Anton Jurgens Charitable Trust is a registered UK charity (nr. 259885) and hereinafter referred to as ‘AJCT'.
1. Data Protection Principles
AJCT is committed to processing data in accordance with its responsibilities under data protection legislation including, the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. AJCT is committed to the GDPR data protection principles, namely that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
- accurate and, where necessary, kept up to date. Every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General Provisions
- This policy applies to all personal data and special personal data processed by AJCT.
- The Responsible Person shall take responsibility for the AJCT’s ongoing compliance with this policy.
- The Responsible Person is currently Marieke Edge-Jurgens.
- This policy shall be reviewed at least annually.
3. Data Subjects’ Rights
- Individuals have, in certain circumstances, the right to access, rectify, object to and restrict the processing of, their personal data and any such requests made to AJCT shall be dealt with in a timely manner and in accordance with the legal requirements.
- Individuals also have, in certain circumstances, the right to be forgotten and rights in relation to automated decision making, and any requests made to the AJCT shall be dealt with in a timely manner and in accordance with the legal requirements.
- Any requests relating to data subject’s rights should be referred to the Responsible Person, whose details are below at paragraph 11.
4. Lawful Purposes of Processing Personal Data
- All data processed by AJCT must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests or legitimate interests. AJCT has identified the following as being our legistimate interests: the assesment of fund applications in order to make decisions on applications, the administration of AJCT, debt recovery, processing accounts and recruitment.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. The individual will have a right to withdraw their consent as easily as they give consent.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent is available.
5. Special Personal Data
In the event that AJCT needs to obtain special personal data from you, other than as required by law, we will always tell you why, how the information will be used and obtain your consent to this, which can be withdrawn at any time.
6. Website Useage and Cookies
Our website uses both persistent and session cookies. Most browsers allow you to block cookies. We may process data in relation to your visit to our website and share this data with third parties for statistical information about the users of our website. We may also use the information to keep our website secure and to prevent fraud. We will further process any information that you chose to send to us through our website.
7. Disclosing Personal Data
- We may disclose your personal data to any of our trustees, volunteers, officers, insurers, professional advisors, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in the policy, or otherwise as required by law.
- We will only disclose your special personal data with your explicit consent, other than as required by law.
- Before you disclose to AJCT the personal data of another person, you are responsible for ensuring that you have the authority for such a disclosure. AJCT cannot take any responsibility for such a disclosure.
8. Archiving, Destruction and Retention
- AJCT will ensure that personal data is kept for no longer than necessary.
- Records, data and information will be retained in accordance with legal requirments and best practice.
- When personal data is deleted this will be undertaken securely, such that the data is irrecoverable.
- AJCT shall ensure that personal data is stored securely.
- Access to personal data shall be limited to personnel who need access.Where required, appropriate back-up and disaster recovery solutions shall be in place.
- In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, AJCT shall promptly assess the risk to people’s rights and freedoms;
- if appropriate report this breach to the ICO, and, where appropriate, to the individuals concerned.
11. Transfers of Personal Data to Third Countries
If AJCT needs to transfer personal data for processing to Third Countries (which is to say a country which is outside the EEA) it will only do so in accordance with legislative requirements.
12. Contact Details, Queries and Complaints
- We will always endeavour to resolve your matter to your satisfaction.
- You also have the right to refer any complaints to the Information Commissioner’s Office in the UK, and, where appropriate, to equivalent supervisory authorities in the European Union.