Privacy Notice

Who we Are

Calne Foundation Trust, (in this notice, “CFT”) whose address is at St Mary’s School, Curzon Street, Calne, Wiltshire SN11 0DF, is a Data Controller, as defined in the Data Protection legislation.  It is a charity registered with number 1147327.

What this Privacy Notice is For

This notice provides information about how CFT will use personal data about individuals.

This information is provided because Data Protection Law gives every individual the right to understand how their data is used. 

Responsibility for Data Protection 

The Bursar, St Mary’s School, Calne is the Data Compliance Manager and will deal with all requests and enquiries concerning the use of personal data and will endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.  The Bursar may be contacted at the School address, as above. 

Why CFT Needs to Process Personal Data 

In order to carry out its ordinary duties, CFT needs to process personal data about individuals as part of its legitimate daily operations. 

CFT will need to carry out some of this activity in order to fulfil its legal rights, duties or obligations – including those under contracts (such as those with sponsors and donors).  Other uses of personal data will be made in accordance with CFT’s legitimate interests, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data. 

CFT expects that the following uses will fall within that category of ‘legitimate interests’: 

  • For the purposes of informing individuals about CFT’s fundraising activities and requesting sponsorship and donations.
  • For the purpose of confirming the identity, and in some cases, the background, of individuals.
  • For the purposes of management, planning, forecasting, research and statistical analysis, including that imposed or provided for by law.
  • To enable relevant authorities to monitor CFT’s activities and to intervene or assist with incidents as appropriate. 

  • To make use of photographic images of individuals in CFT publications, promotional materials, on the CFT website and on social media channels in accordance with the policy of St Mary’s School’s on taking, storing and using images of children.
  • For security purposes.
  • To carry out or cooperate with any complaints, disciplinary or investigation process.
  • Where otherwise reasonably necessary for CFT’s purposes, including to obtain appropriate professional advice.

In addition, CFT will on occasion need to process special category personal data in accordance with the rights and duties imposed by law, such as money laundering checks; where appropriate, explicit consent will be requested.

Types of Personal Data Processed by CFT

The personal data we process takes different forms – it may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a living individual. Examples include;

  • Names, addresses, telephone numbers, email addresses and other contact details.
  • Bank details and other financial information, for example, about individuals who donate to CFT.
  • Correspondence.
  • Images of individuals engaging in school activities. Parents will have been requested by St Mary’s School, Calne to provide consent specifically for the processing of images at the time of enrolment – this consent can be withdrawn at any time (or withdrawn by an individual pupil, if 13 years of age or over).  Please advise the Bursar in writing if you wish to make a change to consent previously given.

How CFT Collects and Handles Data

Generally, CFT will receive personal data directly from individuals.  This may be via a form, or simply in the ordinary course of interaction or communication. Sometimes, personal data might be provided to CFT by third parties, such as other professionals working with that individual.

Personal data held by CFT is processed by appropriate members of staff for the purposes for which that data information was provided. We take appropriate technical and organisational steps to ensure the security of this information, including policies around use of technology and devices, and access to IT systems, as well as requiring at least equivalent steps to be taken by any third parties who process personal data on behalf of CFT.

Who has access to Personal Data and who is it shared with?

Occasionally, CFT might need to share personal information with third parties, such as:

  • Professional advisors.
  • Government authorities, such as the police or local authorities.
  • Regulatory authorities, such as the Charity Commission or the Information Commissioner.
  • The Calne Girls’ Association (CGA).
  • St Mary’s School, Calne.

Most of the personal data collected by CFT will remain within CFT, and will be processed by appropriate staff only in accordance with access protocols (that is, on a ‘need to know’ basis).

Personal data is not transferred outside of the European Economic Area unless CFT is satisfied that the data will be afforded an equivalent level of protection.

Finally, in accordance with Data Protection Law, some of CFT’s processing activity is carried out on its behalf by third parties, such as IT systems providers, web developers, mailing houses and cloud storage providers.  This is always subject to contractual assurances that personal data will be kept securely and only in accordance with CFT’s specific instructions.

How long we keep Personal Data

CFT will retain personal data securely and follows standard guidance as to the period for which it is necessary to keep the data for legitimate reasons.  Please contact the Development Office, St Mary’s School, Calne, with any specific queries about the data retention policy, or with any request for erasure of personal data that you no longer believe to be relevant.  Please remember that CFT will often have lawful and necessary reasons to hold some personal data even following such a request.

A limited and reasonable amount of information will be kept for archiving purposes, for example, even when you have requested that we no longer communicate with you, we will need to keep a record of that fact in order to fulfil your wishes (a ‘suppression record’).

Keeping in touch

CFT will use your contact details to keep you updated about its events and activities, and those of St Mary’s School and the CGA, including sending updates and newsletters by email and post.  Unless you object, CFT may also contact you by post or email in order to seek to raise funds for the School. Should you wish to limit or object to any such contact, or would like further information, please contact the Development Office in writing, at the School’s address.  You always have the right to withdraw consent, where given, or otherwise object to receiving marketing or fundraising communications.

In such case, CFT is likely to retain some of your details (not least to ensure that no further communications are sent to a particular address, email or telephone number). 

Your Rights

  • Whose rights? The rights under Data Protection Law belong to the individual. However, CFT will often rely on parents’ authority or notice in respect of the processing of personal data relating to pupils. Please refer to the Privacy Notice of St Mary’s School, Calne, for information about such circumstances. 

  • Rights of access, etc.  All individuals have various rights under Data Protection Law to access personal data about them which is held by CFT, and, in some cases, to ask for it to be erased or amended or have it transferred to others, or for the school to stop processing it – but this is subject to certain exemptions and limitations.

    Individuals wishing to access or amend personal data, or wish that it be transferred to another person or organisation, or have some other objection to how personal data is used, should put their request in writing to the Development Office.

    CFT will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).

    CFT will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or is similar to previous requests, CFT may ask you to reconsider the scope of the request, or require you to pay a proportionate administrative fee, where Data Protection Law allows. 

  • Requests that cannot be fulfilled.

    Individuals should be aware that the right of access is limited to their own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals, or information which is subject to legal privilege. 

Data Accuracy and Security

CFT will endeavour to ensure that all personal data held is as up to date and as accurate as possible. Individuals should notify the Development Office of any significant changes to important information held about them, such as contact details.

Individuals have the right to request that any out-of-date, irrelevant or inaccurate information held be erased or corrected (subject to certain exemptions and limitations under Data Protection Law).

CFT will take appropriate technical and organisational steps to ensure the security of personal data.

Queries and Complaints

Any queries about the application of this notice should be directed to the Development Office.

If you believe that CFT has not complied with any aspect of this notice or acted otherwise than in accordance with Data Protection Law, you should notify the Development Office. You can also make a referral or lodge a complaint with the data protection regulator, the Information Commissioner, although the regulator recommends that steps are taken to resolve the matter with the School as a first step.

 

 May 2018

 

 

Registered Charity 1147327 © 2013 The Calne Foundation Trust. All Rights Reserved.
Privacy & Cookie Policy  Privacy Notice  | St Mary's School, Calne, Wiltshire SN11 0DF, UK | Tel 01249 857200 | Email: office@calnefoundation.org