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Privacy Policy

What we store and what your Data means to us

INTRODUCTION

At the Association of Jersey Charities we are committed to protecting and respecting your privacy. This policy applies to all personal data collected by the Association of Jersey Charities under the Data Protection (Jersey) Law 2018. This privacy notice will inform you as to how we look after your personal data. 

When contacting and engaging with the Association of Jersey Charities you will be provided with a copy of this privacy policy and we will ask you to confirm you are in agreement before we will be able to process your requests further. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Any questions regarding this policy and our privacy practices should be sent by email to lyn@jerseycharities.org or by writing to Lyn Wilton, Administrator, The Association of Jersey Charities, PO Box 356, St Helier, Jersey. JE4 9YZ. Alternatively, you can telephone 01534 840138. 

You have the right to make a complaint at any time to the Office of the Information Commissioner (“OIC”) Telephone: +44 (0)1534 716530, Email: enquiries@dataci.org 
Address: Office of the Information Commissioner, 4th Floor, One Liberty Place, Liberty Wharf, La Route De La Liberation, St Helier, Jersey JE2 3NY, the Jersey supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance. 

WHO WE ARE

The Association of Jersey Charities is an incorporated association constituted under Loi (1862) sur les teneures en fidéicommis et l'incorporation d'associations. Since 2005 the Association has received the Jersey share of the Channel Islands Lottery profits from the States of Jersey, on a yearly basis, together with other ad hoc donations received from time to time, to distribute to its members to benefit (directly or indirectly) the residents of Jersey. The membership comprises established Jersey Charites and all members must provide a copy of their tax exemption confirmation letter, NPO (Jersey) Law 2008 registration number, constitution/trust deed (governing document), copy of latest set of accounts and a list of current governors plus, if a membership organisation, a list of current members. The list of members will be destroyed once the minimum requirement of 10 has been confirmed. However you will be required to confirm annually, on the Annual Return, that you continue to have an appropriate number of governors (with contact details) and members. The Association works closely with its members to encourage charitable and community work in Jersey and, in particular, to encourage co-ordination of activities to benefit members.
The Association of Jersey Charities is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our”  “the Association” in this privacy notice).

WHAT DATA WE COLLECT

If you are accessing services we require information from you that may include your personal contact details, the nature of your query and information that you choose to disclose which is relevant to us providing you with access to our services and the fulfilment of our duties. 

As a contact for a Member charity, or if you otherwise sign up to receive any communications or information from us, which is either opt in or opt out at any time for anyone who is a member or who is not a member. The personal information we collect will include your name, address, email address, telephone number, your link to the Member charity (for example, governor/member) as well as information relating to the request for a grant or services, or your donation if applicable. 

Identity Data includes first name, maiden name, last name, username or similar identifier, title. 

Contact Data includes delivery address, email address and telephone numbers.

WHERE AND WHEN WE COLLECT YOUR DATA

We use different methods to collect data from and about you including through: 
Direct interactions. You may give us your Identity, contact and/or financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
• apply for membership, a grant or services by email, post or telephone; 
• otherwise subscribe to or request our services or publications;  
• make a donation to us; or
• give us some feedback. 

FOR WHAT PURPOSES WE USE YOUR PERSONAL 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 when you have applied for our services. 
• where it is necessary for our legitimate interests (or those of a third party - for example to a trainer when you have applied for training) and your interests and fundamental rights do not override those interests; 
• where we need to comply with a legal or regulatory obligation; 
• process information requests that you have submitted; 
• assess an application made to Association of Jersey Charities; 
• carry out our obligations arising from you accessing our services and programmes; 
• deal with event invitations; 
• where you subscribe for training
• seek your views or comments on the services we provide; 
• administrate our services; 
• enhancing the value of support; 
• notify you of changes to our services; 
• send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other fundraising activities, promotions of our associated companies goods and services; process a grant or job application, but we will not share your data with any associated company without prior written/email agreement;
• inform you of educational and related purposes consequential to Association of Jersey Charities; 
• contact you in connection with maintenance or improvement of our governance; 
• to pass on to supporting agencies who will work with you in the future to ensure you receive the support you require – only with your prior written/email consent. 

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations.

If we hold contact details for you as a governor, manager/employee or member of a member charity, we are obliged by law to keep a record of our dealings with that member charity until the charity ceases to be a member of the Association of Jersey Charities, and for a period of time thereafter. Your personal data will be included in those records to the extent so required. 

If we assist you to find work, voluntary or paid, we will hold your CV for 6 months, together with an anonymous synopsis of your CV which will be displayed on our website, after which the CV and synopsis will be removed and destroyed. By prior written/email agreement from you, we will pass your CV to interested parties.

WHO HAS ACCESS TO YOUR INFORMATION?

If you are accessing Association of Jersey Charities services or enquiring about accessing services, your information is disclosed only to those third parties who require your details to fulfil our requirements to you with your prior consent unless there are safeguarding concerns for a child’s safety. 
The Association of Jersey Charities acts as the information controller and works with a processor (database management software) to securely store and manage your information. 
Please be reassured that we will not release your information without prior written/email agreement to third parties, unless you have requested us to do so, or we are required to do so by law. For example: a court order or for the purposes of prevention of fraud or other crime. 
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.

THE RIGHT TO BE FORGOTTEN

Under the Data Protection (Jersey) Law 2018 all individuals have the right to have their personal data erased. Individuals can make a request for erasure verbally or in writing and we will respond to this request within one month. The right is not absolute and our legal obligations supersede above the right to be forgotten.

HOW YOU CAN ACCESS AND UPDATE YOUR INFORMATION

It is important that 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. If any of the information we hold is inaccurate or out of date, please email us at: lyn@jerseycharities.org or by writing to us at PO Box 356, St Helier, Jersey, JE4 9YZ. Alternatively, you can telephone 01534 840138. 
You have the right to ask for a copy of the information the Association of Jersey Charities holds about you, to request this information please email lyn@jerseycharities.org. 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 may refuse to comply with your request in these circumstances.

SECURITY PRECAUTIONS AND BREACH POLICY

When you give us personal information, we take steps to ensure that it’s treated securely. 
In the event of personal data breaches, we will report directly to Information Commissioner of Jersey within 72 hours of becoming aware of the breach, where feasible. In the case of a high risk breach which affects our clients and donors, we will inform those individuals without undue delay.

LINKS TO OTHER WEBSITES 

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. 
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

13 OR UNDER

We aim to protect the privacy of children aged 13 or under. If you are aged 13 or under‚ we must obtain your parent/guardian’s permission before processing your personal information. 

LAWFUL BASIS

Legitimate interests
The processing is necessary for the purposes of legitimate interests pursued by the controller or by the third party or parties to whom the data are disclosed.

Where our processing is based on consent (e.g. for optional newsletter or sports and social activity), you may withdraw your consent by unsubscribing from the service or emailing us. In the case of Social Media you may unfriend, unlike, unfollow, or otherwise remove the connection.

HOW LONG WE HOLD YOUR DATA

We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected. 
As a guide, if we receive a CV from you when you are looking for work, paid or voluntary, details will be removed from our website and any paper copies destroyed after 6 months.
If we hold contact details for you as a governor, manager/employee or member of a member charity, we are obliged by law to keep a record of our dealings with that member charity until the charity ceases to be a member of the Association of Jersey Charities, and for a period of time thereafter. Your personal data will be included in those records to the extent so required. 

DATA SECURITY

We use up-to-date data storage and security techniques to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss.
The security measures we have in place include:
Full anti-virus and computer protection software.
Physical Security/Access Permissions - There are access controls to all data held which are appropriate to staff requirements. Paper documents are held under lock and key at the office premises.
Destruction process - All personal data is securely destroyed after it has reached the retention period required by law. Paper waste is shredded and sent to be burned. 


DATA SHARING AND DISCLOSURE

We do not share your data beyond what is agreed as necessary for the provision or operation of our services to you. Any third parties we engage to process your personal information are obliged to respect the confidentiality of your information. 

There are circumstances where we might share anonymised data (not identifying you) for research and analytical purposes.

There are legal and regulatory circumstances where we may be obliged to share data, for example with Court, Police or Regulator.

TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE

If you use our services while you are outside Jersey or the EU, your information may be transferred outside Jersey or the EU in order to provide you with those services.

REVIEW OF THIS POLICY

We keep this policy under regular review and may, at any time, revise this privacy statement. Where there are material changes to this privacy policy we will use reasonable endeavours to update you of these. This policy was last updated in October 2018.

YOUR RIGHTS

You have the right to apply for a copy of the personal data we hold about you and to have any inaccurate personal data about you rectified.

In some circumstances you may also have the right to ask us to erase your personal data or restrict its processing. 
 
Where we process your data for our legitimate interests, you have the right to object to such processing.

Please bear in mind that if you object to processing or withdraw your consent, this may affect our ability to deliver services to you.

Should you wish to discuss the exercise of any your rights, please contact us as set out below:

PO Box 356
St Helier
JE4 9YZ

01534 840138

lyn@jerseycharities.org

There is an excellent guide explaining your data rights here https://ec.europa.eu/commission/sites/beta-political/files/data-protection-overview-citizens_en.pdf