all current data
subjects are obtained
2. A list of all consents will be kept by the Chairman
securely in paper form and electronically
3. No personal information is shared outside the CIO
and the Trust except in accordance with this notice.
4. We ensure that our security systems are where
possible kept up to date.
5. We take note of advice given by the Charity
Commission concerning data protection and fund raising
6. This Notice and the three individual sub-notices
will be reviewed periodically
FURTHER PROCESSING
If we wish to use your personal data for a new
purpose, not covered by this Notice, then we will provide you with a new notice
explaining this new use prior to commencing the processing and setting out the
relevant purposes and processing conditions. Where and whenever necessary, we
will seek your prior consent to the new processing.
CONTACT DETAILS
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Chairman
Email: athlonetrust@outlook.com
You can also contact the Information Commissioners Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113.
Email: https://ico.org.uk/global/contact-us/email/
Present Charity Trustees
David King-Farlow (Chairman)
John Auber (Treasurer)
Anita Loring
Matthew Smallwood
Notice dated 23.09.2020
© Copyright The Athlone Trust CIO | 2020
