1.1 Preservation of your privacy is important to the Talisman Charitable Trust (the ‘Trust‘ ‘we‘, ‘our‘ or ‘us‘ being interpreted accordingly) and we are committed to letting you know how we use your personal information and to making only responsible and lawful use of your data.
1.2 Personal information relating to you from which you can be identified that we collect or which you provide is called personal data (‘Personal Data‘).
- What Personal Data do we collect and use?
3.1 The Personal Data about you that we collect and use includes the following:
(a) your name, title, address, phone and other contact details;
(b) your financial details and social circumstances;
(c) means of visual identification;
(d) membership details including trade union membership;
(e) details of your physical or mental health;
(f) your employment and education history;
(g) character opinions and accounts of your behaviour; and,
(h) information on your racial or ethnic origin, religious or other beliefs of a similar nature.
as well as any other Personal Data that you, or another individual or organisation with your consent, may provide to us from time to time.
- How your Personal Data is collected
4.1 We collect Personal Data about you in various ways as follows:
(a) through your relationship and communications you have with us with us from time to time;
(b) through applications received by organisations on your behalf and with your consent; and
(c) through contact with a family member nominated by you to assist with practicalities in the provision of support.
4.2 Please also note that some of the Personal Data you supply and that we process may include what is known as ‘sensitive’ or ‘special category’ data about you, for example, information regarding your ethnic origin or political, philosophical and religious beliefs.
- Information about third parties
5.1 Please ensure that any Personal Data you supply to us which relates to third party individuals is provided to us with their knowledge of our proposed use of their Personal Data and, to the extent that it forms part of an application for grant-funding or is otherwise necessary, with that individual’s written consent.
- What we use your Personal Data for
Other than as stated above, we may use your Personal Data for one or more of the following purposes:
(a) to provide charitable support by grant-making for the benefit of the public;
(b) to keep and administer our records;
(c) to manage the Trust’s own employees, volunteers and accounts;
(d) to fundraise and promote the interests of the Trust in any other way;
(e) to enforce and/or defend any of our legal claims or rights; and/or
(f) for any other purpose required by applicable law, regulation, the order of any court or regulatory authority.
- The lawful grounds on which we collect and process your Personal Data
7.1 We process your Personal Data for the above purposes relying on one or more of the following lawful grounds:
(a) where you have freely provided your specific, informed and unambiguous consent;
(b) where we agree to provide product(s) and/or services to you, in order to set up and perform our contractual obligations to you and enforce our rights;
(d) where we need to comply with a legal obligation or for the purpose of us being able to establish, exercise or defend legal claims.
7.2 If we process sensitive or special category data as referred to under paragraph 4.2 we will only do this with your explicit consent; or, where needed to comply with applicable social security or social protection laws; or, to protect your vital interests (or those of someone else) in an emergency; or, where you have already clearly publicised such information; or, where we need to use such sensitive data in connection with a legal claim that we have or may be subject to.
- Our Legal Obligations regarding your data
8.1 We collect and process your Personal Data in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) (‘GDPR’) and the UK Data Protection Act 2018 (‘DPA’) together with other applicable UK and EU laws that regulate the collection, processing and privacy of your Personal Data (together, ‘Data Protection Law‘).
- Disclosing your Personal Data to third parties
9.1 We may need to disclose your Personal Data to certain third party organisations who are processing data only in accordance with our instructions under contract (called ‘data processors’) in the following circumstances:
(a) companies and/or organisations that act as our service providers or professional advisers; and,
(b) companies and/or organisations that assist us in processing and/or otherwise fulfilling grant requests.
9.2 We may also disclose your Personal Data to third parties who make their own determination as to how they process your Personal Data and for what purpose(s) (called ‘data controllers’), such as:
(a) where you have made an application on an individual’s behalf, to that individual;
(b) local and central government, other voluntary and charitable organisations – where necessary to process an application received from them or to procure further support; and
(c) our regulators, including the Charity Commission.
The third party data controllers external to us with whom we deal as described above will handle your Personal Data in accordance with their own chosen procedures and you should check the relevant privacy policies of these companies or organisations to understand how they may use your Personal Data. Since they are acting outside of our control, we have no responsibility for the data processing practices of these data controllers.
9.3 Very occasionally we may disclose your Personal Data to a family member nominated by you to assist with practicalities in the provision of support.
9.4 Other than as described above, we will treat your Personal Data as private and will not disclose your Personal Data to third parties without you knowing about it. The exceptions are:
(a) in relation to legal proceedings or where we are legally required to do so and cannot tell you;
(b) where we use third party data processors who are engaged under contract to handle data on our behalf (for example an IT supplier or database hosting provider). In relation to these data processors, we will make sure that they act only in accordance with our instructions and that adequate safeguards are put in place by them to protect your Personal Data.
9.5 In all cases we always aim to ensure that your Personal Data is only used by third parties for lawful purposes and in compliance applicable Data Protection Law.
- International Transfers
10.1 We do not transfer any of your Personal Data outside the United Kingdom/ European Union.
- How long we retain your Personal Data for
11.1 The Trust only retains Personal Data identifying you for as long as you have a relationship with us; or as necessary to perform our obligations to you and the Trust’s grant recipients (or to enforce or defend contract claims); or as is required by applicable law.
11.2 We have a data retention policy (which we may make available on request) that sets out the different periods we retain data for in respect of relevant purposes in accordance with our duties under Data Protection Law. The criteria we use for determining these retention periods is based on various legislative requirements; the purpose for which we hold data; and guidance issued by relevant regulatory authorities including but not limited to the UK Information Commissioner’s Office (ICO).
11.3 Personal Data we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it.
- Security that we use to protect Personal Data
12.1 We will take reasonable precautions to prevent the loss, misuse or alteration of information you give us.
12.2 We employ appropriate technical and organisational security measures to protect your Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.
12.3 We also endeavour to take all reasonable steps to protect Personal Data from external threats such as malicious software or hacking. However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of all data sent to us (including Personal Data).
- Your personal data rights
13.1 In accordance with your legal rights under applicable law, you have a ‘subject access request’ right under which can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to as well as certain other information. Usually we will have a month to respond to such as subject access request. We reserve the right to verify your identity if you make such a subject access request and we may, in case of complex requests, require a further two months to respond. We may also justify a refusal or charge for administrative time in dealing with any manifestly unreasonable or excessive requests for access. We may also require further information to locate the specific information you seek before we can respond in full and apply certain legal exemptions when responding to your request.
13.2 Under Data Protection Law you also have the following rights, which are exercisable by making a request to us in writing:
(a) that we correct Personal Data that we hold about you which is inaccurate or incomplete;
(b) that we erase your Personal Data without undue delay if we no longer need to hold or process it;
(c) to object to any automated processing (if applicable) that we carry out in relation to your Personal Data, for example if we conduct any automated credit scoring;
(d) to object to our use of your Personal Data for direct marketing;
(e) to object and/or to restrict the use of your Personal Data for purpose other than those set out above unless we have a legitimate reason for continuing to use it; or
(f) that we transfer Personal Data to another party where the Personal Data has been collected with your consent or is being used to perform contact with you and is being carried out by automated means.
(g) To withdraw your consent to the processing of your personal data at any time.
13.3 All of these requests may be forwarded on to a third party provider who is involved in the processing of your Personal Data on our behalf.
13.4 If you would like to exercise any of the rights set out above, please contact us at the address below.
13.5 If you make a request and are not satisfied with our response, or believe that we are illegally processing your Personal Data, you have the right to complain to the Information Commissioner’s Office (ICO) – see https://ico.org.uk/.
P. R. Denman
Talisman Charitable Trust
Lower Ground Floor Office
354 Kennington Road
London SE11 4LD