Privacy Policy

Privacy Policy - The Portal Trust

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What this Privacy Policy covers

The Portal Trust, charity number 312425 is located at 31 Jewry Street, London EC3N 2EY and we are providing this Privacy Policy to explain our data collection, use and storage of any personal data which we process. The Portal Trust is the controller and responsible for your personal data. We are registered with the Information Commissioner’s Office, registration number Z7765677. Our VAT registration number is 701 7385 51.

The Portal Trust is committed to protecting your privacy and uses the most powerful and safe online experience. This statement of privacy applies to The Portal Trust’s website and to our processing activities in general. The conditions of processing of personal data and the purposes for which personal data may be collected, stored and used are described in this Privacy Policy. By using The Portal Trust’s website, you signify that you are happy with the data protection practices described in this statement.

Legislation

The Data Protection Act 2018 (incorporating GDPR) provides new rights to individuals regarding the collection, storage and use of their personal data. This Privacy Policy has been updated to take account of any new requirements under the Act. Also covered in this Privacy Policy are the requirements of the Privacy and Electronic Communications Regulations 2003 updated 2004 and 2011 (PECR). A revised ePrivacy Directive will be enacted into UK law and any changes will be adopted in a revised Privacy Policy.

Who is the Data Controller?

The Portal Trust

Data Controller contact details

0778 7371 761

Responsible person

We have appointed a person to be responsible for overseeing questions in relation to this privacy policy. If you have any questions please contact the Chief Executive, Mr. Richard Foley on privacy@portaltrust.org

What is personal data?

Personal data means any information which relates to a living individual who can be identified either directly or indirectly by reference to an identifier such as their name, email address and other personal details.

Why do we process your personal data?

We process your personal data for the following purposes:

- To respond to enquiries or requests that you send us
- To invite you to events or to inform you about our work and mission
- To send you marketing and fundraising information where we have lawful grounds.
- Staff and Governor administration including payroll and payroll administration, tax calculations and payments
- Performance assessments
- The provision of employee benefits including healthcare and maternity benefits
- Sickness, parental, volunteering and other types of leave
- Promotion and succession planning
- Training
- To monitor compliance with our policies and procedures including but not limited to our Data Protection Handbook, [policies].
- To process and administer grant applications
- General administration
- Recruitment
- Regulatory approvals to conduct charitable activities
- Other processes related to the above

What about children’s data?

We do not knowingly process personal data of children under 16

Improved rights under the General Data Protection Regulation

You have some improved rights under the Data Protection Act 2018 (incorporating GDPR).

Data Subject Access Request: You have the right to access the personal information we may hold about you. On receipt of such a request we will endeavour to respond to you as soon as possible, but at least within one calendar month. You must provide us with 2 forms of personal identity to ensure that we only disclose to you information which is relevant to you personally. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Rectification: You have the right to request that we amend any personal information that may be incorrect or require updating.

Erasure: You have the right to request that we delete any personal information pertaining to you. Any questions about these rights may be sent to privacy@portaltrust.org

Data Portability: There is a new right to data portability, primarily designed to make it easier for individuals to switch between service providers. This is unlikely to be relevant to your relationship with The Portal Trust.

The right to restrict processing: Individuals have a right to ‘block’ or suppress processing of personal data. If you decide to do this, we will continue to store the data, but not further process it until we have agreed a solution to the issue you have raised.

Do we collect any special categories of personal data?

We do not collect any special categories of personal data, as defined by the Data Protection Act 2018 (incorporating GDPR), except if you are a staff member. If you apply for a vacancy within The Portal Trust, but are not successful, we will delete your personal information including any special categories in line with our retention policy.

Special categories of data under the Data Protection Act 2018 (incorporating GDPR) are:

“racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”

Is data collected from third party or public domain sources?

We may collect your personal data from you, a member of staff, a Governor of the Trust, face to face, or from a public source where we believe that you will be interested in what we do. Where we collect personal data from third party or public domain source we provide a means to opt-out or unsubscribe on every message we send you.

What are our grounds for lawful processing?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• Where we have your consent

Legitimate Interest means the interest of our charitable organisation in conducting and managing our organisation to enable us to give the best help possible to disadvantaged young people in London in the field of education. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests and those of our charitable cause. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@portaltrust.org

How do we use your personal data?

Primarily we use your personal data to invite you to events that we think you may be interested in, to keep you advised of developments at the Trust and to provide you with opportunities to help us via our marketing and fundraising activities.

How to stop receiving communications

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time at privacy@portaltrust.org

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a grant application or other contract we may have with you.

If you donate on Justgiving you have the choice to select whether or not to receive further correspondence from The Portal Trust. We will not send marketing or fundraising communications to individuals who have unsubscribed, opted-out or otherwise asked us to stop direct marketing. Where we collect contact information from you which may be used for marketing or fundraising purposes, we will let you know how to stop receiving such information if that’s what you prefer.

Surveys or marketing research

We may contact you from time to time to seek your views via a short survey to inform our strategic direction, your thoughts about our work, and other matters. You always have the choice about whether to take part in our research.

Is data processed outside of the EEA? – If so how is it protected?

We do not process personal data outside of the European Economic Area

Is data shared with 3rd parties and if so, who?

We may have to share your personal data with the parties set out below for the purposes set out in the table below. External Third Parties are all based in the United Kingdom.

Service providers acting as processors who provide IT and system administration services.
- BVR Ltd – IT services

Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Capita Employee Benefits Ltd – Pension Actuaries
- Coutts Banking – The Portal Trust’s bankers
- Stuart McNicholas Consulting – HR
- Myers Clark – Accountants
- Sayer Vincent – Auditors
- Gunnercooke llp- Lawyers

HM Revenue & Customs, regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.

Marketing, communications and fundraising.
- Systemcore – Website
- JMM – Marketing

Third parties to whom we may choose to sell, transfer, or merge parts of our charitable organisation or our assets. Alternatively, we may seek to acquire other businesses or charitable organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we disclose personal data to our suppliers in order for them to process personal data on our behalf, we have a contract in place compliant with the Data Protection Act 2018 (incorporating GDPR) to ensure the security of any personal data that each processor or sub-processor processes.

Cookie policy

Our website uses simple cookies that:

i) Allow us to measure website traffic volumes, and better understand how our visitors use the website (via Google Analytics ‘GA’)
ii) Enable the simple viewing and sharing of our news announcements, events and articles (via ‘Twitter.com’)*
iii) Enable the simple sharing of our news announcements, events and articles (via ‘Facebook.com’)*
iv) We also use a cookie that itself remembers your cookie preferences – this is often referred to as an essential ‘cookie-cookie’ (called ‘Klaro’ cookie).

These cookies entail no personal data. Our website will disable all non-essential cookies until consent is granted, and allows you to enable or disable non-essential cookies via the ‘Manage my Cookies’ link in the cookie panel, on our home page.

*Third party cookies: These cookies are set by someone other than the owner of the website you’re visiting. Some of our web pages may also contain content from other sites like Twitter, who may set their own cookies. Also, if you share a link to one of our pages or news items for example, the service you share it on (e.g. Facebook) may set a cookie on your browser. We have no control over third-party cookies – you can always turn them off in your own browser settings, but not through our site.

Remember that you can always review, manage and delete cookies in your own browser’s privacy settings, at any time.

Data security – how we protect your data

We follow appropriate security procedures in the collection, storage and use of your information so as to prevent unauthorised access by third parties.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We process data at our registered offices at 31 Jewry Street, London EC3N 2EY with access restrictions in place and at the sites of our data processors within the UK. Our IT specialist retains our data at a different location equally protected behind the appropriate firewalls and other security devices.

However, unfortunately, the transmission of Information via the Internet is not completely secure. We cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Data Protection Act 2018 (incorporating GDPR) and, the Privacy and Electronic Communications Regulations. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.

External links not covered by this policy

Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies.

Your browsing and interaction on any other website or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the Information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to Information collected by us through our website or services and does not apply to these third party websites and third party service providers.

Data Retention Policy

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at privacy@portaltrust.org

Where the personal data relates to our events you may receive an invitation and our marketing and fundraising efforts where you may be interested in the work we undertake on behalf of disadvantaged young people in London in the field of education.

CCTV

Please be advised that if you visit our premises CCTV is in operation for security purposes in the main entrance hall.

What to do if you have a concern

Please contact us first on privacy@portaltrust.org and we will do our best to help you. If you are not satisfied you may contact the Regulator of the Data Protection Act 2018 (incorporating GDPR) and the Privacy and Electronic Communications Regulations 2003, updated 2004 and 2011 at the Information Commissioner’s Office. If you feel you wish to draw the Regulator’s attention to the way and the purposes for which we are processing personal data, you may contact the ICO.

Changes to this Privacy Policy

Amendments to this Privacy Policy are made every time something changes in the way or the purposes under which we process personal data

When was this last updated?

14th March 2020