PERSONAL DATA PRIVACY NOTICE
Open Hands (OH) is a small charity with a limited need to collect and process data from our donors, other supporters and other contacts (collectively, “our Contacts”) . As such we have not considered it necessary to register under the Data Protection Act 1998. However, the implementation of the EU General Data Protection Regulation (GDPR) in May 2018 and the new Data Protection Act impose new obligations on OH in relation to personal data, which this notice addresses.
Personal Data
For the purpose of this notice, the term “personal data” means data relating to a living individual which allows that person to be identified. Such identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.
OH is unlikely to acquire personal data from any source other than the individual identified by the data or someone acting on such individual’s behalf and with their knowledge.
Data Controller
OH is the data controller (contact details below) as it decides how personal data is processed and for what purposes.
How OH Uses Personal Data
OH acquires personal data in various ways including through our website
We use your personal data for the following purposes: -
- To maintain records of our contacts who have expressed an interest in OH’s work and to send communications about the activities of OH and its Romanian associate, Fundatia Open Hands (FOH), to such individuals from time to time;
- To fundraise for OH, which will include processing of donations by means of Gift Aid or similar tax efficient arrangements;
- To manage our employees (if any) and volunteers;
- In the operation of our Child Sponsorship Program;
- To maintain OH’s accounts and records;
OH does not access bank account, credit card or similar financial data from donors, although the agencies through which it collects some donations (Virgin Giving and Just Giving) may have such information.
Security and Other Matters
OH is committed to ensuring that personal data is maintained securely and is protected from loss, unintended destruction or damage and from unauthorised or unlawful processing; it has put in place suitable physical, electronic and organizational procedures.
OH will not collect or retain excessive amounts of personal data and will, to the extent it is able, keep the personal data it needs up to date.
Retention
Personal data will be retained in relation to each of our contacts and volunteers as long as relevant law requires or, if longer, so long as we consider there to be an ongoing relationship an individual. After that time such data will be securely destroyed.
Legal Basis for Processing Personal Data
Personal data is processed on the following bases:
- For our contacts (including members of our Child Sponsorship Program) and volunteers, explicit consent of the individual in relation to one or more of the data uses set out above.
- For employees, processing necessary for carrying out obligations under employment, social security or social protection law, or other relevant laws;
Sharing Personal Data
Subject to the following or to the requirements of any relevant law, personal data will be treated as strictly confidential and will only be shared among the trustees and employees of OH and OH will not share personal data with third parties. Personal data may also on occasion be shared with volunteers working with OH.
Where volunteers intend to visit projects in Romania it may for local legal or other reasons be necessary to share personal data with the staff of FOH (who will operate similar protections to OH by virtue of the GDPR) or Romanian governmental authorities.
Personal data may also need to be shared with tax authorities to allow for tax reclaims or other processing of donations qualifying for tax benefits.
Rights in Relation to Personal Data
Unless subject to an exemption under the GDPR, individuals have the following rights with respect to their personal data: -
- The right to request a copy of any personal data which OH holds;
- The right to request that OH corrects any personal data if it is found to be inaccurate or out of date;
- The right to request that personal data is erased where it is no longer necessary for the OH to retain such data;
- The right to withdraw consent to the processing at any time
- The right to request that OH provide a copy of personal data and where possible, to transmit that data directly to another data controller, (where applicable).
- The right, where there is a dispute in relation to the accuracy or processing of personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable)The right to lodge a complaint with the Information Commissioners Office.
Exercising some of these rights may make ongoing participation in our child sponsorship program impossible.
Further processing
If OH wishes to use any individual’s personal data for a new purpose, not covered by this notice, then we will provide that person with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, OH will always seek such individual’s prior consent to the new processing.
Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact Open Hands Charity, Spindle Tree Cottage, Stockland Lane, Hadlow Down, East Sussex TN22 4EA or This email address is being protected from spambots. You need JavaScript enabled to view it.You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
June 2018
