Privacy Policy

Introduction

Welcome to the Sir Thomas White Loan Charity’s privacy policy. The Sir Thomas White Loan Charity respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you get in touch with us, visit our premises, visit our website or when we get in touch with you – https://www.stwcharity.co.uk – (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through our contact with you, your visit to our premises and your use of this website, including any data you may provide to us in person, by email, by phone or through our website.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Sir Thomas White Loan Charity is the controller and responsible for your personal data (collectively referred to as “STW”, “we”, “us” or “our” in this privacy policy). If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Clerk to Trustees Sarah Hope in the following ways:

Full name of legal entity: The Sir Thomas White Loan Charity, Reg. Charity Number: 218061
Email address: sarah.hope@stwcharity.co.uk
Postal address: Unit 5, Friars Mill, Bath Lane, Leicester LE3 5BJ
Telephone number: 0116 204 6620

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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. 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 will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• When you contact us:

Call us: we may collect your title, first name, last name, email address, telephone number or any other relevant information you disclose to us when you contact us. We will use this information to discuss your enquiry. The purpose for processing this information is to deal with and respond to your message. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (to communicate with you).

Emailing us: we may collect your title, first name, last name, email address, telephone number or any other relevant information you disclose to use when you contact us. We will use this information to respond to your message. Emails are monitored for malicious content and we take every reasonable precaution to ensure that any attachment sent by us is virus free. However, we cannot accept liability for any damage sustained as a result of software viruses and would advise that you carry out your own virus checks before opening any attachment from us. The purpose for processing this information is to deal with and respond to your message. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (to communicate with you).

Fill in our contact us form on our website: when you contact us through any of our website contact forms you may give us your title, first name, last name, address, email address, telephone number and any other personal information you include in your message. We will use this information to contact you in relation to your message. The purpose for processing this information is to deal with and respond to your message. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (to communicate with you).

Sign up for our electronic newsletter: when you sign up for our electronic newsletter you may give us your first name, last name, company name, email address, telephone number, address and any other personal information you include in the sign up form. We will use this information to send you our electronic newsletter. The purpose for processing this information is to send you our newsletter. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (to communicate with you).

• Social Media: we may collect your first name, last name, email address, telephone number, username or any other relevant information you disclose to use when you connect with us on any of our social media channels (LinkedIn, Twitter, Facebook, Instagram). Data may also be collected by the applicable social media platform and will be subject to the terms of use for the respective platform. We may use this information to communicate with you via social media including via direct message, and also to publicly respond to any public comments you post on any of our social media channels. The purpose for processing this information is to send you our newsletter. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (to communicate with you).

• When you enquire about making a loan, grant or scholarship application: We may collect your first name, last name, title, address, email address, and telephone number. We will use this information to provide you with an application pack, respond to any queries you may have and to follow up on your enquiry in the event you do not apply for a loan, grant or scholarship. The purpose for processing this information is to deal with and respond to your request for information about applying for a loan, grant or scholarship. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests.

• When you apply for a loan, grant or scholarship from us: We may collect your first names, last name, title, date of birth, address, email address, telephone number and relevant bank account details. We will use this information to register you as an applicant and it will be considered as part of your loan application. We may also use this information to conduct anti-money laundering, credit checks and/or other relevant searches with search information providers. If you have completed an optional equal opportunities form, we will also collect your gender, ethnic origin, nationality, marital status and disability status – this is separated from your application and is not taken into account when considering your application. The purpose for processing this information is to deal with and respond to your application. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests.

• When someone applies for a loan with you as their guarantor: We will collect your first name, last name, title, date of birth, address, email address, telephone number, home ownership status, relationship to applicant, job title and description, employer details, level of salary or pension, level of assets, and details of any professional memberships you hold. We will use this information to register you as a guarantor and it will be considered as part of the applicant’s loan application. We may also use this information to conduct anti-money laundering, credit checks and/or other relevant searches with search information providers. The purpose for processing this information is to deal with and respond to the applicant’s loan application. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests.

• When we offer/award you a loan, grant or scholarship: When you are successful in your loan, grant or scholarship application and take out a loan, grant or scholarship with us we will collect your first names, last name, title, date of birth, address, email address, telephone number and (for loans and grants) bank details. We will use this information to process your loan, grant or scholarship and associated payments. The purpose for processing this information is to process your loan, grant or scholarship. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests.

• Visiting our premises (site): When you visit our site you may give us your name, title, address, email address and telephone number. We ask all visitors to sign in and out at reception and, depending on the nature of the visit, may ask you to show a form of ID, which we may or may not record. The purpose for processing this information is for security and safety reasons. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests. We may use this information to make available your basic contact details to third parties as required for the purposes of contact tracing under the NHS Test and Trace service or similar system in relation to Covid-19 (or any other pandemic).

• Our website

Analytics: We may collect non-personal information about you when you use our website. This information may include the browser name, the type of computer and technical information about your means of connecting to our site, such as the operating system and the internet service providers used. We may share this information with Google (California), as Google Analytics will track the data as per the above statement. The purpose for processing this information is to use data analytics to improve our website, services, marketing, relationships and experiences. The lawful basis we rely on is that it is necessary for our legitimate interests (to define types of applicants for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Cookies: As you interact with our website, we will automatically collect data about your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note some parts of the website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Security and performance: We may collect first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, address, email address and telephone numbers, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website to enable us to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). The purpose for processing this information is security and safety reasons. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and because it is necessary to comply with a legal obligation.

• Marketing communications

If you consent to receiving our marking communications, we may collect first name, last name, username or similar identifier, title, postal address, organisation, email address, telephone numbers, link to our organisation, reason for subscription, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and use this information to make suggestions and recommendations to you about goods or services that may be of interest to you. The purpose for processing this information to make suggestions and recommendations to you about goods or services that may be of interest to you. The lawful basis we rely on is that it is necessary for our legitimate interests (to study how you use our services, to develop them, to grow STW and to inform our marketing strategy).

Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. For third party marketing we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out: You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at info@stwcharity.co.uk. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a loan, grant or scholarship application or a loan, grant or scholarship offer or award.

Aggregate Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

Special Categories of Personal Data

We do not collect any other Special Categories of Personal Data about you other than set out in this policy (see When you apply for a loan, grant or scholarship from us). Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel an application you have with us but we will notify you if this is the case at the time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out above in relation to the relevant activity.

· External Third Parties:
– Technical and support partners, such as the companies who manage our marketing activity, host our website, provide financial, technical and / or back-up services.
– Service providers acting as processors based in the UK who provide IT and system administration services.
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
– Credit reference agencies to conduct a credit check and anti-money laundering check against you if you are a loan applicant or a guarantor for a loan applicant.
– Guarantors for the purposes of confirming their position in relation to the loan application.
– Charities, schools, colleges, or other such providers for the purposes of them obtaining a grant or scholarship on your behalf.

· Third parties to whom we may choose to sell, transfer or merge parts of the charity or our assets. Alternatively, we may seek to acquire other charities or merge with them. If a change happens to STW, then the new trustees may use your personal data in the same way as set out in this privacy policy.

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

4. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK) unless otherwise set out in this policy. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK, namely Google (California). Please contact us if you want further information on the specific mechanism used by us when your personal data is transferred out of the UK.

5. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, trustees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. DATA RETENTION

How long will you use my personal data for?
We will only retain your personal data 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 data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

· Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of your personal data 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 data. This enables you to ask us to delete or remove personal data 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 data 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 data 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 data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
– You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data 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.

Time limit to respond

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.

8. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of STW in conducting and managing the charity to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Document reference POL02
This document was last updated on 30 September 2021