1. CONTACT US
1.1 For the purpose of the Data Protection Act 2018 (the “Act”), in respect of any personal data that you submit or that is collected from you or about you, the data controller is The Queen’s Commonwealth Trust which is a company limited by guarantee registered in England and Wales (Company No. 10482169) and a charity registered under the laws of England and Wales with registered charity number 1172107 (referred to as “we”, “us”, “our”).
1.2 Our registered office address is at Thomas House, 84 Eccleston Square, London SW1V 1PX.
1.3 The charity is registered as a data controller with the Information Commissioner’s Office, under registration number: ZA261717.
Postal address: The Queen’s Commonwealth Trust Thomas House 84 Eccleston Square London SW1V 1PX
Email address: firstname.lastname@example.org
2. INFORMATION THAT WE COLLECT ABOUT YOU
The types of personal information that we collect about you may include:
- Your title, name, gender and date of birth;
- Your contact details (address, email, phone number and social media contact details);
- Family and spouse/partner details, relationships to other supporters;
- Your professional activities and employment details;
- Current interests and activities;
- Gift aid status and records of donations;
- Contact preferences;
- Information about your wealth;
- Media articles about you;
- Your IP address, location, browser type and information on how you interact on our website; and
- Any other information provided by yourself at our request.
3. SOURCES OF INFORMATION COLLECTED ABOUT YOU
3.1 We may collect information about you from third parties, from the public domain or information that you provide when you use the Site, when you make a donation if you consent to receiving contact from us, if you subscribe to any of our newsletters as they may exist from time to time or if you contact us for any reason.
Information you give us 3.2 When you make a donation through The Queen’s Commonwealth Trust website, you will be directed to Virgin Money Giving, where the information you will be asked to enter will include some or all of the following:
- Your name;
- Your address;
- Your credit card or other payment details;
- Your mobile or other phone numbers;
- Your email address.
For the avoidance of doubt, if you make a donation to us via the Site, your name and contact details will be passed to us only if you have agreed to be contacted by us. No financial data will be available to us.
3.3 We will also collect personal information about you that is contained in any correspondence that you send to us. For example, if you contact us, we may keep a record of that correspondence by reference to your name or address. We may also ask you for information when you report a problem with the Site or with anything contained on the Site.
3.5 We may collect generic information about your visits to and how you use the Site. We may therefore collect information such as your IP addresses, geographical location, browser type, referral source, length of visit and number of page views. Individual users will not be identifiable from this information and we may use this information for a number of purposes including website administration, optimising the use of the Site, disclosing to third party contributors or for security purposes. In particular, we may use an analytics service provider for website traffic analysis and reporting and to track information such as which browser, screen resolution and IP address you are using to access the Site, in addition to tracking your movements around the Site. Information in the public domain
3.6 We may obtain some information from publicly available resources such as Companies House, newspaper articles or open postings on social media.
4. HOW WE USE YOUR INFORMATION
4.1 We will mainly use your information for the following purposes:
- To ensure that content from the Site is presented in the most effective manner for you and for your computer to process your donations and to maintain accounts and records of all donations received through the Virgin Money Giving reporting system.
- To enable us to provide you with any email updates or newsletters that you may have subscribed to from time to time.
- To provide customer service in relation to your use of the Site and your donations, to contact you, to deal with enquiries and complaints relating to the use of the Site and to notify you about changes to any services.
- To administer your donation or support your fundraising, including processing Gift Aid.
- To invite you to events.
- To keep a record of your relationship with us and record the contact we have had with you.
- To ensure we know how you prefer to be contacted.
- To internally monitor usage of the Site so as to enable us to improve the Site.
- To provide third parties with statistical information about our users but this information will not be able to be used to identify any individual user.
4.2 Tools may be used to improve the effectiveness of The Queen’s Commonwealth Trust communications with you, including tracking whether you open the emails we send you and which links you click within a message.
4.3 We may also use personal information to carry out due diligence so that we are fundraising in accordance with the law, the Fundraising Regulator’s Code of Fundraising Practice and our own internal policies and procedures.
5 LEGITIMATE INTERESTS
5.1 The law allows personal data to be collected and used by an organisation if it is necessary for the legitimate business interests of the organisation. In broad terms, our ‘legitimate interests’ mean our interests in being able to run The Queen’s Commonwealth Trust as a charitable entity effectively in pursuit of our objectives, provided that what the information is used for is fair and does not unduly impact the rights of the individual concerned.
5.2 The following are some of the examples of when and why we would use this approach to our work:
Direct Marketing: We may send postal marketing and fundraising requests which further the aims and objectives of The Queen’s Commonwealth Trust and don’t unduly impact the rights of the individual.
Profiling and analysing information: We carry out limited profiling and research to help us understand our donors and potential donors, including gathering information from publicly available resources to give an insight into philanthropic interests and ability to support The Queen’s Commonwealth Trust (see below for more details).
5.3 Profiling and analysing information of our supporters
In order to tailor what type and level of support we ask you for, we may analyse personal information we collect about you including how you have engaged with us previously, demographic information, measures of affluence, philanthropic interests and networks.
We may also use information in the public domain, for example listed Directorships or typical earnings in a given area.
In some instances, we may use third party wealth screening companies or insight companies to provide us with general information about you (please refer to section 6 for further information on data shared with third parties). You can opt out of your data being used for profiling and wealth screening techniques by contacting the Company Secretary (mail to: email@example.com)
6. DISCLOSURE OF YOUR INFORMATION
6.2 We may disclose your personal information to:
Any data processor who undertakes any of the functions referred to in sections 3, 4 & 5 above on our behalf (including without limitation for the purposes of processing payments, undertaking newsletter mailings, designing, maintaining and administering the Site).
6.3 Any personal information that you include in any goodwill message may be posted to the Site which will be accessible to anyone who visits the Site wherever they may be located.
7.2 The type of cookies we use:
Google Analytics Google Analytics are used widely by websites to collect information about how website visitors use a site. We will use Google Analytics cookies to collect information about how users use the Website and to improve the Website. Google Analytics collect information in an anonymous form and will not allow us to identify you or collect any personal information about you. Google Analytics do not track your internet activity after leaving the Site.
Configure your cookie settings here.
8. THIRD PARTY CONTENT, SITES AND CONTRIBUTORS
8.1 The Site may contain content and links to websites and microsites that are operated by third parties. In addition, any advertisements contained on the Site may operate as links to that advertiser’s websites, and advertisers and third parties may also use and place cookies on your computer.
8.3 If you have any queries or complaints in relation to such third party sites, content, advertisements and/or links which feature or can be accessed via the Site, please contact us (please see section 1). We will try our best to assist with your queries and complaints although please note that we may not be the data controller in respect of the data that you submitted or is collected via such third party sites therefore we may not be able to do anything.
9. SECURITY AND DATA RETENTION
9.1 We and all third parties that process personal data on our behalf employ reasonable security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period in order to achieve or facilitate the purposes described above or as long as the law requires or permits.
9.2 We, or our data processors on our behalf, will store all the personal information, including your login and user details (where applicable), on our secure servers.
9.3 All electronic transactions that you make via the Site and that are processed by our third party payment service provider will be encrypted using industry standard encryption technology. This technology will encrypt all of your credit card numbers so that they cannot be read as the information travels over the internet.
9.4 Notwithstanding clause 9.3 above, data transmission over the internet is inherently insecure and susceptible to unauthorised access and interception, and we cannot guarantee the security of data sent over the internet.
10. INTERNATIONAL DATA TRANSFERS
The servers used to process your information are situated in the UK, however we collect data from wherever users are situated. The information that we collect may therefore be transferred to the UK from any other country in which you may be located and will be subject to UK data protection laws rather than the laws of the country in which you are resident.
11. YOUR RIGHTS
11.1 You are entitled to know what personal data we hold about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us using the information provided above.
11.2 You may request us to cease sending you any correspondence, email updates and newsletters at any time by notifying us in writing or following any “unsubscribe” instructions included in any email sent to you.
11.3 If you have received unwanted, unsolicited emails sent via this system or purporting to be sent via this system, please forward a copy of that email with your comments to firstname.lastname@example.org for review.
11.4 Please let us know if the personal information which we hold about you needs to be corrected or updated at any time.
11.5 If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law: www.ico.org.uk/concerns. Or by post at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.