• personal information we collect AND PROCESS

“Personal data” or “personal information” means any information about an individual from which that person can be identified. An identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

We collect, use, and store various types of personal information about you for the purposes set out in this policy below:

• Personal and Contact Details includes your name, email address, telephone or mobile numbers, and address.
• Account Access Data (where you create an account for making a grant application) includes your password (as well as name and email address).
• Grant Application Data (where you apply for a grant) includes any other personal information in any supporting information / documentation which you chose to share with us as part of your grant application (whether verbally or in written form (e.g. via our online application process or in any subsequent emails)) or we process about you during our relationship with you.  
• Cookie Data – please refer to the “Cookies” sub-section in How We Use Personal Data and Our Lawful Basis for Processing it [TL2] for further details.
• Trustee Data (where you act as a Trustee)includes Personal Details and Contact Data and any other personal information about you that we process during our relationship with you, to carry BNA’s purposes and to comply with charity law requirements and other laws that apply to BNA.
• Apart from personal information relating to you, if you provide us with the personal information of any third parties as part of your grant application, before you provide such third party personal information to us, you must first inform these third parties of any such data which you intend to provide to us and of the processing that we will carry out, as detailed in this policy.

There are certain types of more sensitive personal information (often referred to as “special category personal data”), such as information about a person’s health (whether physical or mental), sexual orientation, genetic / biometric data.  Grant applicants should not provide any sensitive personal information in their grant applications. At the time you complete our online grant application form, we underline that no sensitive personal information should be provided as part of your application because we do not consider that any sensitive data is required for a grant application.  If any sensitive personal information is provided as part of any grant application, your grant application will be invalid, any sensitive personal information will be deleted and you will be asked to re-submit your grant application without sensitive personal information.

• How is personal information collected?

We use different methods to collect personal information from and about you including through:

• Your interactions with us
• Where you make a grant application with us, you give us your personal information by filling in the online account opening form and/or by subsequently corresponding with us (as applicable) by post, phone, email or otherwise.
• Where you act as a Trustee, we will need certain personal information about you to: (i) comply with our legal obligations and the requirements of the Charity Commission; and (ii) to keep in regular contact during Trustee-related activities, by corresponding with us by post, phone, email or otherwise.
• Where you provide goods and/or services to us, you provide us with personal information and contact details so that we can manage our contract with you and you can provide your goods and/or services to us.
• As you interact with our website, we will automatically collect Cookie Data, however, we do not collect any personal information via the cookies we use. Please see the “Cookies” sub-section in How We Use Personal information and Our Lawful Basis for Processing it [TL3] for further details.
• How we use personal information AND OUR LAWFUL BASIS FOR PROCESSING IT

The law requires us to have a valid lawful basis for collecting and processing your personal information. We rely on one or more of the following legal bases:

• Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to, for example, the Charities Act 2011.
• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal information where it is necessary to conduct our grant making purposes and pursue our legitimate interests, for example, to provide a secure online grant application process. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
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• There may be exceptional circumstances where we rely on consent. If we rely on consent, we will make it clear at the time and ensure that we have obtained your active agreement to use your personal information for the specified purpose.

We have set out below, in a table format, a description of the ways we plan to use the various categories of your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where applicable).

Cookies

A cookie is a small data file that is placed on your smart phone, tablet, laptop or other device when you use websites. We only use essential cookies on our website, which are required for the operation of our website. Essential cookies are deployed automatically for all users as soon as they enter our website because our website won’t work without them and are legally exempt from the requirement to gain users’ consent. The essential cookies we use include: fp_logged_in_roles: Value “Subscriber” and IsRetuningVisitor: Value “True”, to allocate the role of “Subscriber” and provide access to the user on login.

• Disclosures of your personal information

Within BNA, your personal information can be accessed by or may be disclosed internally on a need-to-know basis where necessary for the management and administration of BNA as a charity, for example, to ensure we are carrying out our purpose(s) for the public benefit, and complying with our governing documents, applicable laws and the regulatory requirements of the Charity Commission.

Your personal information may also be accessed by third parties who provide us with services, such as hosting, supporting and maintaining our IT systems and website.  Examples of third parties with whom your personal information will be shared include IT service providers, website developers, managed hosting providers, consultants and other professional advisors. 

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

• International transfers

We do not transfer your personal information outside the European Economic Area (EEA).

• Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

• Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we must keep certain information about grant applications and successful grant awards for specified periods in accordance with the laws applicable to charities.

• Your legal rights

Depending on the circumstances, you have several rights under data protection laws in relation to your personal information.

You have the right to:

• Request access to your personal information (commonly known as a “data subject access request” or “DSAR”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your information. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• (where applicable) Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• (where applicable) Withdraw consent at any time where we are relying on consent to process your personal information.  As you can see from the table in How we use personal information and our lawful basis for processing it above[T5] , we do not currently rely on consent to process personal information, however, if we did at any time in future, we will advise you if this is the case and advise you how you can withdraw your consent.
• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us by using the contact details set out below in Contact Details[TL6] .

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

1. Contact details

If you have any questions about this privacy policy, the use of your personal information or you want to exercise your privacy rights, please contact us at: privacy@bna-charity.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.