Privacy policy
EF Bulmer Trust is committed to protecting your personal information. This privacy policy explains how we collect and use data about you, whether your data will be shared with anyone else, and the ways you can control how your data will be used in the future.
We do this not just because we are legally required to do so in line with data protection regulations but because we believe it is the right thing to do.
Who we are
EF Bulmer Trust is registered as a charity in England and Wales (registered charity number 1188978. Within the context of this notice, ‘we’ means the EF Bulmer Trust.
Under data protection regulations, we are required to appoint a Data Protection Officer who ensures your information is always handled securely, in accordance with the law.
Should you wish to contact us about the way we use your information, you can contact our Data Protection Officer by telephone on 01432271293 by email at efbulmer@gmail.com, or by post at: The Fred Bulmer Centre, Wall Street, Hereford, HR4 9HP.
What information do we collect and how do we use it?
Personal information is any information that can be used to identify you, such as a name, address, telephone number, email address, or more rarely - bank account details, and even electronic identifiers such as your internet protocol (IP) address. The amount of information we collect and use about you will vary depending on your relationship to us. We always make sure there is a legal basis in data protection law before we start collecting and using your information. The main legal bases we rely on are:
Consent Where you have given us clear and informed permission
Contractual Where there is a contract between you and us
Legal obligation Where a law says we have to
Legitimate interests Where it is necessary for our charitable aims and the benefits have been carefully balanced against respect for your privacy, your information rights, and your expectations
To keep your information up to date, we may from time to time use publicly available sources. For example, the Royal Mail’s National Change of Address Update if we get a piece of mail returned to us marked as gone away/not at this address.
To help build a snapshot of the type of people we support currently or may work with us in the future and to help us with our planning, we may profile you or your company based on publicly available data, such as your demographics or your geographical location and. If you do not wish to be included in this, you can opt out at any time by contacting us at efbulmer@gmail.com.
We collect your information on the basis of legitimate interests. Using this information enables us to build a lasting relationship with you and the community at large and make financial forecasts. You have the right to object to us collecting this information or restricting the way we use it.
If you choose to work with us by getting involved in publicity work, we collect your photographs and case studies on the basis of consent. Using this information helps us communicate our charitable aims to the public and build support and awareness. You can withdraw your consent for your photographs or case studies to be used at any time by contacting us. We will not use a photograph or case study for longer than two years without renewing your consent.
We like to keep our supporters updated with news about the charity. If you would rather not receive information from us, you can let us know at any time, by contacting us directly at efbulmer@gmail.com.
Staff
If you work for us, we collect information during your recruitment and ongoing work. This may include your contact details and those of your next-of-kin, bank details (for paying salaries or out-of-pocket expenses), personnel references and background checks, sickness and occupational health records, pension information and disciplinary records. This information is mainly provided directly by you but may be obtained from your manager or a past employer. We only share your work information when it is necessary for the fulfilment of your employment contract and to provide the benefits and support promised to you as a worker. For example, your bank details will be shared with our payroll provider, so your salary is always accurate and arrives on time. To comply with pension automatic enrolment legislation, we will supply our pension provider NEST with information on all employees for them to make an assessment of pension eligibility.
We collect work information about paid staff based on contractual obligation. Using this information enables us to comply with employment law and act as a responsible and supportive employer. In most cases you do not have the right to object to us collecting your work information, or restricting how we use it, because to do so would cause a breach of the employment contract between you and us. However, in the rare cases where you do have this right, we will inform you and give you the choice.
During recruitment, you may be asked to provide sensitive personal details, such as your ethnicity, religious belief, and sexual orientation. This information is collected solely for the purpose of equality monitoring, helping us ensure we have an inclusive and diverse workforce. Only authorised staff may access this type of information, and whenever it is used, we make sure it is kept anonymous. You are under no obligation to provide this information, and if you choose not to do so your application will not be affected.
Information about business associates
If you are a company/charity who has a business relationship with us, we collect administrative information about your representatives, plus your payment details and history. This may include contact information, communication history and bank details. This information is always provided by you directly. We do not share your information with anyone externally, except our external financial auditors who may need to look at payment histories to carry out their regulatory audit. We will also share email exchanges between you and us with our auditors if requested.
We collect your information based on purchase agreements, which are a type of contract. Using this information ensures the goods and services we are buying from you are delivered in the agreed way and paid as required. You do not have the right to object to us collecting this information, or restricting how it is used, because you have already agreed to us having and using it as part of the purchase agreement.
Information about website visitors
We love cookies. And we think that you should too. Cookies are pieces of code that help us provide a better experience to you on our website. Cookies allow us to improve our website.
There are four broad types of cookies, these include:
Necessary – Necessary cookies help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. These are set automatically. They contain no information about you as an individual.
Statistics – Statistics cookies are used to track visitors on our website. They allow for reports to be generated on user behaviour, on what pages are accessed, interaction with the site and session duration, as well as general demographic data that is not personally identifiable. These are only set if you choose to ‘accept’ cookies to be set on your device.
Marketing – Marketing cookies are used to track visitors across different websites. To measure the effectiveness of our advertising. And, to display ads that are more relevant and engaging for you as a user on third party websites. These are only set if you choose to ‘accept’ cookies to be set on your device.
Preferences – Preference cookies help store a user’s preferences after leaving a website. This is to help provide a better experience when they return, such as their language preferences. These are only set if you choose to ‘accept’ cookies to be set on your device.You can learn more about cookies by visiting www.allaboutcookies.org.
When you visit our website for the first time, we will ask your permission to collect basic information about your visit through cookies. You have the choice to set your preferences, either to ‘accept’ the use of cookies or to ‘decline’ them. If you choose not to accept cookies on our website, no cookies will be set on your device, except for strictly ‘necessary’ session cookies that are required for the functioning of our website. If you choose to accept cookies, your internet browser will start setting cookies automatically as you travel around our website. The information we collect through cookies will include: details about how often you visit our website; where you came from before visiting the website; which pages you looked at during your visit; plus any details the website needs to remember about you individually, such as when you tell the website to remember your login details, or when you tell a notification to stop appearing.
As well as our own website cookies, we also use Google Analytics to allow us to track how popular our website is and record visitor trends over time. We analyse this data to help us improve the way that our website works and provide you with a better experience. Google Analytics uses a cookie to help track which pages are accessed. This information will only be shared with Google if you choose to accept cookies on our website. Find out more about Google Analytics.
Some of the pages on our website may have embedded features from third-party services, such as Facebook or YouTube. These services may collect their own cookies. For information about how these other third parties use their cookies, and how you can disable them if you wish, please refer to their own Privacy Notices, available on their websites.
We collect information from your cookies based on consent. You can withdraw your consent at any time by updating your cookie preferences on our website. Your cookies will only last 30 days from the date you last visited our website, so we may need to ask for your consent again if you visit after this timeframe.
Keeping your information secure
We take the security of your personal information very seriously. All staff who handle personal information are required to complete training on information security once per year at a minimum. We also carry out regular audits and inspections to make sure our security controls are effective and reliable. Within the organisation, access to information is controlled, so that no one can use personal information unless they have a business reason to do so. If information needs to be taken outside our premises, we take extra precautions to keep it as safe as we can. When information is no longer required, it is archived or securely destroyed in accordance with the law.
Sharing your information
Where we have indicated information may be shared, we always ensure the people receiving your information uphold the same information security standards as we do. This will often be specified in writing as part of a contract or information sharing agreement. All staff, volunteers and agents of EF Bulmer Trust are bound by strict duties of confidentiality.
We affirm here that your information will never be swapped, shared with, or sold to any third parties for the purpose of marketing or monetisation.
Keeping your information
We only keep your information as long as is necessary for the purpose it was collected for. Depending on the details, your information could be used and securely disposed of very quickly, or it could be necessary for us to keep your information for many years to comply with archiving or insurance requirements. As a general guideline:
Financial information about grant applicants will be kept for seven years from the date of last entry into the record
Publicity photographs and case studies will be kept for two years from the date permission was granted to use them by the subjects
Employment information about staff and volunteers will be kept for six years from the date employment or volunteering ceases.
A third party may be involved in the storage or destruction of your records. For example, we may use a company to digitise paper records so they can be retained more securely and easily, or we may use a company to bring shredding equipment to the Fred Bulmer Centre for secure disposal of paper records in bulk. Whenever we use a third party, the companies are vetted and are bound by contracts containing strict confidentiality and data protection requirements.
However long we need to keep information, we ensure that only the minimum amount of data required will be kept.
Your individual rights
Under data protection regulations, you have rights over how your personal information is used by others.
Right to access: You have the right to access the personal information we hold about you. If you wish to see it, you can submit a request to our Data Protection Officer who will respond within one month. Depending on the nature of your request, we may need to seek further clarification from you or gain confirmation of your identity before the information can be provided.
Right to rectification: If the information we hold about you contains errors; you have the right for it to be corrected. We have measures in place to keep our information updated, but if you notice anything wrong with the information we are using, please let us know and we will update it as soon as we can.
Right to erasure: You have the right to request we erase the information we hold about you from our records if you think it is no longer required. Where possible, we will always comply with a request for erasure, however in many cases it will not be possible to erase all information about you, because there may be legal or contractual reasons why we need to keep certain details. If any of your details cannot be erased, we will tell you and explain the reasons.
Right to restriction: If you think your personal information is being used for things it should not be, you have the right to request we stop using it that way. As with erasure, there may be legal or contractual obligations why we need to continue using information in particular ways.
Right to portability: There may be times when you want a particular portion of the information we hold about you to be moved or made portable. For example, if you are an employee, you might want us to give you a list of all the training courses you have attended, to put on your CV perhaps. You have a right to receive information you have provided to us in a structured, commonly used and machine-readable format. This right only applies when the information has been collected and used on the basis of consent or a contract.
Right to objection: You have the right to object to us collecting and using your information when it is being done on the basis of legitimate interests or research. We will inform you at the point we start collecting your information if this right applies. Any objections will be considered and complied with unless there is a lawful exemption.
We will always endeavour to inform you about your rights and uphold them . If you believe we have infringed your rights, we encourage you to contact our Data Protection Officer who will work with you to resolve the matter in a way that satisfies both you and the law. If for any reason you are unable to resolve the matter with us, you can escalate your concerns to the Information Commissioner’s Office, who is the UK’s independent authority responsible for upholding information rights in the public interest.
Information may be required by the organiser of the scheme in relation to hours and tasks carried out and risk assessment processes. We do not employ anyone under the age of 16.
Changes to this notice
From time to time, we may need to change this notice in response to different ways of working, or new regulations. The version number and revision date at the bottom of this notice will tell you when it was last reviewed. As a matter of course, we will review the notice no less than once per year.
We will notify you if there are any substantial changes to this notice that could affect your information rights.
For any enquiries about this privacy notice or our treatment of your personal data, please contact: Data Protection Officer
Email: efbulmer@gmail.com
Telephone: 01432271293
Post: E F Bulmer Benevolent Fund, Fred Bulmer Centre, Wall Street, Hereford, HR4 9HP