A Charitable Incorporated Organisation, Registered Charity No. 1199156 MEMBERS’ PRIVACY POLICY
Effective from 20/7/2023
Protecting personal data is extremely important to the Monken Hadley Common Trust (“the Trust”). This is our privacy policy, which sets out what personal data we collect about our members, how we use it and how long we retain it. By “personal data” we mean any information relating to an identified or identifiable individual, such as their name, address or email address, and any reference to “data” in this policy is a reference to personal data about members and former members of the Trust; the Trust keeps its privacy policy under regular review and the latest version can be found at
mhctrust.org.uk/privacy-policy.pdf
WHAT DATA DOES THE TRUST HOLD ABOUT MEMBERS AND FORMER MEMBERS, AND FOR HOW LONG IS IT HELD?
1. The Trust has a legal obligation to hold the following data about its members and former members: name; service address (which will typically be the member’s home address); the date of becoming a member; and, where appropriate, the date of ceasing to be a member. The Trust will delete this data after the expiration of the minimum period allowed by The Charitable Incorporated Organisations (General) Regulations 2012 – which is 10 years from the date on which that person ceased to be a member.
People will cease to be members when they resign or die, or when they have failed to pay their renewal subscriptions after the expiration of six months from their renewal date, or exceptionally when their membership is terminated under Clause 9(4)(a)(iv) of the Constitution.
The Trust may be legally required to disclose this data to other members as set out in the section “Members’ and Former Members’ Rights” below, but it will not disclose it to any other party other than in exceptional circumstances to the Charity Commission.
2. With their consent the Trust may also hold an email address and a landline and/or a mobile telephone number for each member.
By providing the Trust with a telephone number, and not having withdrawn their consent for this data to be held, members are consenting to being contacted by telephone in relation to any of the purposes set out in this policy.
By providing the Trust with an email address, and not having withdrawn their consent for this data to be held, members are consenting to being contacted by email, including consenting to documents and information being supplied directly as email attachments and indirectly in the form of links to a website, in relation to any of the purposes set out in this policy.
Telephone numbers and email addresses will never be disclosed to any other party, and will not be retained once individuals have ceased to be members.
3. The Trust will also hold copies of any Gift Aid Declaration(s) made; what membership subscriptions have been made, how and when they were made, and the bank reference set up on standing orders (but it will not retain sort codes or account numbers of members’ bank accounts once a standing order has been set up). Other than as required by law or by HMRC (for example to allow Gift Aid to be recovered), the Trust will never share with, or disclose any of this data to third parties nor will it will retain it for former members.
The Trust will also record whether members’ consent has been given to receiving newsletters and other communications as described below.
To hold the data set out in this section, the Trust relies on a condition known as “legitimate interest”: it is in the Trust’s legitimate interest to hold this data, as it provides it with the information it needs to carry out its charitable work.
HOW THE TRUST MAY USE DATA ABOUT MEMBERS
The Trust may use the data it holds about members: to notify or to remind them of Annual or other General Meetings, including sending them details of the matters to be considered at those meetings; to solicit donations, or the renewal of membership, or a change in the membership subscription, or the Gift Aiding of their subscriptions. The Trust may also use it to claim Gift Aid from HMRC, and to meet their and any other regulatory or legal requirements.
Subject to their consent the Trust may from time to time send members copies of its newsletters and other material which is directly or indirectly relevant to the Trust, or to Monken Hadley Common, and which it is felt may be of interest.
The Trust may also be legally required to disclose the statutory data set out in 1. above to other members as set out in the section “Members’ and Former Members’ Rights” below.
MEMBERS’ AND FORMER MEMBERS’ RIGHTS
Members and former members have the right: to access the data that the Trust holds about them; to make it correct any inaccuracies; to make it erase any data it holds about them with their consent; to withdraw their consent where the Trust relying on it to use their data; and to make, update or withdraw Gift Aid Declarations.
Members (but not former members) have the legal right to ask for a list of the statutory data set out in 1. above which the Trust holds about all its current members, and optionally about all the former members about whom the Trust holds data.
Having been supplied with documents or information otherwise than in hard copy form, members are entitled to require the Trust to send a version of the document or information in hard copy form within 21 days of the member’s request.
DATA CONTROLLER
Under the Data Protection Act 2018 the Data Controller is the Trust, i.e. it is the Trust itself which determines the purposes for which and the manner in which any personal data are, or are to be processed; the Trust itself also processes the data.
CONTACTS AND COMPLAINTS
For general questions or complaints about membership, to update the data the Trust holds, to change or remove consents to process data, or to resign membership please write to Cornelia Dung, Membership Secretary, c/o 23 Tudor Road, Barnet, EN5 5NW, or email
membership@mhctrust.org.uk
Members and former members wishing to exercise any of their other rights, can contact the Trust by letter or email at the addresses above; and if they have any concerns about the way we process or have processed their data, or are not happy with the way we’ve handled a request by them in relation to their rights, they also have the right to make a complaint to the Information Commissioner’s Office (ICO) which can be done by telephoning 0303 123 1113 or by accessing their web page at
https://ico.org.uk/make-a-complaint/
(To contact the Trust about any matter to do with the management of the Common, please email curator@mhctrust.org.uk or telephone 0701 424 6096.)
