17 July 2018 09:48

Privacy Notice- 13 July 2018

  1. Who are we?

    In this privacy notice, 'we', 'us', and 'our' mean the Bedgebury Foundation Trustee Company. Our registered address is Priory Cottage, Romford Road, Pembury, Kent, TN2 4JD and our company number is 04259130 and our Charity Commission Registration is 306306.

  2. Scope of our privacy notice

This privacy notice applies to anyone who interacts with us about our products and services ('you', 'your'), in any way (for example by email, through our website, via Flexi-Grant, by phone).  This privacy notice applies to you if you ask us about, accept or use our products, work for us or sell services to us. It describes how we handle your information, regardless of the way you contact us (for example by email, through our website, or by phone)

3. How we collect personal information

We collect personal information from you and from third parties (anyone acting on your behalf), through your contact with us, including by phone, by email, through our website, by post, and by the

Flexi-grant software you may use to make a grant application.

Where you provide us with information about other people, you must make sure that they have seen a copy of this privacy notice and are comfortable with you giving us their information. If you are parent or guardian of a child under 13 you should consent on their behalf.

4. Categories of personal information

We collect and process different categories of personal information about you and (where this applies) your dependants

      - standard personal information (for example, information we use to contact you, to identify you or

        manage our relationship with you): and

      - specific information that depend on your relationship with us (grant applicant,

        supplier to successful grant award holders, non-grant related supplier, employee, volunteer and

        trustee)

Standard personal information includes:

      - contact information, such as your name, username, address, email address and phone numbers

      - information about your employment

      - financial information including bank details

      - the results of any credit or anti-fraud checks we have made on you

      - information about your interactions with us through email, SMS, post or in person

      - any opinions, preferences or personal circumstances which you express

          

Specific information includes:

      - For grant applicants:            

                  -  educational and medical information

                  -  personal financial information including salary levels and tax codes

                  -  information about your race, ethnic origin and religion

      - For Suppliers to successful grant award holders:

                  -  educational qualifications and experience

                  -  information about any criminal convictions and offences (we may get this information                     

when carrying out background screening searches)

      - For Employees

                  -  job description

                  -  appraisal information

                  -  previous employment history including any complaints, grievances and

                     disciplinary records

                  -  personal financial circumstances including salary levels, tax codes and student loans

                  -  information about your race, ethnic origin and religion

       - For Volunteers and Trustees

                  -  details of voluntary position

                  -  educational and employment history

                  -  potential conflicts of interest


5. What we use your personal information for

By law, we must have a lawful reason for processing your personal information. We process standard personal information about you if this is  

  -  necessary to provide the service set out in a contract. If we have a contract with you, we      

      will process your personal information in order to fulfil that contract (that is, to provide

     you and your dependants with our products and services)

   - in our or a third party's legitimate interest. We process your personal information for a         

      number of legitimate interests, including in order to manage a dispute, appeal or

      complaint if it arises in respect of our relationship with you or your organisation

  -  required or allowed by any law that applies

  -  when you have given consent

We process specific information about you because it is necessary to ensure our grant making programmes are not discriminatory, to evaluate applications against our award criteria and to meet any legal requirements.

We use personal information

  -  for an insurance purpose

  -  for a purpose designed to protect the public against dishonesty, malpractice, or other  seriously improper behaviour

  -  to process your grant application

  -  for payment of services offered to our grant beneficiaries

  -  for processing non-grant related supplier invoices

  -  to process employee applications and manage employment

  -  to manage the contribution of volunteers and trustees to the charity

  -   answering your enquiries

We may also use aggregate data for our own business purposes, provided that this aggregate data does not include any Personal Data about you.]

6. Sharing information

We may share your personal information with

  -  our licensors, employees and third parties who are contracted to provide services to us, this may include carrying out reference checks on you or key members of your organisation.This will include Fluent-Technology Ltd (or other grant managing system provider), who develop and host the Flexi-grant product used to make a grant application, Microsoft, HMRC, Nat West and The Charities Commission

  -  suppliers chosen to be used by you, for example, tutors, assessors, therapists. Disclosure in these circumstances will be limited to that necessary to pay your supplier and receive progress report once you have granted permission.

  -  companies and organisations if we are under a duty to disclose personal information in order to comply with any legal obligation, or in order to enforce our terms of use and other agreements or to protect the operation of our website, or the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

  -  future employers, with your permission, should they require an employee reference

ANY EMPLOYEES AND/OR DATA PROCESSORS CONTRACTED BY US WILL BE SUBJECT TO STRICT CONTRACTUAL REQUIREMENTS ONLY TO USE PERSONAL INFORMATION IN ACCORANCE WITH OUR INSTRUCTIONS.

IN THE EVENT WE SELL OR BUY ANY BUSINESS OR ASSETS, WE WILL NEVER SELL PERSONAL INFORMATION AS A SOLE ASSET.

WE MAY DISCLOSE AGGREGATE DATA TO THIRD PARTIES FOR ANALYSIS. ANY DATA SO DISCLOSED WILL NOT CONTAIN PERSONAL OR COMMERCIALLY SENSITIVE INFORMATION BY WHICH YOU OR YOUR ORGANISATION COULD BE IDENTIFIED,


7. Where do we Store Your Data

We are based in the UK and will hold Personal Data in that territory. Currently our servers are based in the UK.

We deal with Fluent Technology Ltd and Microsoft who may use international servers.  As a result, your personal information may be transferred to and held in countries outside the EEA (the EU member states plus Norway, Liechtenstein and Iceland for the purposes set out in this privacy notice) Fluent Technology Ltd and Microsoft take steps to make sure that, when your personal information is transferred to another country, appropriate protection is in place, in line with EU data-protection laws.

8. How long we keep your personal information

We keep your personal information in line with set periods and the following criteria

  • for grant applicants, we retain your information for the duration of the grant application

            process and for up to 12 months after the close of the financial year in which the application  

            was made.

  • for successful grant application(s) for a period of 6 years after the final transaction. This means that we can rely on the data if there is ever a dispute between you and us about a transaction. It also is necessary for us for tax and audit purposes.

     -  for suppliers to successful grant holders, we retain your information for the duration of the grant application process. We also retain financial information relating to successful  grant applications and payments for six years following the final transaction. We will  continue to hold information on your educational qualifications and contact details  beyond this period with your permission.

     -  for non-grant related suppliers, we retain your information for the duration of our contract(s). We also retain financial information relating to transactions and payments for six years following the final transaction

    -  employees, volunteers and trustees, we retain your information for the duration of your involvement with the charity and for a period of 6 years after the end of the financial year in which you were engaged.

  • For Trustees, Directors and Company Secretary contact details are archived and retained indefinitely
  • For employees and pupils of Bedgebury School some historical data is retained for child protection purposes.

9 WHAT SECURITY PROCEDURES DO WE HAVE IN PLACE?

It is our policy to ensure that all Personal Data held by us is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to an individual as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.

 We undertake regular security and risk reviews and we monitor all of the controls that we have in place to ensure the security, accuracy and integrity of the Personal Data we hold. We also endeavour to ensure that such data is only accessed by authorised personnel for a legitimate purpose (in accordance with our privacy policy).

You are able to set your own passwords and security to your data to protect access via your Flexigrant login and account.

We have a set of formal procedures that must be adhered to within our organisation to ensure that security standards are maintained, and that data privacy is respected.

The information retained for safeguarding purposes is archived and physically and digitally secure and only accessed if required to do so as part of a safeguarding investigation.

10. Your rights

    You have the following rights in respect of any Personal Information we hold about you:

 -  Right of access: you have the right to request a copy of the information which we hold about

    you.

 -  Right of rectification: you have the right to require us to correct any data which we hold about

    you which is inaccurate or incomplete.

 -  Right to be forgotten: in certain circumstances you can ask for the data we hold about you to

    be erased from our records.

 -  Right of portability: you have the right to have the data we hold about you transferred to  

    another organisation.

 -  Right to object: you have the right to object to certain types of processing, including direct

    marketing.

-  Right to object to automated processing, including profiling.

          We may need to ask you for further information and identification to help us to comply with this request.

11. Data protection contacts

If you have any questions, comments complaints or suggestions in relation to this notice, or any other concerns in which we process information about you, please contact our Director or our Trustee responsible for data at our registered address or by email to admin@bedgeburyfoundation.org.uk.


If you wish to make a complaint about how we have handled Personal information about you, you may lodge a complaint with the Information Commissioner’s Office by following this link: https://ico.org.uk/concerns/.





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