PRIVACY & COOKIES

Data Privacy Impact Assessment

PRIVACY POLICY

Introduction

This privacy and cookies notice (Notice) explains how The HDH Wills 1965 Charitable Trust, the Martin Wills Fund and the Martin Wills Wildlife Maintenance Trust (the Charities (or Charity where applicable), us, we, our) collects, uses and discloses your personal data, and your rights in relation to the personal data we hold.

This Notice may be updated from time to time; however, any major changes will be notified directly to those affected wherever practicable. This Notice is effective from June 2018, when it was last updated.

Data controller and contact details

Where your data is processed in relation to a grant application, the respective Charity to which you make your application will be the data controller of your personal data.

Where your data is processed in relation to your tenancy of a property on the Ditchley or Ousden Estates, The HDH Wills (1965) Charitable Trust (the Trust) will be the data controller of your personal data.

The Charities are subject to EU Regulation 2016/679 (the GDPR) and, when in force, the UK Data Protection Act 2018.

The Charities all have the same administrator. If you have any questions about how any of the Charities use your personal data, whom we share it with, or if you wish to exercise any of the rights set out in this Notice, please contact us using the following details:

• By post – The Trust Administrator, Henley Knapp Barn, Fullwell, Chipping Norton, Oxfordshire, OX7 4EN.
• By email – trust@hdhwills.org
• By telephone – +44 (0)1608 678051

How we collect your information

We may collect your personal data in a number of ways, for example:

• From the information you provide to us when you meet with one of our trustees, employees or representatives;
• When you use or make an enquiry via the Website or when you communicate with us by post, telephone, fax, or email;
• When you complete and submit grant applications using the Website or by post or email;
• From updates and progress reports we receive from organisations who receive our charitable grants; and
• From third parties such as the Trust’s managing agents, Orpwood Limited (t/a Adkin), who manage residential properties on the Ditchley and Ousden Estates on the Trust’s behalf.

The types of information we collect

We may collect the following categories of personal data about you:

• Where you are a grant applicant, or have been specifically mentioned in a grant application or in a report on a grantee’s use of charitable funds, the respective Charity will collect your name and the name of the organisation you represent, your role at the organisation, contact information and any other personal information that has been included in the application or report;
• Where you are a tenant of a residential property the Trust collects your name, address, and information concerning issues raised in relation to the property (for example, how the property has been treated by you or any complaints raised by other residents that involve you);
• CCTV cameras on the Ditchley and Ousden Estates may capture your image. On occasion (for example, when an incident arises), these images are passed to the Trust by our managing agent who operate the CCTV cameras on the Trust’s behalf. Please see our CCTV policy for more information (CCTV policy);
• Please see our DPIA policy for more information (Data Privacy Impact Assessment);
• Information concerning your engagement with the Charities, including records of communications between you and us and your attendance at the Charities’ events and meetings;
• Your opinion and feedback in relation to any surveys or questionnaires that you complete such as feedback on the Charities’ seminars and events.

The basis for processing your data, how we use that data and with whom we share it

Where we have a contractual relationship with you
We may process your personal data because it is necessary for the performance of a contract, or to take steps at your request prior to entering into a contract. In this respect, we use your personal data to enter into tenancy agreements with you and to instruct our managing agents in relation to your tenancy.

Legitimate interests
We may process your personal data because it is necessary for our or a third party’s legitimate interests. These legitimate interests include the Charities’ charitable objectives. This will always be weighed against your rights, interests and expectations. In this respect, we use your personal data for the following:

• To process grant applications in respect of the Charities’ funds and to evaluate how charitable funds are being used;
• To process any enquiries in relation to the Charities’ activities;

In this respect, we provide your personal data to the following:

• Our professional advisers where it is necessary for us to obtain their advice or assistance;
• Our IT support and any data storage provider;

Your data may also be shared between the Charities; the Charities have the same administrator and individuals may be trustees of more than one Charity. Data is shared in this way so that we have oversight over which grant applicants have received funding and to be able to advise grant applicants in cases where another Charity may be more appropriate to receive a grant application.

Legal obligations

We may also process your data for our compliance with our legal and regulatory obligations. In this respect we may use your personal data to comply with subject access requests of others, tax legislation, safeguarding requirements, for the prevention and detection of crime, and to assist the police, the Charity Commission and other competent authorities with investigations (including criminal investigations).

Consent

In some circumstances we may seek your specific consent to process your personal data: for example, if we wish to use your likeness or an attributed quote in our newsletters or other materials that promote the Charities’ work.

If you have given your consent and you wish to withdraw it, please contact us using the contact details above.

International transfers

Our website, which holds information relating to grant applications, is hosted on a server based in the USA. Personal information will only be transferred outside of the EEA if an appropriate gateway (such as Privacy Shield) is in place.

Retention of your data

We will retain your personal data for so long as is required for our legal and regulatory obligations and for our legitimate business purposes after the termination of your relationship with us. In particular:

• We retain information in relation to successful grant applications and trustee minutes recording such information indefinitely;
• We retain information in relation to unsuccessful grant applications for one year after your application is turned down;
• We retain information in relation to tenancies at our residential properties for up to seven years after the relationship has concluded.

Your rights

You have the following rights:

• To obtain access to, and copies of, the personal data that we hold about you;
• To request that we erase your personal data;
• To request that we restrict our data processing activities;
• To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
• To require us to correct the personal data we hold about you if it is inaccurate.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply: for example, if we have reason to believe the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Notice.

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner ico.org.uk

CCTV policy