General Privacy Notice
The Titus Trust
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/Act 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 the Titus Trust of 12 Lime Tree Mews, 2 Lime Walk, Oxford, OX3 7DZ (herein after referred to as the Trust). The Operations Director is the Data Controller for your data, contact details: firstname.lastname@example.org and 01865 760944.
The Trust conducts its activities through both its central team and the three Camp Groups listed below:
• Lymington Rushmore Holidays
• Gloddaeth Holidays
• LDN Holidays
The Trust is a single legal entity, both a charity (number 1066751) and a limited company (number 3473879). The holiday camps listed above are part of this legal entity, and are subject to the single Data Controller listed above.
What data does the Data Controller listed above process? He or she will process some or all of the following where necessary to perform his or her tasks:
• Names, titles, and aliases, photographs;
• Contact details such as telephone numbers, addresses, and email addresses;
• Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependants;
• 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, our mission is to provide Christian activity holidays for children and young people. The fact that we process your data at all may be suggestive of your religious beliefs. Where you provide this information, we may also process other categories of sensitive personal data e.g. details of injuries, medication/treatment received and safeguarding data, which is required to provide our activity holidays.
How do we process your personal data?
The Data Controller will comply with his or her 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 facilitate running of activity holidays and schools visits;
• 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 administer membership records;
• To fundraise and promote the interests of the Trust and its Camp Groups;
• 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 changes to our services, events and role holders;
• To send you communications which you have requested and that may be of interest to you. These may include information about the camps, activities, appeals, other fundraising activities;
• To process a grant or application for a role;
• To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our charitable aims and articles;
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party. Our legitimate interests include provision of activity holidays, school visits, training events and communication connected to our activities. We will always take into account your interests, rights and freedoms.
Some of our processing is necessary for compliance with a legal obligation. For example, we are required to seek DBS check on all our staff and volunteers, and to publish certain amalgamated data in our annual accounts.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with signing up for one of our holiday camps.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing 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 (e.g. sections of your data may be shared with volunteer leaders, support teams, medical professional and activity providers to be able to run safe and effective holidays), where you first give us your prior consent, or where we have a legitimate interest to do so. It is likely that we will need to share your data (but only where necessary) with our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to provide a service or activity on camp;
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.
1. 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.
2. 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.
3. 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).
4. 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.
5. 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.
6. 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 Data Controller contact details at the beginning of this Notice).
7. The right to object to the processing of personal data where applicable.
8. 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 news items) 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.
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. Please contact the Data Controller in any of these cases.
You can contact the Information Commissioner’s Office on 0303 123 1113, via email here or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.