Privacy & GDPR Notice

This Privacy & GDPR Notice governs the manner in which The Sir Thomas White Loan Charity collects, uses, maintains, disposes and discloses data collected from our prospective applicants, applicants, current and former borrowers and other individuals (each, a “User”) of The Sir Thomas White Loan Charity. Users of our website www.stwcharity.co.uk should refer to our specific Website Privacy Policy.

Introduction

The Sir Thomas White Loan Charity (“STW”, “we”, “our” or “us”) and its employees take the privacy of our Users very seriously. All data processed by STW is done so in accordance with the Data Protection Act 1998 and the General Data Protection Regulations (GDPR).

The purpose of this Notice is to inform you of the following:

• Our privacy promise
• Data we collect
• How we collect your data
• How we may use or disclose your data
• How we store your data
• Rights of data subjects
• Contacting us

Our privacy promise

We promise:

• To keep your data safe
• Not to sell your data
• Where you have consented to receive our marketing materials, including our quarterly newsletter, to provide you with ability to manage and review your subscription at any time

Data we collect

In the course of STW business, primarily the provision of loans, we collect personal and sensitive personal data including:

• Personal data – such as name and title, gender, date of birth
• Sensitive personal data – such as ethnicity
• Contact data – such as postal address, email address, telephone and mobile numbers
• Identification data and copy documentation – such as passport, driving license, proof of qualifications, proof of academic registration, proof of address, National Insurance Number
• Biographical data – such as academic and other results, institutions attended, employment history
• Financial data – such as bank account details and credit check information
• Transaction data – such as details on payments to and from you
• Profile data – such as feedback and survey responses
• Marketing data – such as your preferences in receiving marketing and other communications
• Any other data you may provide

Data may be collected from you at different times during your interaction and engagement with us and not all data will be collected or held on every individual who interacts and engages with us.

How we collect your data

We obtain personal data from a variety of sources, as follows:

• Directly from you when you interact with us, for example when you
– Request an application pack
– Submit an application
– Complete an equal opportunities form
– Are granted a loan
– Provide verification as part of the bond signing process
– Provide us with a completed annual contact us form (Revision of Records form)
– Sign up (opt in) to our mailing list
– Write to us, including by email
– Take part in a survey or provide us with feedback
– Provide information for a case study, as an Ambassador or other marketing purpose
– Apply for a job or send us your CV

• From an applicant, borrower or third party, for example
– When an applicant submits personal details for prospective guarantors
– When a borrower provides, confirms or updates personal details for guarantors
– When conducting an anti-money laundering and credit check on an applicant or prospective guarantor
– When a third party such as a charity, school or college provides personal details for the purposes of obtaining a grant or scholarship for an individual

• From automated technologies, such as cookies when you use our website – for more information on this please see our Website Privacy Policy

How we may use or disclose your data

We may use your personal data for a number of reasons, depending on the reasons for submitting to us / for us collecting the data. To process your personal data, we must have a lawful basis and these are listed below.

• Legitimate interests – we process your personal data for our legitimate interests and these include the following
– to conduct and manage our business, primarily but not limited to the provision of loans and grants
– to analyse, improve and update our processes and services for the benefit of our applicants, borrowers and grant recipients
– to deal with and respond to complaints

• Consent – we process your personal data where you have given us specific consent to do so, for example where you have opted in to receive our quarterly newsletter.

• Contract – we may process your personal data where there is an contractual obligation

• Legal obligation – we may process your personal data in order to comply with applicable laws

Please note, more than one lawful basis may apply at any given time. We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason compatible with the original purpose.

Most commonly we will use your personal data in the following circumstances:

• Prospective Applicants – to provide you with an application pack, to respond to any queries you may have and to follow up on your pack request in the event you do not apply
• Applicants and guarantors – to process the application including credit and anti-money laundering checks
• Applicants submitting an equal opportunities form – to provide aggregated data to the trustees to ensure we are compliant with our equal opportunities policy
• Borrowers – to process your loan, including payments, missed payments and confirmation of bank details and for ongoing purposes including visits, changes to guarantors, submission of annual contact us form (Revision of Records) and Ambassador duties
• Guarantors – to contact you to ensure your details are up to date and in the event of a loan being recalled or payments being missed by the borrower
• If it is necessary for our legitimate interests and these are not overridden by your own rights or interests
• To send you our quarterly newsletter, where you have given us consent to
• Where we need to comply with a legal, regulatory or contractual obligation

We may disclose and share your personal data to the following recipients for the purposes set out in this notice:

• e-mail and mail service providers
• our Trustees, employees and contractors
• technical and support partners, such as the companies who manage our marketing activity, host our website, provide financial, technical and / or back-up services
• government, public or law enforcement agencies or officials, regulators or any other person or entity who has the appropriate legal authority
• any other parties where we have your specific consent to do so

How we store your data

We take the security of your data seriously. Only authorised STW employees, trustees and third parties processing data on our behalf have access to your personal data. We take all reasonable steps to keep your data secure. This includes storing data in locked filing cabinets, in a securely locked and alarm protected office and ensuring computer access is controlled through the use of individual computer logins, where passwords are regularly changed.

We consider the personal data we store and we will not store your information in a form which identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. All businesses must keep personnel and financial records in order to run their business efficiently and to comply with statutory requirements. As such, how long we store your data for will depend on the nature of the data, your relationship with us and whether we have statutory or lawful requirements to continue to store the data.

Rights of data subjects

As a data subject you have a number of rights. These include the following:

• Right to be informed
• Right of access
• Right to rectification of errors in personal data
• Right of erasure
• Right to restrict or object to processing
• Right to data portability

For more information about your rights please visit the Information Commissioner’s Office (ICO) website at https://ico.org.uk.

Contacting us

If you have any questions about this Privacy & GDPR Notice please contact us at:

The Sir Thomas White Loan Charity, Unit 5, Friars Mill, Bath Lane, Leicester, LE3 5BJ
Tel: 0116 204 6620, Reg. Charity Number: 218061

Document Reference: POL02

This document was last updated on 25 May 2018.