Holocaust Memorial Day Trust (HMDT) takes the privacy and security of your data extremely seriously. This policy explains when and why we collect personal data (that is, information by which an individual can be identified – such as name and address), how we use it, the conditions under which we may disclose it to others and how we keep it secure and explains our obligations and your rights under the General Data Protection Regulation and any subsequent UK legislation and regulations (collectively referred to as ‘Data Protections laws’). This policy has been put in place to protect your rights under the Data Protection laws, and it is important that you understand what we will do with your data and that you are happy with this.
References to the processing of information includes the collection, use, storage and protection of data.
HMDT is the ‘data controller’ for the purposes of this policy, and the policy extends to its staff, trustees, volunteers and others, including selected third parties, who may process data on our behalf from time to time. If at any time you would like to contact HMDT to discuss this policy in more detail please do so by writing to us, calling us or emailing us.
Telephone – 0207 785 7029
Email – firstname.lastname@example.org
Postal address - Holocaust Memorial Day Trust, PO BOX 61074, London, SE1P 5BX
This policy is effective from 25 May 2018.
A. Why do we collect data?
Organisations are permitted to process data if they have a legal basis for doing so. HMDT processes data on the basis that:
- Express and informed consent has been given by the person whose data is being processed; or
- HMDT has a legitimate interest to process data; or
- It is necessary in relation to a contract or agreement which the person has entered into or because the person has asked for something to be done so they can enter into a contract or agreement; or
- There is a legal obligation on HMDT to process data.
Where HMDT is relying solely on consent as the basis for processing data, we are required to obtain your explicit consent. You can update or withdraw this consent at any time by notifying us by telephone, email or letter to the details listed above. This may affect the extent to which we are able to interact with you in future.
B. What data do we collect?
We collect the minimum data necessary for HMDT to pursue our stated charitable objectives, and by running events, keeping our members informed of our activities, marketing, and the effective running of HMDT through its staff, trustees and volunteers. Data collected and processed may include, but not be limited to:
- Names and contact information such as telephone numbers, email and postal addresses
- Such other information that is relevant and necessary for HMDT to carry out its activities, charitable purposes and legal obligations.
C. What we do with the data we process
We will share your personal data with third parties where we are required to by law or regulation, where it is necessary in the provision of services, for administration purposes, or where we have another legitimate reason in doing so.
D. Your rights in relation to your personal data
At any time
- You may request details of personal information which we hold about you.
- You may choose to restrict the collection or use of your personal information, but this may inhibit or limit the way in which HMDT is able to interact with you.
- You may, change your mind about what information we hold about you,
- You may withdraw consent for us to hold any information about you if we continue to hold it at all, subject to any legal obligation on HMDT to retain data.
- You may ask us to delete any record that we have of you
- You may ask us to update your details. HMDT take seriously the need to hold accurate and up to date data. We will promptly correct any information found to be incorrect.
You can obtain further information about Data Protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk/for-thepublic.
E. Data retention
HMDT retain data for no longer than necessary.
- If we have been unable to contact you for three or more consecutive mailings we will automatically remove your data from our system.
- If we have not had contact with you or three years or more.
HMDT are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we process. Persons processing data on behalf of HMDT do so in accordance with this policy and on the basis that HMDT is satisfied that they can and will adhere to our high standards for data protection and security.
The transmission of information over the internet is inherently insecure. We cannot guarantee the security of data sent over the internet and you send it at your own risk. You are responsible for keeping the password you use for accessing our website (if applicable) confidential; we will not ask you for your password, except when you need it to log in to our website.
G. Web browsing and cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We may also collect and store information about your browsing device, including, where available, your operating system and browser type. This is anonymous statistical data about your browsing activities and patterns, and does not contain any personal data.
H. Links to other websites
If you feel that we have not adhered to this policy, please call us on 0207 785 7029 or send an email to email@example.com and we will solve the problem promptly.