DATA PRIVACY NOTICE
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the Data Protection Act 2018 and General Data Protection Regulations 2018.
Who are we?
The Light College and Collective is the working name of The Light Project. The Light Project is the data controller. This means it decides how your personal data is processed and for what purposes. The Light Project is a charity registered with The Charity Commission (England and Wales), charity number 1084941.
The contact details for The Light Project are:
The Light Project
Chester CH1 2JH
T: 01244 400221 (please note that due to Covid restrictions the telephone number is not currently manned, nor is there an answerphone)
How do we process your personal data?
The Light Project complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes: –
- To manage our employees and volunteers. The Light Project process the personal information of employees and volunteers for recruitment, staff and volunteer administration, payroll, training, pensions and performance management and pastoral care purposes.
- To maintain our own accounts and records for example if we have a contract for services with you or a supplier account.
- Fundraising and marketing. Like all charities we have a range of fundraising and marketing activities that are designed to raise income or promote the aims and objectives of the charity. This may include inviting you to supporter days, newsletters, sponsorship or volunteering. This also includes suppression lists of people where consent to contact has been withdrawn. If you donate to The Light Project either directly or through a third party such as MyDonate we will process your name. If your donation is also eligible for Gift Aid we will process your address and will need to share this with HMRC via Gift Aid claims.
- Student recruitment and delivery of training courses including the FdA and the BA with the University of Chester. We may need to ensure you are eligible to study in the UK, process Student Loan information, process your name and address, date of birth, academic information, contact details and further information such as any medical issue we need to be aware of.
What is the legal basis for processing your personal data?
The Light Project needs a lawful basis to collect and use your personal data. The law allows for six legitimate purposes which organisations can rely on to process people’s personal data. The following five are the ones relevant to The Light Project’s activities:
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
- Processing is necessary to protect the vital interests of a data subject such as emergency contact and allergies
- Processing is based on an individual’s consent (more information below)
- Processing is necessary for compliance with a legal obligation for example when claiming gift aid or running payroll
- Processing is necessary for a legitimate interest of The Light Project (more information below)
The Light Project will always ask for your consent before sending you marketing or newsletters by email or post.
Where you give us consent to process your data we will keep a record of how and when this was given and you can withdraw your consent by contacting The Light Project office as above.
The law allows personal data to be legally collected and used by an organisation if it is necessary for a legitimate business interest of the organisation – as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned.
There are times when it is just not practical to ask a person for consent. In many situations, the best approach for The Light Project and our supporters, students, employees and volunteers is to process personal data because of our legitimate interests, rather than consent. You can however still withdraw you consent for such processing as outlined in “consent”.
Areas where The Light Project is relying on “legitimate interest” as the legal basis for processing are:
- Governance: reporting criminal acts and compliance with the legal instructions of law enforcement agencies; external audit and examination; statutory reporting
- Operational management: employee, student and volunteer recording and monitoring; IT and network security; maintenance of suppression lists; academic record; pension provision
- Financial management and control: processing of financial transactions and maintaining financial controls; prevention of fraud.
- Purely administrative: responding to any solicited enquiry from any of our stakeholders or potential new students; delivery of requested resources or information packs; administration of standing orders; providing ‘thank you’ communications and receipts.
What information we collect
We collect and use personal information such as names and address details, as well as other contact information such as email addresses and telephone numbers. We also collect information about the training you received from The Light Project, any financial transactions you make and any marketing preferences you give.
We maintain a record of communications that we send to you, and will also log any communications that you send to us.
If you have made a donation and kindly agreed to Gift Aid that donation we must record the fact that you are a UK tax payer and we have to maintain a record of the amount of Gift Aid we have collected.
We may record pastoral issues, safeguarding incidents, health and safety incidents, complaints, grievances or disciplinary procedures.
Student academic progress, marks, qualifications, academic work submitted, attendance, bursaries and fee payment information will be collected.
Where we collect and process sensitive personal data about yourself, for example any health condition that may be relevant or your religious beliefs, we will always seek your explicit consent to process this data.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will only be shared with employees and trustees of The Light Project as needed.
In addition, where legally required we will share relevant personal data with HMRC or NEST (our pension provider) or law enforcement agencies.
If you are a student on the FdA or BA we will share relevant information with The University of Chester. If you are also a student on the Baptist Ministry route, we will share relevant information with Northern Baptist College in accordance with our data sharing agreement.
If you are a student on our Chaplaincy course, we may share relevant information with Third Space Ministries.
If you have consented to receiving our emailed newsletter your name and email address will be exported to a provider such as Mailchimp or Mailerlite. You can unsubscribe to this service at any time.
We will not share your data with any other third parties without your consent.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary during the time you are connected with The Light Project.
The length of time each category of data will be retained will vary on how long we need to process it, the reason it is collected, and in line with any statutory requirements.
After this point the data will either be deleted or rendered anonymous.
What to do if you are not happy
In the first instance, please talk to us directly so we can help resolve any problem or query. Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
- The right to request a copy of your personal data which The Light Project holds about you;
- The right to request that The Light Project corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for The Light Project to retain such data;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to lodge a complaint with the Information Commissioners Office.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.