This website (the Website) and the material published on it is owned by the Anton Jurgens Charitable Trust, a registered UK charity (nr. 259885) and hereinafter referred to as ‘AJCT'. Unless otherwise stated, references to ‘we’, ‘our’ or ‘us’ are references to AJCT. By using the Website, you confirm that you accept the terms set out on this page and that you agree to comply with them.
1. Data Protection Principles
AJCT is committed to processing data in accordance with its responsibilities under data protection legislation including, the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. AJCT is committed to the GDPR data protection principles, namely that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General Provisions
- This policy applies to all personal data and special personal data processed by AJCT.
- The Responsible Person shall take responsibility for the AJCT’s ongoing compliance with this policy.
- The Responsible Person is currently Mr. F.Ch.M. Tilman.
- This policy shall be reviewed at least annually.
3. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect the following categories of personal data about you:
- Your name, job title and contact details such as address, email address, telephone number and contact preferences, such as when you complete forms or submit information to us;
- Any other information which you may provide to us from time to time, including any information you provide us with on a grant application form.
4. Ways Personal Data May Be Collected
We may collect your personal data in a number of ways, for example:
- From the information that you provide when you complete a grant application or other form;
- When you enter your details on our website (www.ajct.org.uk);
- When you communicate with us by post, telephone, fax, email or other forms of electronic communication;
- From information provided to us by your organisation in connection with a grant application or a project which we are supporting; and
- From other individuals or organisations seeking to introduce us to you.
5. Data Subjects’ Rights
- Individuals have, in certain circumstances, the right to access, rectify, object to and restrict the processing of, their personal data and any such requests made to AJCT shall be dealt with in a timely manner and in accordance with the legal requirements.
- Individuals also have, in certain circumstances, the right to be forgotten and rights in relation to automated decision making, and any requests made to the AJCT shall be dealt with in a timely manner and in accordance with the legal requirements.
- Any requests relating to data subject’s rights should be referred to the Responsible Person, whose details are below at paragraph 15.
6. Lawful Purposes of Processing Personal Data
- All data processed by AJCT must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests or legitimate interests.
- We may process your personal data to comply with a legal obligation. This may include subject access requests of others, tax legislation, Charity Commission requirements, for the prevention and detection of crime, and in order to assist the police and other competent authorities with investigations (including criminal investigations). In this respect, we may provide your personal data to our professional advisers, where this is necessary for us to obtain their advice or assistance.
- We may process your personal data for our legitimate interests. AJCT has identified the following as being our legistimate interests: the assessment of fund applications in order to make decisions on applications, the administration of AJCT, debt recovery, processing accounts and recruitment.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. The individual will have a right to withdraw their consent as easily as they give consent. If you have given your consent and you wish to withdraw it, please contact us using the contact details below. Please note that where our processing of your personal data does not rely on your consent, we may not be able to fulfil your request.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent is available.
7. Special Personal Data
In the event that AJCT needs to obtain special personal data from you, other than as required by law, we will always tell you why, how the information will be used and obtain your consent to this, which can be withdrawn at any time.
8. Website Usage and Cookies
9. Disclosing Personal Data
- We may disclose your personal data to any of our trustees, volunteers, officers, insurers, professional advisors, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in the policy, or otherwise as required by law.
- We will only disclose your special personal data with your explicit consent, other than as required by law.
- Before you disclose to AJCT the personal data of another person, you are responsible for ensuring that you have the authority for such a disclosure. AJCT cannot take any responsibility for such a disclosure.
10. How We Protect Your Personal Information
- We use technological and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
- All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your personal information. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted via our website – any transmission is at your own risk.
11. Archiving, Destruction and Retention
- AJCT will ensure that personal data is kept for no longer than necessary.
- Records, data and information will be retained in accordance with legal requirements and best practice. AJCT may retain your personal data for as long as is necessary to deliver our charitable services to you or the organisation you represent, and to protect our legal interests (for example where required by relevant authorities, or for a reasonable legal limitation period after we have ceased providing grant funding to the organisation you represent/represented) or as otherwise stated to you when your data is collected, or for such period as we consider appropriate in connection with our relationship with you and/or the organisation you represent/represented.
- When personal data is deleted this will be undertaken securely, such that the data is irrecoverable.
- AJCT shall ensure that personal data is stored securely.
- Access to personal data shall be limited to personnel who need access. Where required, appropriate back-up and disaster recovery solutions shall be in place.
- In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, AJCT shall promptly assess the risk to people’s rights and freedoms.
- If appropriate report this breach to the ICO, and, where appropriate, to the individuals concerned.
14. Transfers of Personal Data to Third Countries
If AJCT needs to transfer personal data for processing to Third Countries (which is to say a country which is outside the EEA) it will only do so in accordance with legislative requirements.
15. Contact Details, Queries and Complaints
- We will always endeavour to resolve your matter to your satisfaction.
- You also have the right to refer any complaints to the Information Commissioner’s Office in the UK, and, where appropriate, to equivalent supervisory authorities in the European Union.