Privacy Policies
Contents
- Purpose of the Policy – view
- Data protection principles – view
- What information do we collect? – view
- How do we collect information? – view
- How do we use this information? – view
- Do we share your information with anyone else? – view
- How long do we keep your information? – view
- How do we protect your personal information? – view
- Your Rights – view
- Cookies – view
- Changes to this policy – view
APPENDICES
1. Purpose of the Policy
This policy sets out the data protection policies and procedures of the St Giles & St George Education Charity and the Alms Charity, together the “Charities”. It explains why each of the Education and Alms Charities collect data from you or that you provide to them, and how the respective Charity will use it. Please read it carefully to understand how each Charity will treat your personal data and your rights.
The Trustees of each Charity take your privacy seriously and are committed to protecting your personal information.
Each Charity is a data controller which means it is responsible for how it collects and uses personal information about you during and after your working relationship with it, in accordance with the General Data Protection Regulation (GDPR) 2018.
The relevant parts of this policy apply to all personal information that each Charity collects and processes relating to identifiable, living individuals. For both Charities, it applies to all current and former employees, workers and contractors, volunteers, trustees, grant beneficiaries and partner organisations and, for the Alms Charity, it also applies to almshouse residents. It is also relevant to anyone who has applied for (but not been selected) any of these roles or services.
The Clerk to the Trustees is the nominated person for data protection for both charities.
Both the Alms Charity and Education Charity are registered as a data controller under the GDPR with the Information Commissioner’s Office.
2. Data protection principles
Both charities will comply with the data protection law in force at the time. This requires that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- limited to what is necessary for that purpose;
- accurate and up to date;
- kept only as long as necessary for the purposes we told you about;
- kept securely.
3. What information do we collect?
Both charities may collect, store and use a variety of categories of personal information about you. This may include your name, contact details, date of birth, financial information, bank details.
We may also collect, store and use ‘special categories’ of more sensitive personal information.
A full explanation of the information collected for each different activity of the charities is detailed in each Information Audit in the Appendices to this policy.
4. How do we collect information?
Both charities mostly obtain personal information that individuals provide about themselves, when you:
- use our website
- sign up to mailing lists
- submit an application form (electronically or in hard copy)
- make an enquiry via email or telephone
- or otherwise provide us with personal information.
There are situations where both charities may collect additional information, for instance:
- Researching information in the public domain, ie newspaper or online media items, publicly available posts on Linked In or social media or Charity Commission and Companies House listings.
- Requesting information from third party organisations (such as employment agencies, background check provider, and referees) during selection processes for employees, Directors and Almshouse residents. We will inform you (and sometimes get your consent) for any checks that we are carrying out.
- Finding out additional information in the course of job-related activities throughout the period of you working/volunteering/being accommodation/accessing services with us.
- Technical information relating to your use of our website, including your browser type or the Internet Protocol (IP) address used to connect your computer to the internet.
Each Charity also gathers general information about the use of our joint website, such as which pages users visit most often, and which services/activities are of most interest. We may also track which pages users visit when they click on links in emails. We may use this information to personalise the way our website is presented when users visit it, to make improvements to our website and to ensure we provide the best service for users. Wherever possible, we use aggregated or anonymous information which does not identify individual visitors to our website.
5. How do we use this information?
Each Charity may use your personal information:
- To process your application for a grant
- To process your application as an employee/trustee/worker/volunteer
- To provide you with services or information you have requested
- To keep in touch with grant recipients and inform them or any changes to our grants scheme or any events we are holding
- To keep in touch with partner and referral organisation, to send you information about our work, invitation to our events and regular newsletters
- To meet our legal requirements as an employer
- To meet our legal requirements as registered charities and companies limited by guarantee
- To personalise your future visits to our website and to improve the experience we provide to our online users.
Additionally, the Alms Charity may use your personal information:
- To process your application to become a St Giles Almshouse resident
- To provide support and assistance to St Giles Almshouse residents
- To maintain the St Giles Almshouses properties.
For more detailed information, please refer to the specific Information Audits for each service/activity contained in the Appendices.
6. Do we share your information with anyone else?
Neither Charity will sell your information to any third party. Your information may be disclosed to third parties who provide the charities with services to store data, and act as processors on behalf of the charities, eg:
- Online grant applications forms (Formstack)
- Grants management system (Salesforce)
- Mailing list (Mailchimp)
- Cloud data storage (Office 365)
For the Alms Charity, your information may be disclosed to third parties who provide services on our behalf, to the extent necessary to enable you to receive those service, eg:
- Almshouse telecare service
- Almshouse maintenance contractors
- Suppliers of appliances and furniture to grant recipients
We have contracts in place with all third-party suppliers to ensure that they are obligated to treat our customers’ personal data in compliance with General Data Protection Regulation 2018.
In certain circumstances, the charities may be required to disclose personal data to third parties when required by law, when necessary to protect the charities’ legal rights, or in an emergency situation where the health or security of an individual is endangered.
For more detailed information, please refer to the specific Information Audits for each service/activity contained in the Appendices.
7. How long do we keep your information?
Neither Charity will keep your information for longer than necessary. We will retain your information for any period required by law, for example, financial records are stored for seven years in compliance with HMRC requirements. Where we are not under a legal obligation to retain your information, we will determine what is necessary for our legitimate interests. Both charities maintain an archive for historical purposes.
When either Charity disposes of personal data, this will be done in a secure manner. Paper based documents will be shredded on site. Electronic data will be permanently deleted from all drives and electronic media.
For more detailed information, please refer to the specific Information Audits for each service/activity contained in the Appendices.
8. How do we protect your personal information?
Both charities take necessary technical and organisational security measures to prevent the unauthorised or unlawful processing or disclosure of personal data, and the accidental loss, destruction of, or damage to personal data.
You should be aware that the use of the Internet is not entirely secure and although we do our best to protect your personal data, we cannot guarantee the security or integrity of any personal information which is transferred from you or to you over the Internet. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features such as encryption to try to prevent unauthorised access.
9. Your Rights
Data protection regulations give you clear rights over how your data is used by us. You can find out more details about your rights by visiting the Information Commissioner’s Officer website section on individual rights. In summary, you have the right to:
- Request a copy of the information that we hold about you (access)
- Ask us to correct information that you think is inaccurate (rectification)
- Ask for your data to be deleted (erasure), although this is not absolute.
- Ask us to restrict our usage of your data (restriction), although this is complicated.
If you would like to exercise any of your rights above, please contact the Clerk to the Trustees by:
Email: clerk@stgilesandstgeorge.org.uk
Post: 60 St Giles High Street, London, WC2H 8LG
We will act in accordance with your instructions as soon as reasonably possible and you will not be charged.
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline on 0303 123 1113.
10. Cookies
The use of cookies is common practice on modern websites. A cookie is a small text file which is placed on your computer’s hard drive by a website. When you visit our website, your browser checks to see if it has any cookies for it and sends the information contained in these cookies back to the site in order to tailor and improve your experience.
We also use third-party cookies to track how our websites are used. For example, we use Google Analytics cookies to collect anonymous usage and visitor behaviour information – this includes IP addresses, operating system, browser type, pages visited, and links you click on.
11. Changes to this policy
Both charities keep the Privacy Policy under regular review and will place any updates on this web page.
This privacy policy was reviewed on 23 March 2021.