Data Protection Policy        
Last updated Jan 2024

Charity
The Simon Trust (Autism) CIO

What is the General Data Protection Regulation (GDPR)?
A new law came into force in 2018 affecting all industry sectors, which addresses what we can and cannot do with personal data. ‘Personal data’ is information that identifies individuals directly or from which individuals can be identified indirectly. We are the ‘data controller’ in relation to your personal data that we hold, because we control the storage and use of that personal data.

One of the requirements of GDPR is that we provide you with details about how we process your personal data. ‘Processing’ includes obtaining, recording or storing personal data and carrying out any tasks using the personal data. This notice also describes your data protection rights, including a right to object to the processing which we carry out.

For what purposes do you process my personal data?
Everyone on our database has helped or will be making Linden Farm actually happen! Either by kindly donating to The Simon Trust, generally supporting the Charity or running marathons, doing quiz nights etc. We really want to keep you up to date with build progress and what is happening, as Linden Farm becomes a reality.
 
Below are several of our data guidelines:
  • We only store a/ your name, b/ your email address, c/ the date you became known to the charity and d/ your connection to the charity - volunteer, fund raiser, parent etc. Nothing else.
  • We will promise to store your data as securely as we can and we will never pass it on to a third party.  We do however use Mailchimp to send out our (infrequent)  Newsletters.
  • We promise not to bombard your inboxes with anything other than our quarterly (or as relevant) newsletters from The Simon Trust.
  • In our newsletters we will share with you our achievements and any future plans.  
  • To lose you at any stage would be a huge loss to us as you have been really supportive in the past. 

Can I withdraw my consent?
Yes of course and please send us a brief message using the email address below.  However, we feel this is such a worthwhile project that we hope that you will stay involved for the long term as either an interested bystander or actively involved.

Data officer
Peter Lawrence, Trustee, will oversee The Simon Trust data.

1.. Data protection principles
The Simon Trust is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. 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;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. 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
  6. 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
  1. This policy applies to all personal data processed by the Charity.
  2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
4. Lawful purposes
  1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. The Charity shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems. 
5. Data minimisation
  1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed – newsletters only on a quarterly (or as necessary) basis.
  1. The Charity only stores a) name, b) email address, c) the date known to the charity and d) connection to the charity - volunteer, fund-raiser, parent etc. Nothing else.
6. Accuracy
  1. The Charity shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date. 
7. Archiving / removal
  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.
8. Security
  1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.
9. Breach
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, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
 
We thank you very much for all your support for The Simon Trust and we hope that we can continue sending you our newsletters.  If you have any questions or concerns on any of these matters, then please contact us on the email address below.  Your support and generosity is much appreciated! 

The Simon Trust (Autism) CIO                           
Registered charity number 1163069     

www.thesimontrust.org

Gairholm, Littleworth Road, The Sands,  Farnham, Surrey   GU10 1JW
Email: [email protected]
Tel.: 01252 783704