We’ll never sell your personal data and will only share it with organisations we work with when it’s necessary and the privacy and security of your data is assured.
Who are ‘we’?
In this policy, whenever you see the words ‘we’, ‘us’, ‘our’, ‘Town Trust, it refers to the Stratford-upon-Avon Town Trust (registered charity no. 1088521) and a company limited by guarantee, registered in England and Wales (no. 4222949). The Town Trust is also Trustee of the Guild Estate Charity (no. 217484) and College Estate Charity (no. 217485).
(Our ICO registration number is Z6139647).
The Town Trust’s purpose is to advance “a future where quality of life is improved for the people of Stratford-upon-Avon”. This statement is at the heart of the activities of the Town Trust.
The Town Trust distributes grant funding to other charities, groups and in some cases individuals to support projects and activities consistent with the Town Trust’s charitable objects.
The Town Trust is a membership based charity, in order to be eligible to become a member of the Town Trust individuals must be over the age of 18 that reside within Stratford-upon-Avon.
What personal data do we collect?
Your personal data (any information which identifies you, or which can be identified as relating to you personally for example, name, address, phone number, email address) will be collected and used by us. We’ll only collect the personal data that we need.
We collect personal data in connection with specific activities such as registration or membership requests, placing an order/making a booking, donations, volunteering, conducting research, employment,grant applications etc.
You can give us your personal data by filling in forms on our website, by registering to use our website, participate in discussion boards, subscribing to take part in research on our website or other social media functions on our website, entering a competition, promotion or survey or by corresponding with us (by phone, email or by joining as a member/supporter/customer).
This personal data you give us may include name, title, address, date of birth, age, gender, employment status, demographic information, email address, telephone numbers, personal description, photographs, CCTV images, attitudes, opinions, usernames and passwords).
Personal data provided by you
This includes information you give when interacting with us, for example joining or registering, placing an order or communicating with us. For example:
- Personal details (name, date of birth, email, address, telephone, and so on) when you join as a member or volunteer
- Financial information (payment information such as credit or debit card or direct debit details, and whether donations are gift-aided)
- Your opinions and attitudes about the Town Trust, activities and interests, and your experiences of the Town Trust
We may automatically collect the following information:
· Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and if you access our website via your mobile device we will collect your unique phone identifier
· Information about your visit, including, but not limited to the full Uniform Resource Locators (URL) and query string, clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as but not limited to scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number
· Information about your purchases including but not limited to revenue figures, the types of products purchased, membership application ID, purchase ID.
· The terms that you use to search our website
Please note that certain services on our websites may not be available to you until you’ve registered to use our website.
Personal data created by your involvement with us
Your activities and involvement with us will result in personal data being created. This could include details of how you’ve helped us by volunteering or being involved with our campaigns and activities. If you decide to donate to us then we may keep records of when and how much you give to a particular activity.
Information we generate
We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to interest you. The sections Research and Profiling gives more detail about how we use information for profiling and targeted advertising, including giving you more relevant digital content.
Sensitive personal data
At times we’ll collect sensitive personal data for Equal Opportunities monitoring, as well as researching whether we deliver great experiences for everyone, but this is only ever analysed at an aggregate level.
If you’re a volunteer then we may collect extra information about you (e.g. references, criminal records checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal or contractual reasons, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
Young and children’s personal data
Membership is only available to persons over the age of 18. There is no child, young person or family membership option.
If any events are undertaken where children may participate, personal information may be collected to ensure their right to admission at our places. No information will be retained beyond the event and no marketing to children will be undertaken.
Marketing to young people and fundraising
We won’t send marketing emails, letters or make calls to people under the age of 18.
Our newsletters may sometimes include competitions or ideas about how to raise money, but they are a member benefit. Most newsletter content is about our work, grants and ideas to help you make the most of the Trust.
How we use your personal data
We’ll only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (from 25 May 2018)/UK Data Protection Act and Privacy of Electronic Communication Regulation.
Personal data provided to us will be used for the purpose or purposes outlined in any fair processing notice in a transparent manner at the time of collection or registration where appropriate, in accordance with any preferences you express. If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.
Your personal data may be collected and used to help us deliver our charitable activities, help us raise funds, or complete your order or request. Below are the main uses of your data which depend on the nature of our relationship with you and how you interact with our various services, websites and activities.
Your privacy is important to us, so we’ll always keep your details secure. We’d like to use your details to keep in touch about things that may matter to you.
If you choose to hear from us we may send you information based on what is most relevant to you or things you’ve told us you like. We may also show you relevant content online. This might be volunteering, membership, events, or conservation work.
We’ll only send these to you if you agree to receive them and we will never share your information with companies outside the Town Trust for inclusion in their marketing. (We may however share cookie data with third parties to help with our own advertising targeting). If you agree to receive marketing information from us you can change your mind at a later date.
However, if you tell us you don’t want to receive marketing communications, then you may not hear about events or other work we do that may be of interest to you.
We may sometimes use third parties to capture some of our data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and in-line with the requirements set out in the GDPR.
How can I change my contact preferences?
We’ll always act upon your choice of how you want to receive communications (for example, by email, post or phone). However, there are some communications that we need to send. These are essential to fulfil our promises to you as a member, volunteer, donor or buyer of goods or services from the Trust. Examples are:
- · Membership-related mailings such as Town Trust newsletters and notice of our Annual General Meeting
Membership including newsletters
We use the personal data you provide as a member provide to service your membership. This includes sending newsletters, flyers, information releases and information about our Annual General Meeting. It’s also used to verify you when you contact our Administration Team.
Fundraising, donations and legacy pledges
Where we have your permission, we may invite you to support vital conservation work by making a donation, buying a raffle ticket, getting involved in fundraising activities or leaving a gift in your will.
Occasionally, we may invite some supporters to attend special events to find out more about the ways in which donations and gifts in wills can make a difference to specific projects and to our cause. We’ll also send you updates on the impact that you make by supporting us in this way, unless you tell us not to.
If you make a donation, we’ll use any personal information you give us to record the nature and amount of your gift, claim gift aid where you’ve told us you’re eligible and thank you for your gift. If you interact or have a conversation with us, we’ll note anything relevant and store this securely on our systems.
If you tell us you want to fundraise to support our cause, we’ll use the personal information you give us to record your plans and contact you to support your fundraising efforts.
If you’ve told us that you’re planning to, or thinking about, leaving us a gift in your will, we’ll use the information you give us to keep a record of this – including the purpose of your gift, if you let us know this.
If we have a conversation or interaction with you (or with someone who contacts us in relation to your will, for example your solicitor), we’ll note these interactions throughout your relationship with us, as this helps to ensure your gift is directed as you wanted.
Charity Commission rules require us to be assured of the provenance of funds and any conditions attached to them. We follow a due diligence process which involves researching the financial soundness, credibility, reputation and ethical principles of donors who’ve made, or are likely to make, a significant donation to the Town Trust.
As part of this process we’ll carry out research using publicly available information and professional resources. If this applies to you, we’ll remind you about the process when you make your donation.
Management of volunteers
We need to use your personal data to manage your volunteering, from the moment you enquire to the time you decide to stop volunteering with us. This could include: contacting you about a role you’ve applied for or we think you might be interested in, expense claims you’ve made, shifts you’ve booked and to recognise your contribution.
It could also include information from local teams about things happening where you volunteer and about your volunteering, including asking for your opinions on your volunteering experience.
We may also share this with funders to help them monitor how their funding is making a difference.
We may process customer data in order to fulfil bookings that may be made with us. Your data will be used to communicate with you throughout the process, including to confirm we’ve received your order and payment, for confirmation, to clarify where we might need more detail to fulfil an order or booking, or to resolve issues that might arise with your booking. Properties may also hold dietary requirements for events.
We may carry out research with our members, supporters, customers, staff and volunteers to get feedback on their experience with us. We use this feedback to improve the experiences that we offer and ensure we know what is relevant and interesting to you.
If you choose to take part in research, we’ll tell you when you start what data we will collect, why and how we’ll use it. All the research we conduct is optional and you can choose not to take part. For some of our research we may ask you to provide sensitive personal data. You don’t have to provide this data and we also provide a ‘prefer not to say’ option. We only use it at an aggregate level for reporting (e.g. equal opportunities monitoring).
Recruitment and employment
In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including ‘sensitive’ personal data, from job applicants and employees.
Such data can include, but isn’t limited to, information relating to health, ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it’s processed is given below.
Contractual responsibilities: Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.
Statutory responsibilities: Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.
Management responsibilities: Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, training and development, absence, disciplinary matters, e-mail address and telephone number.
Sensitive personal data
The Act defines ‘sensitive personal data’ as information about racial or ethnic origin, political opinions, religious beliefs or other similar beliefs, trade union membership, physical or mental health, sexual life, and criminal allegations, proceedings or convictions.
In certain limited circumstances, we may legally collect and process sensitive personal data without requiring the explicit consent of an employee.
(a) We will process data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and, where necessary, consent.
(b) We will process data about, but not limited to, an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding our equal opportunities policies and related provisions.
(c) Data about an employee’s criminal convictions will be held as necessary.
Disclosure of personal data to other bodies
In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with one or more third party supplier.
To meet the employment contract, we are required to transfer an employee’s personal data to third parties, for example, to pension providers and HM Revenue & Customs.
In order to fulfil our statutory responsibilities, we’re required to give some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.
Updating your data and marketing preferences
We want you to remain in control of your personal data. If, at any time, you want to update or amend your personal data or marketing preferences please contact us in one of the following ways:
01789 207 111 (local call rates apply).
Open 9.00am – 4.30pm weekdays
Stratford Town Trust,
14 Rother Street,
Verification, updating or amendment of personal data will take place within 30 days of receipt of your request.
Your data protection rights (DPO)
Where the Town Trust is using your personal data on the basis of consent, you have the right to withdraw that consent at any time.
Subject access rights
If you would like further information on your rights or wish to exercise them, please write to us at The Data Protection Officer, Town Trust, 14 Rother Street, Stratford-upon-Avon, CV37 6LU or email email@example.com
You will be asked to provide the following details:
- · The personal information you want to access;
- · Where it is likely to be held;
- · The date range of the information you wish to access
We will also need you to provide information that will help us confirm your identity. If we hold personal information about you, we will give you a copy of the information in an understandable format together with an explanation of why we hold and use it.
Once we have all the information necessary to respond to your request we’ll provide your information to you within one month. This timeframe may be extended by up to two months if your request is particularly complex.
What to do if you’re not happy
In the first instance, please talk to us directly so we can resolve any problem or query. You also have the right to contact the Information Commissions Office (ICO) if you have any questions about Data Protection. You can contact them using their help line 0303 123 113 or at www.ico.org.uk.
Cookies and links to third party websites
Links to other websites
Keeping your information
We will only use and store your information for as long as it is required for the purposes it was collected for. How long it will be stored for depends on the information in question, what it is being used for and, sometimes, statutory legal requirements.
How we secure your data
Information system and data security is imperative to us to ensure that we are keeping our customers, members, volunteers, employees and contractors safe.
We operate a robust and thorough process for assessing, managing and protecting new and existing systems which ensures that they are up to date and secure against the ever changing threat landscape. In addition to this, we follow a defense in depth security model, which means that your data is protected by multiple layers of security.
When you trust us with your data we will always keep your information secure to maintain your confidentiality. By utilising strong encryption when your information is stored or in transit we minimize the risk of unauthorized access or disclosure.
Disclosing and sharing information
When we allow third parties acting on behalf of the Town Trust to access to your information, we will always have complete control of what they see, how long they see it for and what they are allowed to do with it. We do not sell or share your personal information for other organisations to use.
Personal data collected and processed by us may be shared with the following groups where necessary:
- · Town Trust employees and volunteers
- · Third party cloud hosting and IT infrastructure providers who host the website and provide IT support in respect of the website;
Also, under strictly controlled conditions:
- · Contractors
- · Service Providers providing services to us
- · Advisors
- · Agents
Storage of information
The Town Trust operations are based in the UK and we store most of our data within the European Union (EU). Some organisations which provide services to us may transfer data outside the European Economic Area but we’ll only allow this if your data is adequately protected. Some of our systems are provided by US companies and whilst it is our policy that we prefer data hosting and processing to remain on EU-based solutions, it may be that using their products results in data transfer to the USA. However we only allow this when we certain it will be adequately protected. (e.g. US Privacy Shield or Standard EU contractual clauses).
Some of our locations and properties have Closed Circuit Television (CCTV) and you may be recorded when you visit them.
CCTV is used to provide security and protect both our members and visitors and the Town Trust. CCTV will be only be viewed when necessary (e.g. to detect or prevent crime) and footage is stored for set period of time after which it is recorded over. The Town Trust complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is used.
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