THE LIHOU CHARITABLE TRUST
1. About this Policy
1.1 This policy explains when and why we collect personal information about our customers, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Office of the Data Protection Authority in Guernsey (www.odpa.gg). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
2. Who are we?
2.1 We are the Lihou Charitable Trust (‘Trust’). We can be contacted at The Warden, The Lihou Charitable Trust, Entre Nous, Bailiffs Cross Road, St Andrews, Guernsey GY6 8RZ / Email – email@example.com / Tel – 07781 120421.
3. What information we collect and why.
Type of information, purpose and legal basis of processing
- Customer’s name, address, telephone numbers, e-mail address(es) for managing the customer’s booking with the Trust and Performing the Trust’s contract with the customer for the purposes of our legitimate interests in operating the Trust.
- Bank account details of the customer or other person making payment to the Trust where a refund payment is due to them by the Trust to manage the customer’s provision of services and events to enable the Trust in performing the Trust’s contract with the Customer.
- Name, e-mail address and telephone number of each employee of the Trust to enable Information to be published on Trust’s website, in Trust’s newsletter and other publications and in the Trust’s marketing materials for the purposes of our legitimate interests in operating and promoting the Trust.
- Employees and representatives of suppliers to the Trust to enable the Trust to enter into and manage arrangements with suppliers so the Trust can Enter into and performe contracts with suppliers.
4. How we protect your personal data
4.1 We will not transfer your personal data outside the EU without your consent.
4.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
4.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
4.4 For any payments which we take from you online we will use a recognised online secure payment system.
4.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5. Who else has access to the information you provide us?
5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs 5.2 and 5.3 below.
5.2 We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). We do this for the purpose of our legitimate interests in operating the Trust and for performing our contract with you. However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub- processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
6. How long do we keep your information?
6.1 We will hold your personal data on our systems for as long as you are a customer of the Trust and for as long afterwards as it is in the Trust’s legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
6.2 We securely destroy all financial information once we have used it and no longer need it.
7. Your rights
7.1 You have rights under the GDPR:
(a) to access your personal data.
(b) to be provided with information about how your personal data is processed.
(c) to have your personal data corrected.
(d) to have your personal data erased in certain circumstances.
(e) to object to or restrict how your personal data is processed.
(f) to have your personal data transferred to yourself or to another business in certain circumstances.
7.2 You have the right to take any complaints about how we process your personal data to the Data Protection Commissioner, The Office of the Data Protection Authority, St Martin’s House, Le Bordage, St Peter Port, Guernsey GY1 1BR / Email – firstname.lastname@example.org / Tel – 01481 742074.
For more details, please address any questions, comments and requests regarding our data processing practices to The Warden, The Lihou Charitable Trust, Entre Nous, Bailiffs Cross Road, St Andrews, Guernsey GY6 8RZ / Email – email@example.com / Tel – 07781 120421.
This document was updated on the 1st of June 2019