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). 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 Bill 2017 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.
Who are we?
This Privacy Notice is provided to you by iNet Trust Limited which is the data controller for your data. For the purposes of this Policy, ‘us’, ‘we’ and ‘our’ refer to iNet Trust Limited.
What information do we collect?
- Names, titles, and aliases, photographs;
- Contact details such as telephone numbers, addresses, and email addresses;
- Where you make donations or pay for activities, financial identifiers such as bank account numbers, payment card numbers, and payment/transaction identifiers;
- The data we process is likely to constitute sensitive personal data because, as a Christian organisation, the fact that we process your data at all may be suggestive of your religious beliefs.
What do we do with it?
We will as Data Controller comply with our legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- To enable us to meet all legal and statutory obligations;
- To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments;
- To deliver the Charity’s mission and to carry out any other voluntary or charitable activities for the benefit of the public as provided for in our constitution and statutory framework;
- To provide you with training on member care and preparation for short term overseas missions trips including pastoral and spiritual care;
- To administer our membership records;
- To fundraise and promote the interests of the charity;
- To maintain our own accounts and records;
- To process a donation that you have made (including Gift Aid information);
- To seek your views or comments;
- To notify you of our events, meetings and services;
- To send you communications which you have requested and that may be of interest to you. These may include information about our cross cultural workers, short term mission trips and fundraising activities;
- To process a grant or application for a role
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests. An example of this would be our safeguarding work to protect children and adults at risk. We will always take into account your interests, rights and freedoms.
If you are an existing supporter as at 31st January 2018 we may continue to contact you by email where you have previously given us your consent. We may also contact you by post or telephone where we have a legitimate interest to do so. For example, where you have previously made a donation to iNet we may continue to send you information about the work your donation is making possible or other work we may wish to do. Where you have previously asked us not to contact you in this way we will continue to respect your contact preferences. You can change your preferences at any time or object to us processing your data by contacting us by telephone, post or email.
If you are a new supporter coming on board for the first time, on or after 31st January 2018, we will process your personal data on the basis of the consent you provided us with. You are free to change your preferences at any time by contacting us by telephone, post or email.
Some of our processing is necessary for compliance with a legal obligation
We may process your data if we have a contract with you, or to take steps to enter into a contract.
Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
When we share your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- HMRC in relation to gift aid claims on the donations you make to us.
- Our agents, servants and contractors. For example, we use Mailchimp to circulate information to our supporters, or to maintain our database software;
- Churches with which we are carrying out joint events or activities.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee. T
- The right to correct and update the information we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data
- You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
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.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on our web site at www.inet-trust.org. This Notice was last updated in March 2018.]
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 Data Controller, iNet Trust Limited, 17 Sydenham Road, London, SE26 5EX
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5A