6th October 2020
The Fursa Trust (the “Trust”), a registered charity with the charity number 1186991 (“we”, “us” and “our”), is committed to safeguarding information provided to us by any person who it deals with (“you”) from which any individual can be identified, such as names, contact details and ID data (“Personal Information”). This includes the Personal Information of: donors (“Donors”); the young people with whom the Trust engages with in respect of the its programme (“Students”) and their respective parents/carers/guardians (“Carers”) and all visitors to the website https://www.thefursatrust.org/ (our “Website”).
We will only use Personal Information which is provided to us, or otherwise obtained by us, as set out in this Policy. We will ensure that your Personal Information is handled in accordance with the “Data Protection Legislation” (meaning any law relating to the processing of Personal Information and/or privacy as the same may be re-enacted, applied, amended, superseded, repealed or consolidated from time to time, including without limitation, the UK Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, directions and orders issued from time to time under or in connection with any such law).
For the purpose of the Data Protection Legislation the data controller is the Trust.
To the extent that any Personal Information is collected, it will be held in confidence in accordance with the Data Protection Legislation (as defined above). Please read the following carefully to understand our practices regarding your Personal Information and how we will treat it. By visiting our Website you are accepting and consenting to us collecting, using and transferring your Personal Information as described in this policy. The Trust reserves the right to change this Policy from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.
2. Information we may collect from you
We may collect and process Personal Information about you from any of the following means:
- You may give us Personal Information about yourself by: registering as a Donor or a Student (or a Carer of a Student); or as a point of contact for a Student; filling in forms on our Website and/or by communicating with us by phone, email or otherwise.
- The Personal Information you give us may include your name; date of birth; address; e-mail address ,address or phone number.
- Please note that where you provide Personal Information on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Information to us and directing them to this Policy so they can see how we will process their Personal Information.
Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address). Some of this Personal Information is collected and processed for the purpose of legal compliance and some for the purposes of our legitimate interests (namely to carry out analysis on the use of our Website).
In addition, in common with many other online services, we and our authorised third parties may use “cookies” and/or other tools to store and sometimes track information about you.
This is to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site.
You can restrict, remove or block cookies or tracking services through your browser settings at any time (see below). Certain cookies may be set as soon as you use a website, but you can remove them by enabling the Do Not Track (or DNT) preference in your browsing settings. This will let websites know that you do not want them collecting certain information about you. For more information about how to do this, you can visit: allaboutcookies.org and youronlinechoices.eu.
3. Information we receive from other sources
We may receive Personal Information from other sources including third parties we work with (such as schools and partners) who have confirmed to us they are authorised to pass your information on to us and we may share this data internally.
Students or Carers may also give us emergency contact information.
Where this is the case the third party is responsible for informing you that they have shared your Personal Information with us, directing you to this Policy and obtaining any relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used.
However, once we are holding it, we will only handle any person’s Personal Information in accordance with this Policy.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out in paragraph 5 below (depending on the types of information we receive).
4. Sensitive Personal Information
“Sensitive Personal Information” is Personal Information concerning an individual’s (i) racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or other beliefs of a similar nature, (iv) membership of a trade union, (v) physical or mental health or condition, (vi) sexual life or orientation, (vii) commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by him/her, the disposal of such proceedings or the sentence of any court in such proceedings.
Given the nature of the Trust’s programme, you may disclose Sensitive Personal Information to us whilst you are engaged with us. We will not record and/or disclose any Sensitive Personal Information about you unless we have your explicit consent or it is necessary to follow the instructions from the police or local authorities and/or the law. Where we do receive and retain Sensitive Personal Information, we will only keep such information for as long as strictly necessary in order to comply with our obligations under the Data Protection Legislation and the law.
The legal basis on which we process Sensitive Personal Information when providing our services are (i) with the explicit consent of the relevant person; (ii) to protect the vital interests of the data subject where they are not capable of giving consent; (iii) for reasons of public interest to safeguard children or individuals at risk or the prevention or detection of an unlawful act; or (iv) to carry out the obligations and exercising the specific rights of the data controller or the data subject in the field of social protection law.
5. What we do with your Personal Information
We use Personal Information (other than Sensitive Personal Information) held about you to the extent this is necessary for our legitimate interests. In particular, we would expect to use your Personal Information in the following ways:
(i) Personal Information you give to us.
- to help us to provide you with the information required for your participation in the Trust’s programme;
- to keep a record of donations made and actions taken by our supporters and our communications with them;
- to claim gift aid on donations;
- to help us improve the Website, the experience you have and the quality of our services;
- to comply with legal obligations;
- to manage our organisation;
- to send, with your permission, newsletters, updates and useful information about volunteering and how to get involved; and
- to ensure that content from our Website is presented in the most effective manner for you and for your device.
(ii) Personal Information we collect about you by other means.
- to administer our Website and for internal operations, including troubleshooting, data analysis, testing, improvements, research, statistical and survey purposes;
- to improve our Website to ensure that content is presented in the most effective manner for you and for your device; and
- to keep our Website safe and secure.
6. Disclosure of your information
We may share your Personal Information with selected third parties including: schools and partners, and other third parties where it is necessary to enable us to provide the Trust’s programme.
We may also disclose your Personal Information to or share it with third parties:
- to protect the rights, property, or safety of the Trust, our Students or others; and/or
- as necessary to follow instructions from the police or local authorities and/or the law. This also applies to the disclosure of Sensitive Personal Information.
The Trust will never sell your Personal Information.
7. Where we store your Personal Information
This means that we will only transfer your Personal Information outside the EEA if: (a) the recipient is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information, (b) the recipient has agreed (by way of written contract incorporating the “model clauses” as approved by the European Commission or by some other form of data transfer mechanism approved by the European Commission) to provide all protections to your Personal Information as required by the Data Protection Legislation or (c) we have your explicit consent to do so. Where any transfer takes place under a written contract, you have the right to request a copy of that contract and may do so by using the contact details in Section 11. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.
By submitting your Personal Information to us, you acknowledge and agree to this transfer, storing and processing of your Personal Information.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. Your rights
You have the right to ask us not to process your Personal Information for marketing purposes. We will request your consent to use your Personal Information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by indicating via the method provided on the forms we use to collect your Personal Information. You can also exercise the right at any time by sending us a Privacy question on our Contact page.
Our site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to these websites.
9. Access to and updating your information
You are entitled to know some details about the Personal Information we hold about you and how that information is processed. If you would like to request this, please contact us using the contact details below and we will provide you with the information to which you are entitled.
You can also ask us to: (a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some circumstances, transfer any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact the Data Protection Coordinator, Sarah Gabay by email at email@example.com.
Should you have any queries or complaints in relation to how we use your Personal Information, please contact the Data Protection Coordinator, Sarah Gabay, by email at firstname.lastname@example.org. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Information via these websites.