This policy was reviewed in October 2023.
A. What is the purpose of this policy?
References to the processing of information includes the collection, use, storage, sharing 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 rely on having your consent or a legitimate interest to process your data, you are entitled to ask that we modify the way in which we process your data or stop doing so completely (subject to any other overriding legal obligations), 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.
B. What data do we process?
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 its staff, volunteers and those who work for or with us. 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;
- Information relating to staff and volunteers necessary for their engagement including, but not limited to, payroll details and information required to ensure the safeguarding of vulnerable persons;
- Information necessary to run events and to inform stakeholders, supporters and donors about our activities, projects and other information pertaining to the work of the Portland Trusts that we think you may be interest in;
- Such other information is relevant and necessary for the Portland Trust to carry out its activities, charitable purposes and legal obligations.
The legal basis and purposes for which different categories of data are processed will vary depending on the purpose for which the data was collected, but will in any event only be collected and retained to the extent and for the duration deemed necessary for such purpose or purposes. The Portland Trust takes all reasonable steps to ensure the personal data processed is accurate. If you believe that any information we are holding about you is incorrect or incomplete, please write to us as soon as possible. We will promptly correct any information found to be incorrect.
C. What we do with this data?
We may use your personal information to send you our monthly Palestinian Economic Bulletin and other relevant publications, together with information which we think may be of interest to you about the Portland Trust, matters relating to our activities and the projects we support and about the economic status of the region with which the Portland Trust is concerned.
If we share your data for operational reasons with colleagues or trusted partners outside of the UK or European Union, such as our staff or project partners in Israel or Palestine, or to back-up and securely store data in the United States, 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. Where necessary, we will ensure that data is shared only pursuant to the requisite standard contractual clauses (‘SCC’s’).
D. Your rights
You, as the data subject, may unsubscribe from any distribution lists, 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, for example, to retain Gift Aid records for HMRC. We may keep a limited amount of data on a ‘suppression list’ so we know not to contact you or process your data in future until further notice.
You may request details of personal information which we hold about you. This is known as a data access request and should be submitted in writing to the Portland Trust’s Data Protection Officer. Once we have verified your identity, the response will be sent within one calendar month, in a comprehensive and intelligible form. Response to a request is free; however, if additional data copies have been requested by the data subject, or if requests are unfounded or excessive a small free may be payable.
You can obtain further information about Data Protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk/your-data-matters/
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure of sensitive information, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we process and prevent unauthorised sharing of information. Persons processing data on behalf of the Portland Trust do so in accordance with this policy and on the basis that we are 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.
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.
Google analytics collects and stores information about your browsing device, including, where available, your IP address, operating system and browser type, together with certain anonymous statistical data about your browsing activities and patterns which does not contain any personal data. This data is stored on the Google servers, and not on the Portland website.
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.
H. Links to external websites