Privacy policy v 1.4 (December 2019)

We are the Henry Smith Charity of 65 Leadenhall Street, London, EC3A 2AD registered with the Charity Commission under the number 230102, and below we shall explain how we both use the personal information which you entrust to use and how we protect that information.

If you would like to know more about how we process your information, would like to request a copy of that information, or to enforce any of your rights, please contact our Compliance Manager whose details can be found at the end of this policy.

This privacy policy sets out how we use and protect any information that you provide to us either in a manual or electronic format or captured by us while you are using our website.

About us

The Henry Smith Charity is an independent grant making trust. We aim to bring about lasting change to people’s lives helping them benefit from and contribute to society.

Why we need your information

We need your personal information to allow us to offer our services to you and to comply with our legal and fiduciary duties. We will only collect the minimum amount of information necessary to provide our service to you or to comply with our legal obligations.

To help you swiftly find which part of this policy applies directly to you we have split the information into the following sections:

  • Grant applications
  • Kindred
  • Volunteer Visitors
  • Kindred Visitors
  • Ordinands
  • Trustees
  • Visitors to our website
  • Human Resources
  • Finance
  • Photographs
  • Requests to use our logo

Grant Applications

In order to process grant applications personal information must be provided to us, this will include name and contact details of the parties making the application as well as other relevant information relating to the application.

We will use this information, along with subsequent progress reports, only for the purposes of assessing your application, managing or monitoring any grant awarded and related administration or research purposes. Details may be shared with other funding organisations to use in their own assessment of applications and managing or monitoring of grants awarded, and for the detection and prevention of fraud.

Whilst it is not required, or requested, some applicants do include case studies and other information able to identify other individuals within their application. Where possible this information is deleted immediately upon receipt. Applicants should ensure that no personal information relating to third parties is included without the written agreement and permission of the individuals concerned.

Kindred

The Henry Smith Charity not only provide grants to good causes, but support the descendants of our founder and benefactor, Henry Smith.

We maintain a register of all the descendants of Henry Smith, and we do this to help us identify offspring that may benefit from our support. We use online and offline family tree services and genealogy websites together with public records such as the Probate Office and the Central Registry Office, the latter help us verify relationships and applications. We refer to this descendent information as ‘Kindred’ data.

If you make an application for a grant, we will collect only that information necessary to assist us in processing the grant request. This may include copies of documents and certificates to verify your identity, details of your finances and your personal circumstances, some of which may be of a sensitive nature, such as details of medical conditions. Other information that may be relevant to supporting the grant application may also be processed.

As with all personal data we will keep this information secure and never share with any unauthorised third parties. If you would like to know more about how we collect, process and use this information contact our Kindred team using the contact details below.

Volunteer Visitors

We will use your information for the purposes of managing the volunteer recruitment process, administering and arranging volunteer visits, managing your volunteer experience, including training and conferences and for the purposes of anonymised statistical analysis and research.

Some information, such as your nationality, date of birth, address and bank details are essential for your volunteering role.

We may ask for medical information so that we can support you in your volunteering, although you are free to decline these requests as they are not compulsory.

Details of a person to contact in an emergency are required for our lone working policy as well as any other information you chose to give us.

We may share your name and basic contact information with grant applicants you have agreed to visit.

Kindred Visitors

We will use your information for the purposes of managing the Kindred Visitor recruitment process and administering and arranging kindred visits.

Some information, such as your CV, nationality, date of birth, address and bank details are essential for your recruitment, visiting role and for enhanced DBS clearance checks.

We share your name with kindred grants applicants you have agreed to visit.

Ordinands

We collect the details supplied in bursary fund application forms for the purposes of awarding these bursaries. Information collected includes name, age, gender, nationality, marital status and supporting statement. This information may be used internally for analysis of our bursary funding work.

    Trustees

    We process the personal details of Trustees to comply with our legal obligations, to comply with the requirements of the Charity Commission and to keep in regular contact.

    We maintain a list of Retired Trustees for the purposes of keeping in touch with newsletters and invitations to events.

    Visitors to our website

    We may collect anonymous information about you when you visit our website. We do NOT have any contact us or newsletter sign-up functionality on our site, however by visiting our website we will be able to see your IP address and the pages you visit. Your information is completely anonymous.

    If you accept our default cookie settings, then information is captured by Google Analytics – please see the section below for full details.

    Human Resources

    To comply with employment legislation and ensure that all staff and trustees working within the organisation are qualified, competent, vetted and receive ongoing training we will collect both personal and sensitive information and may keep that in a manual or electronic form.

    Records will include personnel files, training records, minutes of meetings and other relevant documentation.

    In order to consider your application, offer employment, and comply with our legal obligations, for example, the right to work within the UK, we ask for your personal details including contact details. Other information such as qualifications and work experience will be requested to ensure you are qualified to fulfil your role. Some information, such as your nationality, date of birth, address and bank details, are essential for your employment.

    We share employee details such as salary information and bank details with an external payroll service company who process the payroll on our behalf.

    We may also ask for details of your ethnicity and sexuality, to comply with anti-discrimination laws, and medical information so that we can support you in your employment. You are free to decline these requests as they are not compulsory.

    Details of next of kin will be collected as well as any other information you wish to give us.

    Finance

    Where there is a need to make financial transactions, such as processing expenses claims, for individuals, we will hold details such as name, contact details and bank details within our finance system. These details are used only for the purpose of making these transactions and for holding a record of these transactions.

    Photographs

    We sometimes use photographs of funded projects for publicity purposes. Where these photographs include pictures of people, we request confirmation that those people in the picture have given their consent for the picture to be used in this way.

    Requests to use our logo

    We receive names, email addresses and other contact details of those grant holders who request to use our logo. This allows us to verify that requests are from existing grant holders and provide our logo in an electronic file format in order that grant holders may acknowledge the support of The Henry Smith Charity in their publications.

    The legal reason we process your information and how long we keep it

    We will only use your personal information for the purpose for which it was given, will not keep it for longer than necessary and will destroy the information securely according to our data retention policy.

    Below is an overview of the legal reason, called the ‘lawful basis’ of why we process your information as well as guidance on how long we shall retain personal information:

    Area Purpose Lawful basis How long we keep
    Grant applications To process grant applications Explicit consent/Legal & Contractual obligations & legal obligations 7 years after grant completed
    Grant applications Detect fraud Legitimate interests & legal obligations 7 years
    Kindred data Genealogy information Legitimate interests Indefinitely
    Kindred data Grant Applications Explicit consent/Legal & Contractual obligations & legal obligations 7 years
    Visitors to our website Website analytics Legitimate interests 7 years
    Human Resources Personnel File – non-essential elements (diversity information/photographs etc) Explicit consent 7 years after employment
    Ordinand Bursary Fund Applicants To process bursary fund applications Legitimate interests & legal obligations 7 years
    Human Resources & Volunteer Visitors Application Forms / CV’s Legal obligation

    If employed/recruited
    – 7 years after employment

    If unsuccessful

    – 6 months

    Volunteer Visitors Lone working information (emergency contact, transport details) Explicit consent 1 year after volunteer role ends
    Volunteer Visitors Essential elements: Contact details, Address Explicit Consent 1 year after volunteer role ends
    Finance Bank details, individual payment records, contact details Legal obligation 7 years
    Trustees Contact details, public information, meet our legal obligations Legitimate interests and legal obligations. 1 year after trustee role ends
    Trustees Essential contact details for keeping in touch Explicit consent Indefinitely
    Requests to use our logo Requests to use our logo in publicity Consent & Legitimate interests 2 years
    General Emails Legitimate interest/consent As swiftly as possible but maximum 2 years

    Lawful basis explanation (you could do this as an external link or dropdown if easier).

    Consent: You have given your clear consent for us to process your personal data for a specific purpose. This may be verbal or written consent to process.

    Explicit Consent: As above but the consent is usually in writing.

    Contract: The processing is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract.

    Legal obligation: The processing is necessary for us to comply with our legal obligations, or the law.

    Vital interests: The processing is necessary to protect someone’s life.

    Public task: The processing is necessary for a task in the public interest or for official functions.

    Legitimate interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party. Please note our legitimate interests can only be used if your privacy rights are not overridden.

    Substantial public interest: Processing is necessary for reasons of public interest as long as specific measures are in place to safeguard your rights and freedoms.

    Archiving or Research purposes: Processing is necessary for archiving or research purposes in the public interest.

    Security

    We are committed to ensuring that your information is kept secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.

    All information collected from or about you is hosted within the UK or the EEA (European Economic Area).

    Third party sharing

    Your information will not be shared with third parties unless you have previously been informed, for example, on an application form we will advise you if we need to share with partners or other bodies, or with the Kindred we may need to share your details for you to obtain external assistance or support. In many cases we must share your data as the law requires us to do so, for example, sharing financial or tax information with HMRC, or with the police for the detection or prevention of crime.

    We also have a duty to ensure that no fraudulent claims are made; sharing with other grant making bodies may take place to assist with this aim. Details of applications and, albeit it very rarely, complaints will be shared with the appropriate teams internally and with our board of Trustees.

    Cookie Policy

    A cookie is a small file which is placed on your computer’s hard drive. Some cookies are essential for the site to operate. Other non-essential cookies, such as analytical cookies, help us understand how our site is being used. These ‘non-essential’ cookies are only used if you agree to their use. Read our Cookie Policy for more information.

    We do not store personal information such as name or address which can identify the user of our website within the cookies that we use.

    Google Analytics

    We use Google Analytics to analyse the use of our websites; Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ devices.

    The information generated relating to our website is used to create reports about the use of our website. Details captured during your visit will include, but are not limited to, your IP Address, traffic data, location data, weblogs and other communication data and the resources you access. All data collected by Google is anonymous and will not be used to identify you as an individual.

    Google, not The Henry Smith Charity, stores this activity information, and you can view Google’s privacy policy at http://www.google.com/privacypolicy.html.

    To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

    Links to other websites

    Our website may contain links to other websites of interest. However, once you have used these links and left our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

    Your rights

    The Data Protection Act 2018 and GDPR provides you with certain rights and these are listed below for your convenience:

    • You have the right to access a copy of the personal information we hold about you by making a Data Subject Access Request (DSAR), you can do this by phone, in writing or by email to the Compliance Manager whose full contact details are provided at the end of this Privacy Policy. We will have to verify your identity before we can proceed.
    • You have the right of rectification to amend or update your personal information and ensure we maintain accurate and up to date records and or data about you.
    • You have the right to erasure, also known as ‘the right to be forgotten’.
      The broad principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing by the Henry Smith Charity.
    • You have the right to ‘block’ or suppress the processing of your personal data. Processing of your personal information may be restricted in the event it is no longer essential to support the use of services provided to you and/or not part of any contractual, legal or financial requirement to do so.
      The Henry Smith Charity is permitted to store the personal data, but not further process it. We will retain just enough information about you to ensure that any restriction is respected in future.
    • You have the right for data portability which allows you to obtain and or reuse your personal data for your own purposes across different services. This right allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. This right does not apply to any information held by Henry Smith Charity.
    • You have the right to object to the processing of your personal information where processing is based on consent, our legitimate interests or the performance of a task in the public interest or exercise of official authority including profiling activity, direct marketing including profiling activity; and processing for purposes of scientific and or historical research and statistics.
    • You have right to be made aware of any automated decision-making, that is a decision or processing made without any human involvement, and/or profiling of your personal information – again, the Henry Smith Charity do not perform any automated decision on you.
    • You have an absolute right to ask us to stop sending you direct mail or email. At Henry Smith we do not send unsolicited direct marketing.

    For some processing you will have given us permission to process your information, and in these cases, you can withdraw your consent at any time. In certain situations, these rights may not apply, for example, if you applied for a grant we would process your original request with your consent. If you then withdraw your consent after the application had been processed any information relating to that grant would not be deleted until the 7 year term. The reason being that we are then processing the application under our legitimate interests, for legal obligations and defence of a legal claim.

    If you are unhappy with how we have processed your information, you have the right to lodge a complaint with the Office of the Information Commissioner, contact details below.

    Changes to this policy

    The Henry Smith Charity may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 20 December 2019.

    Our contact details

    The Compliance Officer

    Henry Smith Charity, 65 Leadenhall St, London, EC3A 2AD

    Telephone number: 020 7264 4970

    Email: compliance@henrysmithcharity.org.uk

    Charity Registration Number: 230102

    ICO Registration No: Z8024318

    Complaints

    If you are unhappy with how we have processed your personal information please firstly contact the Compliance Manager listed above, if you are still unhappy you may contact the following:

    Information Commissioner’s Office

    Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

    Helpline: 0303 123 1113 (local rate) or +44 1625 545 745

    URL: https://ico.org.uk/make-a-complaint/