Policy Owner: Anna Josse
Distribution: Not confidential – For Internal and External distribution
Prism the Gift Fund: a company limited by guarantee registered in England and Wales. Company no. 04677253 and registered charity no. 1099682
Rewriting Extinction is a restricted fund operating under the auspices of Prism the Gift Fund, registered charity no. 1099682
Prism the Gift Fund is committed to protecting the privacy of your personal data in accordance with Data Protection legislation. Further details about us can be found under “How to Contact Us” below.
The Data Protection Legislation
As from 25th May 2018, most personal data processing in the UK is subject to the EU General Data Protection Regulation (“GDPR”), as supplemented by UK legislation.
Personal data is any information that directly or indirectly identifies a living individual.
For the purposes of the GDPR, we will be the controller of any personal data that we collect from or about you in connection with the provision of our services, or related activities such as promoting our events or, where relevant, dealing with job applications.
Under the GDPR, data controllers are required to process personal data lawfully, fairly and in a transparent manner, and in a manner that ensures appropriate security of the personal data. Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. The data must be adequate, relevant and limited to what is necessary in relation to those purposes, accurate and, where necessary, kept up to date, and kept in a form which permits identification of data subjects for no longer than is necessary for those purposes. Data controllers are responsible for, and must able to demonstrate, compliance with these principles.
What personal data do we collect from or about you?
If you make an enquiry
If you contact us with an enquiry about our services (either through our Site or by phone, email or post), we will ask you to supply essential contact details (your name, e-mail address, phone number and, where applicable, the company or other person you represent and your job title), which we need in order to identify you and deal with your enquiry.
Depending on the nature of your enquiry, we may collect from you further details, such as the circumstances in which you are making the enquiry, the professional services that may be of interest to you or, where you are interested in a possible position with us, your CV and related information.
If you are or become a client or donor
If you are or become a client (or the company or other person you represent is or becomes a client) or donor, and in the course of providing our services, we may collect further personal data from you, depending on the nature of the services we are providing.
We may also need to ask you to provide further personal data, and may need to carry out background checks about you with credit reference agencies and fraud prevention agencies, for credit control purposes and in order to satisfy our obligations under any applicable legislation concerning money laundering, tax evasion, crime prevention and fraud protection. If you do not provide us with the information we need, we will not be able to provide our professional services for you or the company or other person you represent.
When you make a personal payment for our services, details of the method of payment, your bank details or your credit or debit card number will be processed.
If you are a professional or business contact
If you provide us (or one of our employees or other personnel) with your professional or business contact details or other relevant personal data, we will use this in order to keep in touch with you and exchange information that we believe is, or may become, relevant to our and your business or profession.
If you enquire about a job or becoming a volunteer
If you submit a job application or enquire about a potential position with us, or another person does so on your behalf, or with a view to becoming a volunteer with one of the collective funds or foundations that we administer, we will ask you to provide relevant personal information about you. Further details of the personal data that we collect, and of the basis on which we will process your personal data, will be provided at the time.
Why and on what basis do we process your personal data?
When you make an enquiry, we will process the personal data that you give us, or we collect from you or about you, so that we can supply you with the information that you have requested about our services, on the basis that it is necessary for our legitimate interests in promoting and marketing our services, or in order to provide a quotation for our services.
Clients and donors
If you are or become a client (or the company or other person you represent is or becomes a client) or a donor, we will process the personal data that you give us, or we collect from you or about you, in order to perform the contract that we have with you (or the company or other person you represent).
We will also process your personal data for internal record keeping, billing and accounting, and to respond to any queries, complaints or requests for further information, and for the purposes of archiving. The basis on which we do so is that it is necessary for our performance of the contract we have with you (or the company or other person you represent), or is necessary for our legitimate interests in managing our business and improving our services, and to comply with our legal and regulatory obligations.
In appropriate circumstances we will use the personal data that you provide or that we collect about you on the basis that we are required to do so in order to comply with our regulatory obligations, including those under applicable legislation such as that concerning money laundering, tax evasion, crime prevention and fraud protection.
Staying in touch
We provide a wide range of additional services and information for our clients and donors and our professional and business contacts, such as news updates and events. We would like to use the details on our database in order to inform you of these and the various services that we provide, on the basis that it is necessary for our legitimate interests in promoting and marketing our services. If you wish us to use your personal data in this way, please tick the relevant box or click the relevant link on the form or in the email that we send you. All future marketing communications will also contain a simple way to opt out of receiving any further marketing communications from us.
Who do we share your personal data with?
We will not use your personal data for any other purpose, or disclose it to any third party, without your consent unless we are required to do so by law, or as mentioned in this section.
Other professionals and other bodies
In order to provide some of our services, we may use the input of third parties such as lawyers, accountants and financial advisers, or we may refer you to such third parties, with your consent or where this is necessary for the performance of our contract with you (or the company or other person you represent). This will require the disclosure to such third parties of your contact details, as well as further personal data about you which is relevant to the services they provide. We may also be required to disclose your personal data to regulators, or where required to do so by order of the court, or to Government departments and local authorities and similar bodies in order to comply with legal obligations or to perform our contract with you (or the company or other person you represent).
Data processing and other services
Some of our data processing or other services are supplied by third party providers, who will need to have access to your data for that purpose. Such third party suppliers will be appointed on the basis that they provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing will meet the requirements of the applicable Data Protection legislation and ensure the protection of the rights of the data subjects, and will carry out processing only on our written instructions, or where we have a legitimate interest in doing so, as indicated above.
We may disclose your personal data if we are required to do so in order to comply with any legal or regulatory obligation or request, or where we have a legitimate interest in doing so, such as in order to enforce or apply our contract with you, to investigate potential breaches, or to protect our property and rights or those of others. This may include exchanging information with other companies and agencies for the purposes of credit risk reduction and to comply with legislation concerning money laundering, tax evasion, crime prevention and fraud protection.
Professional or business contacts
If you are not a client (or a representative of a client) or a donor, but have provided us with your professional or business contact details or other relevant personal data, we may share your personal data with our other professional or business contacts or those of our other Group members, on the basis that it is necessary for our legitimate interests in promoting and marketing our services, unless you indicate otherwise.
How long do we keep personal data for?
If you contact us with an enquiry about our services but you do not subsequently become a client (or the company or other person you represent does not do so) or a donor, it is our policy to delete your personal data after twelve months. If you are or become a client (or the company or other person you represent is or becomes a client) or a donor, we normally retain contract information (including personal data) for a minimum of 12 years after the end of the relevant contract or client relationship.
We may agree with you to retain documents and personal data for a longer period, and in some cases it may be necessary for us to do so, depending on the circumstances of the case, including where it is necessary for us to retain the data for a longer period for regulatory reasons or for the establishment, exercise or defence of legal claims.
Personal data relating to our professional contacts will be retained for so long as is necessary, or until you indicate otherwise to us, but we will aim to update our contacts’ preferences on a periodic basis.
Your rights as a data subject
As a data subject, you have certain legal rights (subject to certain exceptions under the Data Protection legislation) including the right:
- to access the personal data held about you and request a copy of it;
- to ask us not to process your personal data for marketing purposes;
- to withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your personal data on the basis of a consent that you have given (and not on some other legal basis);
- to ask us to rectify inaccurate personal data about you;
- to ask for the restriction of personal data about you that is inaccurate, unlawfully processed, or no longer required;
- to ask for the transfer of your personal data in a structured, commonly used and machine readable format where appropriate;
- to ask for the erasure of personal data about you where processing is no longer necessary, or the legitimate interests we have in processing your personal data are overridden by your interests, rights and freedoms as the data subject; and
- to make a complaint to the Information Commissioner’s Office, which can be contacted by post via: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone via 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
How to Contact Us
- by email to: firstname.lastname@example.org
- by post to: The Head of Internal Systems & Operations, Prism the Gift Fund, 20 Gloucester Place, London W1U 8HA.
Prism the Gift Fund is incorporated in England and Wales as a private company limited by guarantee, company number 04677253, and is registered as charity in England and Wales under number 1099682. Our registered office is at 20 Gloucester Place, London W1U 8HA, England.