References to the processing of information includes the collection, use, storage and protection of data. The Portland Trust is the ‘data controller’ for the purposes of this policy, and this policy extends to our staff, trustees and anyone else processing data on our behalf from time to time.
Organisations are permitted to process data if they have a legal basis for doing so. The Portland Trust processes data on the basis that:
- Express and informed consent has been given by the person whose data is being processed; and/or
- The Portland Trust has a legitimate interest in processing the data; and/or
- It is necessary in relation to a contract or agreement which the person has entered into or because the person has asked for something to be done so they can enter into a contract or agreement; and/or
- We have a legal obligation to process data.
Where The Portland Trust is relying solely on consent as the basis for processing data, we are required to obtain your explicit consent and you can modify or withdraw this consent at any time by notifying us in writing, although this may affect the extent to which we are able to provide services to or interact with you in future.
The Portland Trust may change this policy from time to time and any such changes will be published on our website. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.
This policy is effective from 6 April 2018.
B. What data do we collect?
We collect the data necessary for The Portland Trust to pursue its stated charitable objectives, including but not limited to driving initiatives to promote peace and stability between Israelis and Palestinians through economic development. Accordingly, data will be processed for operational purposes, keeping stakeholders and supporters informed of matters relating to the region and projects with which The Portland Trust is concerned, fundraising, organising and hosting events and the effective running of The Portland Trust through those who work with or for The Portland Trust. Data collected and processed may include, but not be limited to:
- Names and contact information such as telephone numbers, email and postal addresses.
- Stakeholder, supporter and donor records and preferences, including, where necessary, bank or payment details in order to process payments from or to individuals and information provided about an individual’s tax status for the purposes, for example, of claiming Gift Aid tax relief
- Such other information as is relevant and necessary for The Portland Trust to carry out its activities, charitable purposes and legal obligations.
C. What we do with the data we process
If we share your data with colleagues or trusted partners outside of the European Union, such as our staff or project partners in Israel or Palestine, we will only do so if we are confident that they adhere to the same high standards that we do when processing data and protecting its privacy and security.
We will not disclose your personal information to any other third party unless required to do so by law or unless it is reasonably necessary in our view to defend the rights or reputation of The Portland Trust or its users.
You, as the data subject, may change your preferences or request deletion of your data at any time in writing, subject to any overriding legal requirement for its retention, such as the need, where appropriate, to retain Gift Aid records for Her Majesty’s Revenue and Customs. We may keep such data on a ‘suppression list’ so we know not to contact you or process your data in future until further notice.
D. Your rights in relation to your personal data
You may request details of personal information which we hold about you. Any such request must be submitted in writing. A small fee may be payable if an information request is particularly onerous.
You may choose to restrict the collection or use of your personal information, but this may inhibit or limit the way in which we are able to interact with you. You may, at any time, change your mind about what information we hold about you, or if we continue to hold it at all, subject to any legal obligation on The Portland Trust to retain data.
You are responsible for the accuracy of data you have provided to us. If you believe that any information we are holding on you is incorrect or incomplete, please write to us as soon as possible. We will promptly correct any information found to be incorrect.
You can obtain further information about Data Protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk/for-thepublic(link is external).
We are committed to ensuring that your information is 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 data we process. Persons processing data on behalf of The Portland Trust do so in accordance with this policy and on the basis that The Portland Trust is satisfied that they can and will adhere to our high standards for data protection and security.
The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. If and where applicable, you are responsible for keeping confidential any password you use for accessing our website; in such circumstances, we will not ask you for your password (except when you log in to our website).
F. Web browsing and Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We may also collect and store information about your browsing device, including, where available, your IP address, operating system and browser type. This is anonymous statistical data about your browsing activities and patterns and does not contain any personal data.
An example of the sort of cookie we use is Google analytics – which tracks statistics on the number of hits we receive.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
G. Links to other websites