Privacy Policy

At the Randal Foundation, we prioritise your privacy. Our Privacy Policy outlines how we collect, use, and protect your personal information. Learn about your rights and our commitment to safeguarding your data.

Purpose of the Policy
 
The Randal Charitable Foundation® (‘the Foundation’, ‘we’, ‘us and ‘our’) respects your privacy and is committed to protecting your personal data. ‘Personal data’ means any information about an individual from which that person can be identified (hereinafter “Personal Information”). Personal Information does not include data where your identity has been removed or which is not associated with or linked to your Personal Information (anonymous data). 
 
The name and the logo of the The Randal Charitable Foundation® are a registered trade marks. 
 
This Privacy Policy details what Personal Information the Foundation collects, why the Foundation collects it and from whom, and for how long it is retained. It will also tell you about your privacy rights and how the law protects you.
 
This Privacy Policy aims to give you information on how the Foundation collects and processes your Personal Information. It applies to information the Foundation collects about:
 
• People who email or send letters to the Foundation regarding Grant Funding or other support
• People who use the ‘Send Enquiry’ service on the ‘Contact Us’ page of our website
• People who download and complete and submit a Gift Aid form to enable us to reclaim income tax on personal donations; and
• Charities, other organisations or individuals who share information with the Foundation
 
It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice which the Foundation may provide on specific occasions when Personal Information is collected or processed so that you are fully aware of how and why the Foundation is using your Personal Information.
 
Data Controller
 
For the purposes of the data protection laws in the UK, the Foundation is the data controller and is therefore responsible for your Personal Information. The Foundation’s contact details are set out at the end of this Privacy Policy.
 
The Foundation has appointed Trustees who are responsible for overseeing this Privacy Policy and any questions relating to it. If you have any questions, including any requests to exercise your legal rights, please contact the Trustees using the details set out at the end of this Privacy Policy.
 
Our purpose and legal basis for using your Personal Information 
 
Under UK data protection law, we must have a valid basis for using your Personal Information. There are four main ways we may have a valid basis for using your Personal Information: 
 
1. For performance of a contract with you, or to take steps to enter into a contract including determining the terms on which we will provide our grant funding, updating our records and managing our relationship with you; 
 
2. Legal obligation: We have a legal obligation to store your Personal Information relating all grant-giving accounting periods in line with Charity Commission guidance and financial regulations;
 
3. Legitimate interest: Where we process Personal Information on the basis of a legitimate interest, as set out in this Privacy Policy, “legitimate interest” means the interests of the Foundation in conducting and managing our operations. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
 
4. Consent: Generally we do not rely on consent as a legal basis for processing your Personal Information, unless expressly stated. However, where appropriate the Foundation may look to share your Personal Information with other Grantees and use images and photographs taken at events and meetings for use on our website and within publications of reports and newsletters. Specific consent will be sought where necessary with details of how Personal Information and photographs will be used. 
 
We may collect and process Personal Information about you for the following purposes:
 
• Applications for grants – Personal Information provided in applications for grant funding and subsequent correspondence concerning the same will be processed so as to allow us to process and evaluate the application in accordance with our standard operating procedure and our legitimate interests in operating as a grant giving foundation. The Personal Information provided will generally be the name, role and contact details of the individual within the project or charity responsible for making the application. If your application contains Personal Information about any of your service users or other individuals you must ensure that you have their consent before sharing their Personal Information with us, or anonymise it. 
 
• Grant funding and support – Additional Personal Information (including further contact details, images/photographs and financial/bank details) may be required in order to record your grant offer and manage the administration of grant funding; provide you with assistance and support throughout the grant funding period, to contact you to discuss future funding opportunities and to communicate with you and to keep you informed of important information or notices. Your Personal Information will be processed in accordance with our standard operating procedure and our legitimate interests in operating as a grant giving foundation. Where we have your consent, we may share your contact details with other grantees where and when appropriate.
 
• Monitoring – Personal Information provided by the projects and/or charities to which grants are distributed, including by way of monitoring forms, will be processed so as to allow us to communicate with those charities including monitoring the projects in respect of which grants are awarded, in accordance with our legal obligations and our legitimate interests in ensuring our own governance. As stated above, you must ensure that you have consent of service users or other individuals before sharing their Personal Information with us, or anonymise it. 
 
• Donations – Personal Information provided by donors (name, contact details and where provided financial data) will be processed to enable us to receive donations, including reclaiming Gift Aid. We will also keep in touch with our donors to update them on our activities and the projects and charities that the Foundation supports and to keep donors informed of important information or notices. This is necessary for our legitimate interests in receiving and processing donations, our own governance and in growing and developing the Foundation. 
 
• Enquiries – when you contact us using the ‘Send Enquiry’ service via our website, the Foundation will receive an email which contains the contents of the enquiry amongst other Personal Information. This information will not be shared with any other organisations and will be used solely for the purpose of dealing with that enquiry as requested by the individual concerned and in accordance with our legitimate interests including that of providing a response to such enquiries. Similarly, if you contact us with an enquiry by any other means, we will use your Personal Information to respond to you.
 
• Administration – we may use your Personal Information for the purpose of protecting the Foundation and our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to update our website with grant funding awards, publish impact reports, newsletters and internal reports. This is necessary for our legitimate interest in running the Foundation, the provision of administration and IT services, network security, to prevent fraud and in the context of a reorganisation or restructuring exercise, and for compliance with our legal obligations.
 
• Website analytics – as you navigate our website, technical and usage data may be collected automatically through cookies (as referred to below). We do this for statistical and analytical purposes to find out things such as the number of visitors to the various parts of the website, to help us to improve the content of the website and services, and to customise the content or layout of the website for you, which may include collecting geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the website. This is necessary for our legitimate interest in defining types of users of our services, to keep our website updated and relevant, to develop the Foundation and to inform our operational strategies. However, where possible we use anonymous or aggregated data that does not identify individuals and is not considered Personal Information in law, such as your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) pages viewed, online browsing, clicks, actions, etc.). However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.
 
• Fault reporting – if you contact us to report a fault with our website, we will use the Personal Information provided for the purposes of rectifying that fault in accordance with our legitimate interests.
 
• Recruitment – Personal Information provided for an employment opportunity will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.
 
We may also use Personal Information which you provide to us, where the law allows us to do so, as follows:
 
• To deal with and/or respond to any enquiry or request made by you prior to entering into any contract with us or as a result of such contract
• For the performance of our contractual obligations towards you and providing you with our services 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• For compliance with legal, financial or regulatory obligations to which we are subject, including the prevention of crime. 
 
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
 
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  
 
How do we receive information about you? 
 
We may receive your Personal Information from various sources: 
 
• When you voluntarily provide us your Personal Information in order to submit an enquiry by email, letter, phone call, or via our website 
• When you use or access this website in connection with your use of our service
• When you make a donation and/or submit a completed Gift Aid form, 
• From third party providers such as other grant providers (where you have consented to them sending us your Personal Information), services and public registers such as Companies House and The Charity Commission
• Through cookies and other technical means when you use our website  
 
Disclosure of Personal Information
 
Your Personal Information will only be disclosed to those of our Trustees, employees or workers that have a need for such access for the purpose for which it was collected. In most circumstances, the Foundation will not disclose Personal Information to any third parties without consent, unless legally obliged to do so or as set out below. 
 
In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers for any of the following purposes:  
 
• Hosting and operating our website, including providing a personalised display of our website
• IT support, including technical diagnostics or analytics
• The Foundation also stores information on 3rd party customer relationship software, which is used to process enquiries, applications and other information to track, monitor and report internally. The software we use for this is Salesforce. 
• To receive the advice of our professional advisers
 
We may also disclose Personal Information if, acting in good faith, we believe that disclosure of such information is helpful or reasonably necessary to: 
 
(i) comply with any applicable law, regulation, legal process or governmental request; 
 
(ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; 
 
(iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; 
 
(iv) to establish or exercise our rights to defend against legal claims; 
 
(v) prevent harm to the rights, property or safety of us, our Trustees, employees and workers, donors, projects/charities, suppliers, our website visitors, yourself or any third party; or 
 
(vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
 
Personal Information sent electronically or processed by the Foundation will be sent within the UK and in the European Economic Area by The Foundation and its third-party processors. Where any Personal Information is processed by any third-party processor The Foundation shall ensure that such processors have appropriate levels of security and organisational controls to meet data protection requirements and to ensure a level of protection appropriate to any risk to the rights and freedoms of the individual. The Personal Information provided will be held securely by the Foundation and/or the data processors whether the information is in electronic or physical format.
This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information, except as set forth in this Privacy Policy.  
 
International transfers
 
The Foundation works with projects, charities, voluntary and Non-Governmental Organisations (NGOs) both in the UK and around the world (including countries outside of the European Economic Area).
 
To the extent that we need to transfer your Personal Information out of the European Economic Area, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 
 
• We will only transfer Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. 
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in the European Economic Area. 
 
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the European Economic Area. 
 
Personal Information retention 
 
The Foundation will only retain Personal Information for as long as is necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal requirements.
 
To determine the appropriate retention period for Personal Information, the Foundation considers the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of the Personal Information, the purposes for which the Foundation processes the Personal Information and whether the Foundation can achieve those purposes through other means, and the applicable legal requirements.
 
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
 
Third party collection of Personal Information 
 
Our policy only addresses the use and disclosure of Personal Information we collect from you. To the extent you disclose your Personal Information to other parties or websites throughout the internet, different rules may apply to their use or disclosure of the Personal Information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose Personal Information to.  
 
How do we safeguard your Personal Information? 
 
We take great care in implementing and maintaining the security of the website and your Personal Information. The Foundation follows standard procedures to ensure the safety of the Personal Information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 
The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee that the transmission of data via the internet is or will be secure; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your Personal Information when you are on the internet.
 
Minors 
 
We understand the importance of protecting children’s privacy, especially in an online environment. Our website is not designed for or directed at children. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact the Foundation immediately (please see the Contact Us page on our website for more details).
 
Cookies 
 
We use cookies to distinguish you from other users when you visit our website or access our services.  
 
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our services quicker and easier. 
 
Our website uses the following types of cookies: 
 
a. ‘session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;  
 
b. ‘persistent cookies ‘ which are read only by the website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits. 
 
c. ‘third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyse our web access. 
 
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our website may not operate properly and your online experience may be limited. 
 
We also use a tool called “Google Analytics” to collect information about your use of the website. Google Analytics collects information such as how often users access the website, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our website and services. Google Analytics collects the IP address assigned to you on the date you visit websites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
 
Links to other websites
 
Please note that The Foundation’s website may contain links to other websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share Personal Information. The Foundation does not control third party websites and is not responsible for their privacy notices or for the content, accuracy or opinions express in such websites. The Foundation does not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through the Foundation’s website does not imply approval or endorsement by The Foundation of the linked website. 
 
The Foundation encourages individuals to read the privacy statements on the other websites that they visit.
 
User Rights 
 
Individuals have the right to:  
 
1. Receive confirmation as to whether or not Personal Information concerning them is being processed, and access their stored Personal Information, together with supplementary information. 
 
2. Receive a copy of Personal Information they directly volunteer to us in a structured, commonly used and machine-readable format. 
 
3. Request rectification of their Personal information that is in our control.
 
4. Request erasure of their Personal Information. Please note, however, that we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to them, if applicable, at the time of the request.
 
5. Object to the processing of Personal Information by us. 
 
6. Request to restrict processing of their Personal Information by us.
 
7. Withdraw their consent at any time where we are relying on consent to process their Personal Information. However, this will not affect the lawfulness of any processing carried out before they withdraw their consent. 
 
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.  
 
If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Administrator using the details provided on our Contact Us page on our website.
 
You will not have to pay a fee to access your Personal Information or to exercise any of your 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.
 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
 
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/ . We would, however, appreciate the chance to deal with any concerns before you approach the ICO, so please contact the Administrator by email in the first instance.
 
Changes to this Privacy Policy
 
The Foundation keeps the Privacy Policy and documents under regular review. This Privacy Policy was last updated on 24 August 2020.
 
How to contact us
 
If you want to request information about the Privacy Policy, the manner in which The Foundation handles Personal Information or to exercise any of your rights in respect of your Personal Information, please write to us at:
 
The Randal Charitable Foundation, Nene House, 4 Rushmills, Northampton, NN4 7YB
 
Alternatively you can contact us via email: [email protected]
 
Please address all correspondence in respect of this Privacy Policy, the manner in which the Foundation handle Personal Information or the exercise of an individual’s rights in respect of their Personal Information to the Administrator.
 
To enable us to verify your identity and process your request, please include all of the following information and documentation with your request: 
 
• Your full name 
• Your email address
• Your business / personal address 
• A description of the data that you are requesting, including a date range 
• The date of the request 
 
Last Updated: 19 September 2020