The information we collect, how we collect it and what we do with it.
Project Trust is an Educational Gap Year Charity, (Company Registration No. 170673 and Registered as a Charity in Scotland No. SCO25668). In this privacy notice, references to “we”, “us” and “our” are to Project Trust and the website referred to is www.projecttrust.org.uk. Project Trust is referred to as the “Data Controller”, “data controller” means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed.”
How we use you data
At Project Trust we take your privacy seriously and will only use your personal and sensitive personal data in relation to:
- Your Application and Selection as a Volunteer.
- Providing the necessary support in fundraising, training and briefing before departure.
- Organising the logistics of your placement – travel, insurance, visas and security.
- Providing the necessary support during your overseas placement.
- Providing support for your son, daughter or ward throughout their Project Trust journey from application to Returned Volunteer.
- Encouraging ongoing engagement and support on your return.
- Liaising with you as a donor.
- Engaging with you as a school representative when recruiting Project Trust Volunteers and providing Global Citizenship presentations.
- Engaging and liaising with you as an in-country Project Trust Representative or project Host.
- Engaging and liaising with you in your capacity as a Service Provider, Project Trust Trustee or supporter.
- Staff employment.
- Fundraising and promoting the interests of Project Trust.
Definition of Sensitive Personal Data under the GDPR (General Data Protection Regulation)
Data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
The main legal basis upon which we rely to process this information is “Legitimate Interest”. For applicants, the processing of your data is necessary in providing an international volunteering opportunity and we are unable to accept your application without this understanding. We assume candidates, our Volunteers and Returned Volunteers, Volunteer parents, next of kin, school contacts and donors would reasonably expect Project Trust to need this data to process in the delivery of services to them.
In some circumstances, we rely upon “Consent” as the legal basis, eg in marketing and fundraising. In these cases we seek an OPT IN to the communication of marketing and fundraising materials and campaigns by text, e-mail or automated telephone call.
“Legal Obligation” is an additional legal basis, eg as an employer, mainly concerning HMRC [Her Majesty’s Revenue and Customs] requirements and, in fundraising, in the filing of donor information for Gift Aid.
- Withdrawal of Consent
Your data is collected in a number of ways
Your information is collected when you request information from Project Trust, contact us (and vice versa), make an application, use our website/apps, link to or from our website/apps, give personal information at school talks or careers fairs, connect with us via social media and any other engagement Project Trust has with you, including observations of your skills, motivation and behaviour on your Selection course.
Any personal or sensitive personal information we collect will be used in accordance with the GDPR and PECR [Privacy and Electronic Communications Regulations] laws.
The personal and sensitive personal data we may need to collect includes:
- Known name, full name (as on passport) and date of birth.
- Contact details including e-mail, telephone numbers, home address.
- Parent(s)/next of kin details and their contact details, including e-mail, telephone numbers, home address. They will be contacted within a month of receipt of their details.
- References from your nominated referees.
- Details of skills and interests, courses, academic education and qualifications.
- Sensitive classes of information, including details of any pre-existing conditions and special requirements (physical health, mental health, dietary, disability and special needs), racial and ethnic origin details, religious or other beliefs and details of any transgressions of the law.
- Details relating to a bursary application, including social circumstances, socio economic factors, home/accommodation circumstances and health issues.
- Passport, disclosure and driving licence details.
- Employment details.
- Debit and/or credit card details for transactions.
- Donations made by you, including Gift Aid declarations.
Project Trust will collect personal and sensitive personal data and will process this data in:
- The recruitment, selection and placement of Volunteers.
- Organising international placements, with the support of an in-Country Representative and liaising with your project Hosts.
- Booking travel tickets.
- Providing insurance cover.
- Providing emergency support and ongoing support throughout your time abroad with Project Trust.
- Engagement with Project Trust Returned Volunteer Community.
- The employment of staff, including interns and temporary staff.
Sharing of Data
We may need to disclose your personal and sensitive personal data to Service Providers who act as “data processors” on our behalf. “data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.”
These services may include administration, service, quality and improvement related activities, customer care, product innovation and choice, business management, operation and efficiencies, reorganisation/structuring, fraud and crime prevention/detection, monitoring, research and analysis, social media, dispute resolution/litigation, credit checking and debt collection.
These service providers include:
- In-country Representative(s) and project Hosts.
- Accommodation hosts and community volunteers on the Isle of Coll.
- Diversity Travel, through whom we book your flights.
- Ian Dickson Travel, through whom China in-country travel is booked.
- CEAIE, who organise our project placements in China and support the Volunteers.
- Caledonian MacBrayne, when booking ferry tickets to and from the Isle of Coll.
- Aviva Insurance through whom we provide medical, accident and public liability insurance.
- Duke of Edinburgh, for proof of completion of specific sections of their awards.
- Potential donors, including Charitable Trusts who we may approach on individual Volunteers’ behalf.
- Donors who require feedback on their support of specific Volunteers or initiatives.
- MailChimp for large e-mailings.
Selected Volunteers, please note it will not be possible to arrange all of the logistics of a placement and to offer ongoing support during the overseas placement if you do not agree to Project Trust sharing specific information with these individuals and organisations. The consent given at the point of completing an application to Project Trust covers the sharing of data with the above “data processors”, though an additional OPT IN will be required prior to finalising your placement abroad.
Project Trust has an official contract with all Service Providers, identifying the data shared and outlining the limitations of use. In the case of communications with donors and potential donors, Volunteers will be consulted before any data is shared.
In addition, we may need to share your details with:
- Healthlink 360 – who provide health advice and support.
- CEGA, who are Aviva Insurance’s International support provider – in cases of medical or accident claims and emergencies.
- In-country travel agents – through whom representatives may book internal travel.
- Visa service providers – who are used to arrange visas for specific countries.
- The Foreign, Commonwealth & Development Office [FCDO] – in cases of emergencies abroad.
- Police and legal advisors – in cases of legal issues.
- It may be mandatory to disclose information to foreign government authorities for immigration, border control, security and anti-terrorism purposes.
- Potential employers – where you request Project Trust provide a reference or endorsement.
- LGBT Scotland.
- Who Cares Scotland.
We will seek your agreement or that of your next of kin, except in the case of an extreme emergency where time is of the essence or if there is a mandatory requirement to disclose information to a foreign government authority or UK Police, before sharing your sensitive personal data with the above list. We respect your privacy in all matters and any confidential information will only ever be shared on a need to know basis within Project Trust.
We will never sell your personal details to any third parties for marketing.
All data collected is stored in a secure location for the purposes of complying with our legal obligations. Any financial transactions will be encrypted and we will employ strict procedures and protocols to try to prevent unauthorised access.
Sharing Data in non EU countries
Outside the European Economic Area (EEA), data protection controls may not be as strong as the legal requirements in this country. The only partners outwith the EU with whom we will share some of your personal and sensitive personal data are your in-country Representative (and CEAIE in China), your project Host(s) and the mass mailing service provider, MailChimp, who is based in the United States. Project Trust has an official contract, outlining the limitations of use with in-country Representatives and project Hosts and ensuring there are specific measures in place to secure your information. We are also transitioning away from MailChimp, by providing similar mailing functionality in our new CRM (Microsoft Dynamics 365) which is hosted in the UK.
In the case of the mandatory sharing of data with foreign governments and authorities, this is covered by the consent you gave at the time of Application to Project Trust.
Project Trust will retain personal and sensitive personal data only for as long as is necessary.
Gift Aid declarations, including personal information, will be retained for 6 years from the end of the accounting period in which the final donation was made.
In the event you do not become a Project Trust Volunteer or withdraw having been offered a placement, we will delete all of your personal information, only retaining an anonymised record of your application or interest, ensuring you cannot be identified.
Within 3 months of your return from abroad, we will delete all non essential data pertaining to your passport, health, qualifications, skills and disclosure. We will retain your contact information and international placement data (year abroad, project name, travel details, insurance claims, selection assessment, emergency event notes, communications with you and feedback from your project Host, in-country Representative and Country Coordinator/Desk Officer). This data is required for the purposes of providing references, endorsements and confirmation of your time abroad as a Project Trust Volunteer and assisting you in keeping in contact with or re-connecting with your fellow Returned Volunteers and with Project Trust.
We will continue to update our records with details of Returned Volunteers’ engagement with Project Trust and fellow Returned Volunteers and will update change of name, future plans, contact and career details, when we are able.
If our contact with you is via our website or other e-platforms where our advertising is displayed, cookies may be used. Information on cookies and how to manage them can be found on https://ico.org.uk/for-the-public/online/cookies
You agree to respect the intellectual property rights of Project Trust and will refrain from copying, downloading, transmitting, reproducing, printing, or exploiting for commercial purpose any material produced by Project Trust.
Rights of the Individual
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Project Trust does not use any form of automated decision making in the selection of our Volunteers nor in any other area of work.
More information on these rights can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
In order to exercise your rights, please either e-mail email@example.com, or write to the CEO, Project Trust, Hebridean Centre, Isle of Coll, Argyll, PA78 6TE or tel: 01879 230 444.
If you wish to complain about this privacy notice or any of the procedures set out in it, please contact Project Trust at firstname.lastname@example.org
If you believe that your data protection rights have not been adhered to, you also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside the UK.
IT & Digital Manager
Isle of Coll
Argyll PA78 6TE