PRIVACY AND DATA PROTECTION

 

INTRODUCTION

The Attingham Trust is committed to ensuring the security and protection of the personal information that we process, how we communicate with you, and to providing a compliant and consistent approach to data protection. We have a robust and effective data protection programme in place which complies with existing law and abides by the data protection principles. In addition, we recognise our obligations to meet the demands of the EU GDPR and the UK Data Protection Bill.
The Attingham Trust is committed to protecting the privacy of your personal data. We will respect any personal data you share with us, keep it safe and not do anything with it that you would not reasonably expect.

YOUR PRIVACY

Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will collect, use and store your personal data. It also details how we keep your information secure. We may update this policy from time to time, without notice to you, and our most up to date version will be available on our website.

DATA PROTECTION PRINCIPLES

The Attingham Trust will comply with data protection law, which says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  3. Relevant to the purposes we have told you about and limited only to those purposes
  4. Accurate and kept up to date
  5. Kept only as long as necessary for the purposes we have told you about
  6. Kept securely

WHAT PERSONAL INFORMATION DO WE HOLD?

The Attingham Trust will collect information when you decide to interact with us. In collecting personal information from you, our aim is to contribute to the smooth running and development of The Attingham Trust, its courses and its alumni activities, and to let you know about things that might be of interest to you.

Some examples of the type of information we may collect and hold about you are as follows:

  • your full name and your title;
  • birth date or alternatively a relevant age range;
  • postal address (private and/or professional);
  • telephone number(s);
  • email address (private and/or professional);
  • professional status and activities
  • records of your correspondence with us;
  • bank or credit card details (if you purchase something from us or donate to us);
  • information you enter into our websites and digital products and details of how you use those websites and digital products;
  • Photographs and digital images of individuals
  • Data about you that will enable us to be more precise in what we send you or how we approach you

In general, we do not collect sensitive personal data. We will only process sensitive personal data also known as special categories of data (e.g. in relation to your health), with your explicit consent, for reasons of substantial public interests or where necessary for the establishment, exercise or defence of legal claims. The Attingham Trust will only use information about your physical or mental health, or disability status:

  • To ensure your health and safety on one of our courses;
  • To provide appropriate reasonable adjustments;
  • To monitor and manage sickness absence

HOW DO WE USE YOUR PERSONAL DATA?

The Attingham Trust collects information from you to guarantee we continue to provide a service that maintains the high level of efficiency and personal communication that our course participants and supporters expect. We will only use your personal information when the law allows us to. We might use your information in the following ways

  • To carry out administrative functions (eg completing application forms, booking courses and events, taking payments)
  • To provide you with the information, product or service you have requested from us
  • To provide you with other information which we feel may interest you. This may include newsletters, information in relation to events we think you may be interested in attending, fundraising etc
  • To keep in contact with you in the ways that you have requested or agreed to
  • To keep a record of our relationship with you
  • To notify you about changes to our services
  • To fulfil a legitimate interest pursued by us and your interests and fundamental rights do not override those interests
  • To improve our services
  • To handle complaints
  • To conduct investigations and due diligence.
  • To comply with applicable laws and regulations and requests from statutory agencies including for such purposes as health and safety; the detection and prevention of crime and safeguarding
  • To approach potential supporters
  • To further our charitable mission
  • To administer our course admissions, selection and interviews
  • To seek your views or comments on the services we provide

WHAT LAWFUL BASES DO WE RELY ON TO USE YOUR PERSONAL DATA?

The legal bases that we rely on for processing your personal data are either:

You have provided your consent to us using your personal data for a specific purpose
We will ask for your consent to use your personal data to send you specific types of communication and you always have the right to withdraw your consent at any time.

It is necessary in connection with the performance of a contract with you
Sometimes it is necessary to process your personal data so that we can enter into contractual relationships with you.

It is necessary for compliance with a legal obligation to which we are subject
This would include where we have to retain certain records, for example, to ensure we comply with health and safety requirements or for tax reasons.

It is within our legitimate interests
Applicable law allows personal data to be collected and used if it is reasonably necessary for our legitimate interests and we will rely on this ground to process your personal data when it is not practical or appropriate to ask for your consent, and where we are confident that this will not impact your rights.

HOW DO WE COLLECT PERSONAL DATA?

We collect information about you when:

It is given to us directly by you
You may give us your personal data for a number of reasons. This includes in order to receive information from us about our activities, for the administering of a course or event application, for donation purposes, to participate in training and accreditation, or when you engage with us on our website.

When a third party provides us with your personal data
This may include information provided by referees and employers on your behalf.

When it is available publicly
We may combine personal data you provide to us with personal data available from external publicly available sources such as company websites, published articles and social media sites. We use this personal data to improve our communications.

When you use our website
We may collect personal data about you when you use our website. Whenever you input personal data into our website (for example, if you book an event), we will collect the personal data that you give to us.
We may collect other personal data from your use of the website, such as your IP address and access times.
We may link our websites directly to other sites. This privacy policy does not cover external websites and we are not responsible for the privacy practices or content of those sites.

COMMUNICATIONS AND MARKETING

We may contact you by post, telephone or email where you have provided consent, or where we have a legitimate interest. We provide the opportunity for you to opt-out from receiving our marketing communications at any point by contacting

DATA SHARING

We do not sell or rent your information under any circumstances, nor share your personal data with third parties for marketing purposes.

Whilst we may allow our staff, consultants and/or external service providers acting on our behalf to access and use your personal data for the activities we have described in this policy (e.g. to provide services or products to you or to deliver mailings), we only permit them to use it to deliver the relevant information, goods or services, and only as required to provide our services to you.

We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies. Unfortunately, the transmission of personal data via the internet is not completely secure and any transmission through our website or via email is at your own risk.

DATA SAFETY AND ACCESS

We are committed to ensuring that there are appropriate technical controls in place to protect your personal data including protection from misuse and unauthorised access. Your information is only accessible by staff and contractors who are bound by appropriate policies and procedures to protect your information.

YOUR DATA PROTECTION RIGHTS

Rights to access information

You have the right to access the information that we hold about you. If you would like to request a copy, please email .

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, The Attingham Trust may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

The Attingham Trust aims to comply with the requests for access to personal information as quickly as possible, and will ensure it is provided without undue delay and in any event within one month of receipt of the request, other than in exceptional circumstances, unless exceptions apply. For example, if the request is considered complex or if there has been a significant number of requests, The Attingham Trust may extend the timeframe to respond by a further two months. In such cases, the reason for any delay will be explained in writing to the person making the request.

Request correction

You have the right to request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure

This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.

Object to processing

You have a right to object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing

You have a right to request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer

You have the right to request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us via the details below in writing.

DATA RETENTION

We regularly review the personal data that we hold, and proactively remove data when we think that there is no longer a legitimate interest in the Attingham Trust’s affairs. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

  • The amount, nature and sensitivity of the personal data
  • The potential risk of harm from unauthorised use or disclosure of your personal data
  • The purposes for which we process your personal data and whether we can achieve those purposes through other means
  • The applicable legal requirements

COMPLAINTS

If you are unhappy with the way in which we have handled your personal data please contact us at

You are also entitled to make a complaint to the Information Commissioner’s Office. For further information see: https://ico.org.uk/for-the-public/personal-information.

DISCLAIMER

Although every effort has been made to ensure the information in this policy is accurate at the time of publication, The Attingham Trust does not accept any liability for error or omission.

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