Introduction

This Privacy Policy sets out the basis on which personal data we collect from you, or that you provide to us, will be processed by The Commonwealth Education Trust.  CET is a charity registered in England and Wales (number 1119647).  Our office address is 2^nd Floor, 11/12 Tokenhouse Yard, London EC2R 7AS. We are firmly committed to protecting your privacy and aim to be clear about how we collect, use and protect your personal information.

How and when we collect personal information

We may collect and store information about you when you interact with us. For example, this could be for:

• Governance and trustee management
• Employee recruitment
• Employee and contractor administration
• General enquiries
• Fundraising
• A contract you have with us

What information we might collect

When you engage with us by phone, mail, in person or online, we may collect information about you.  This may include your name, address, email address, telephone number, date of birth, bank account details, and other information relating to you personally which you may choose to provide to us. Data protection law recognises that certain types of personal information are more sensitive. This is known as ‘sensitive’ or ‘special category’ personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person’s sex life or sexual orientation.  Sensitive information will only be collected where necessary, for example, when you become a member of staff. Clear notices will be provided at the time we collect this information, stating what information is needed, and why. We may obtain information about your visit to our website.  The website uses tracking software to understand how visitors interact with the site by collecting and reporting information anonymously. This software is provided by Google Analytics. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website.  You can read Google’s privacy policy at www.google.com/privacy.html.

How and why we use your information

We will use your personal information for the following purposes:

• Responding to a request: If you contact us with a query, we may use your personal information to provide you with a response.
• Fundraising or direct marketing:  We will only send you marketing information by email, SMS, or phone if you have given us specific consent.
• Processing an application to work with us: We may process your information if you complete an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and respond to you.
• Transactional purposes: We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services.
• Donation processing: We will process personal information you provide in order to administer any one-off or on-going donations you make and claim Gift Aid.
• Legal, regulatory and tax compliance: Where we are subject to a legal obligation, we may process your personal information to fulfil that obligation.
• Improving and developing our website.

How we may share personal information

We may share some of your personal information with organisations that carry out processing operations on our behalf, such as payroll and web services companies.  We carry out checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal information that we give to them. We do not sell or share personal information to third parties for the purposes of marketing.

How long we keep personal information

We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction). In respect of other personal information, we will retain it for no longer than necessary for the purposes for which it was collected, taking into account guidance issued by the Information Commissioner’s Office.

Your rights

Data protection legislation gives you the right to request access to personal information about you which is processed by CET and to have any inaccuracies corrected.  You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information. To exercise any of these rights, please contact us at the address below. You can find out more about your rights from the Information Commissioner, who regulates data protection and privacy. The Information Commissioner’s website is www.ico.org.uk.

Changes to this policy

We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on our website or by contacting you directly.

Contact

Please feel free to contact us with any questions, comments or queries regarding this Privacy Policy. All questions should be directed to the Trust Secretary by email to info@cet1886.org, or by post to 2^nd Floor, 11/12 Tokenhouse Yard, London EC2R 7AS.