The Archbishop’s Palace Conservation Trust (“the Trust”) is a Charitable Incorporated Organisation, whose registered office is The School House, 21 High Street, Otford, Sevenoaks, Kent TN14 5PG. The registration number is 1173486.
As part of our work, we need to handle information relating to individuals, and we take privacy serious. We are committed to protecting your personal information. We comply with all applicable data protection laws and undertake to process your information in line with this policy. If you have any enquiries relating to the policy, our Secretary can be contacted at firstname.lastname@example.org
This Policy sets out the basis on which any personal data the Trust collect from or about you, or that you provide to us, will be used, or processed by us.
- Privacy Notices
1.1 We deal with information relating to our Service Users
1.1.1 We deal with information relating to customers of the Trust for the purpose of providing goods and services. We do this because it is necessary for a contract for commercial services that we have with each of these people. The information we deal with may include (for example) contact details and details of the purchase and payment details.
1.1.2 We deal with information relating to potential and current customers of the the Trust for the purposes of providing marketing information to them about the organisation and the goods and services offered. We do this because we have a legitimate interest in maximising the revenues from our goods and services. The information we deal with may include (for example) names and e-mail addresses of the individual.
1.2 We deal with information relating to our Suppliers
1.2.1 We deal with information relating to suppliers to the Trust for the purposes of administering contracts for supplies of products, goods, and services to the Trust. We do this because we have a contract with those suppliers. The information we deal with may include (for example) contact details, insurance details and financial details. We also deal with information relating to suppliers (and individual employees at suppliers) for the purpose of maintaining contact lists of people the Trust can call on to supply the Trust. We do this because it is in our legitimate interests to maximise the availability of suppliers to the Trust. The information we deal for this purpose are names and contact details.
1.3 We deal with information relating to our Donors and Prospective Donors
1.3.1 We deal with information relating to our Donors and Prospective Donors for the purposes of fundraising. We do this because it is in the legitimate interests of the Trust to raise money to further our activities. The information we deal with may include (for example) contact details, publicly available details of trusteeships of companies and charities. However, where we are fortunate enough to deal with a donor to the Trust, we also deal with information related to that donor for the purpose of processing a donation and we do this because of a contract with that donor. Also, sometimes we need to supply details about a donor and any donation to HMRC for Gift Aid purposes (which we do because it is a legal obligation to do so).
1.3.2 How much of this information we collect depends on the type of relationship we have with you and the information we build in the course of your relationship with us. We do not store information that is classed as ‘sensitive’ or ‘special category’ personal data (meaning data relating to health (physical or mental); ethnicity; political, religious or philosophical beliefs; trade union membership, sex life; or genetic/biometric identifiers) or any data regarding criminal offences that you share with us, unless there is a clear and valid reason for us having to process this particular data that complies with applicable law, primarily that we have your explicit consent, and/or that you have made that information public and/or we have to process that data in connection with a legal claim.
1.4 We deal with information relating to our Visitors
1.8.1 We deal with information relating to visitors to the Trust for the purposes Visitor management and building security, of keeping records of individuals accessing the Palace Buildings, of which we have a legitimate interest to do; and any accidents in the BIS of which we do because we have a legal obligation to do so. The information we deal with may include (for example) contact details of the visitors.
1.5 We deal with information relating to our Contacts
1.9.2 We deal with information relating to previous visitors to the Trust and interested members of the general public for the purposes of providing marketing information to them about the organisation, and public events being held by the Trust. We do this because we have received explicit consent from the individuals to provide them with the information. The information we deal with may include (for example) names and email addresses of the individual.
1.9.3 We deal with information relating to Media and Key Stakeholder Contacts (including MPs) for the purpose of dealing with the media, the public and their representatives. We do this because it is in our legitimate interests to maintain a good profile in the press and with the public. The information we deal with may include (for example) contact details and publicly available information.
1.9.4 We deal with information relating to our Industry contacts for the purpose of providing marketing information to them about the organisation. We do this because it is in our legitimate interests to market to these people. The information we deal with may include (for example) contact details.
1.9.5 We deal with information relating to Non-member individuals sign-ups for marketing to the Trust for various purposes which are: (i) to update them about the work, fundraising opportunities or other news about the Trust and the Palace itself; and (ii) to notify them about and market events run by the Trust. We do this only to the extent that we have the specific and informed consent of these individuals to use that information for those purposes. The information we deal with may include (for example) various details on these individuals (such as contact and career details, and details of their interaction with the Trust).
- Transferring Information Outside the European Economic Area (EEA)
In some circumstances your information may be transferred outside the EEA. This is usually where we are providing a service you have applied for where delivery is outside of the EEA, such as an event or through a commercial agreement. The countries we transfer information to may not have similar data protection laws as in the UK. If you are applying for, or helping us deliver, a service delivered outside of the EEA, you are agreeing to this transfer of data.
If we transfer your information outside of the EEA, we will take steps to ensure your data is secure. We work with trusted service providers and use suppliers who can evidence their compliance with the UK Data Protection Act 2018, and require them to hold information securely and confidentially.
- Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
3.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
3.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
3.4 Object to processing of your personal information where we are relying on a legitimate interest (of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
3.5 Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
3.6 Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
3.7 Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the Membership and Office Manager at email@example.com . We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal information (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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
- Your right to lodge a complaint with the ICO
If you feel that we have not handled information relating to you properly, or if you have contacted us about how we use that information and are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner’s Office.
By phone: 0303 123 1113
- Our Website
Your use of our website signifies your consent to us collecting and using data about you as specified below in accordance with this policy statement.
5.1 How do we collect information about you and how is it used?
- You may provide personal information when contacting or communicating with us, and we may keep a record of that correspondence
- You may use our services and give your name and e-mail address to make a comment about our services or website.
- We will collect information about your tastes and preferences, both when you tell us and by analysis of customer traffic, including using “cookies”.
- It may be that you provide us details of credit or debit cards or bank accounts in making payment to us. Any such information (confidential financial information) will be disclosed only in accordance with the disclosure policy below.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- We may use personal information collected about you through cookies to help us develop the layout of our website to ensure that our site is as useful and enjoyable as possible.
- We may use personal information collected to let you know about functions on our website or changes to our terms and conditions of use.
- Personal data provided to us by third parties in accordance with the law.
5.1.1 IP addresses
We may sometimes collect information about the computer or device you use to access our sites, including where available your IP address, operating system and browser type, for system administration.
5.1.2 Traffic data
We may provide aggregate statistics about sales, customers, traffic patterns and information to third parties, but these statistics will not include any information that identifies you or any individual personally.
5.2 Uses made of the information
We use personal data held about you in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products, or services that you request from us (for example, our newsletters) or which we feel may be of interest to you. This may be by post, email or other electronic means where you have expressly consented to be contacted for such purposes, or if you have purchased goods or services from us previously, we may contact you with information about similar goods or services that may be of interest.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service when you choose to do so.
- To notify you about changes to any service we have contracted to provide you with.
We will not pass your information on to third parties other than our contractors, suppliers, or agents who we use to provide services that you have requested or who help us provide those services. We do not sell or rent your personal data to third parties and shall only permit selected third parties to use your data.
All information you provide to us is stored on secure servers in the UK or European Union. Any payment transactions will be encrypted using SSL technology and any credit, debit card or payment details you submit online will be processed and held by our third-party payment processors, Stripe or PayPal. We do not hold credit or debit card data ourselves. When you sign up for our Friends of Otford Palace Newsletter, these details are held by MailChimp.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do what we reasonably can to protect your personal data and we have had this website security tested by a third party, we cannot guarantee the security of your data transmitted to our site and any such transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to protect your personal data against unauthorised or unlawful access or accidental loss, destruction, or damage.
6. Disclosure policy
We may disclose your personal information to third parties:
In the event that our organisation merges, transfers its assets or is acquired in which case your personal data may be one of the merged, transferred or acquired assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to establish, defend or enforce our legal rights or to protect the rights, property, or safety of the Trust, our customers or others with whom we interact. This includes exchanging information with other organisations for the purposes of fraud protection and credit risk reduction or the police or regulatory authorities.