Where the website has links to external websites Hilary’s Dream Trust is not responsible for the privacy practices of those websites.
Hilary’s Dream Trust complies with the principles of the Data Protection Act 1998, and includes legislation that came into force in May 2018.
If you would like to review any information we hold (about you) or would like it to be removed, please contact us.
Likewise if you are unsure about any aspects of our policy or have any queries about it, please contact us.
Hilary’s Dream Trust Ltd
Privacy and Data Protection Policy
Data we collect
We collect your data when you supply your details to us. We take care to ensure your data is kept safe and protected.
Sharing your data
We will not share your data with third parties without your permission.
You have various rights in relation to the data we have collected about you, for example the right to receive a copy of the data we hold, the right to ask us to send a copy of the information we hold to a third party and the right to request we remove data relating to you from our records.
Who are we
We are the Trustees and officers of HDT.
- When do we collect personal information?
We collect your personal information when you:
- Register your details when making enquiries about a grant for assistance or to take part in an event we are running;
- Complete a form asking for a financial grant or registering to take part in one of our events;
- Sign up as a volunteer of HDT;
- Are referred by another charitable organisation or person to apply for assistance/advice or grant;
- Visit our Website;
- Engage with us on social media;
- Contact us by any means with questions about a service or to raise a complaint;
- Ask one of our sailing advisers to email you information about a service, or assistance;
- Enter prize draws or competitions;
- Choose to complete any surveys/feedback we send you;
- Comment on or review our services. Any individual may access personal information related to them, including opinions. So if your comment or review includes information about the colleague who provided that service, it may be passed on to them if requested;
- Fill in any forms, e.g. applications for a financial grant;
- Have given a third party permission to share the personal information they hold about you with us;
- Phone us, we will record that you have contacted us by phone for our records.
- What personal information do we collect and why?
The personal information that we collect about you broadly falls into the following categories:
Information that you provide voluntarily
When you register with us to access our services, attend an event, enter a prize draw/competition or donate to HDT, you will be asked for some essential information including your title, first name, surname, postal address, email address, telephone, and, if applicable, payment information. These are collected to help us:
- Register your details as a new participant at one of our events;
- Manage and process your application for a grant;
- Understand your needs and listen to your feedback;
- Keep in contact and updating you about specific events you are taking part in;
- Speed up your form filling processes if you’ve registered online;
- Provide you with information about our fundraising activities;
- Respond to any issues or queries;
- Conduct analytics to understand how our services are used; and/or
- Notify you about changes to our service.
Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. For example we may receive personal information from an individual recommending that we consider your application for a financial grant of assistance.
If you have any questions about the third parties we obtain personal information from, please contact us using the contact details provided under the “How to contact us” heading below.
Enhancing our data
Where we have obtained your personal information from various sources (including personal information we have lawfully obtained from third parties) we may combine this information in certain circumstances in order to enhance our understanding of your requirements and preferences. This is necessary for the purposes of our legitimate interests to ensure that we provide you the most appropriate offers for services.
We will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our service users and ensuring that our services meet the needs of our service users. We undertake data analytics in order to:
- Learn more about our service users and their preferences;
- To identify patterns and trends amongst our service users;
- Enhance user experience on our Website;
- Provide information, content and offerings tailored to our service users needs;
- For general research and statistical purposes;
- To help us develop new services and events;
- To monitor performance of our services;
We will use your personal information (including by anonymising and aggregating it with other service users personal information) for financial analysis purposes, to determine how we are performing and where improvements can be made. This is necessary for the purposes of our legitimate interests in understanding how our charity is performing, and considering how to improve our performance.
- Who do we share your personal information with?
We may disclose your personal information to the following categories of recipients:
- to sailing safety officers, instructors, sailing partners;
- Other sailing charities who support our business;
- Other third parties who help us manage electronic communications with you;
- Competition or prize-draw partners
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or apply our Terms and Conditions, or (iii) to protect your vital interests or those of any other person;
- to any other person with your consent to the disclosure.
Where we share your personal information with third party service providers and partners we apply a policy to ensure your personal information is safe and in order to protect your privacy. Our policy requires:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in any agreement with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your personal information held by them will either be deleted or rendered anonymous (subject to applicable law).
If you have any questions about the third parties we share your personal information with, please contact us using the contact details provided under the “How to contact us” heading below.
- Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform any agreement with you, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
- How do we keep your personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include:
- Encrypting your personal information.
- Keeping your information up-to-date and accurate. Please note that, to do this, we require you to tell us if any of your details such as your name or address change; and
- Having in place strict security procedures for the storage and disclosure of your information to prevent unauthorised access.
Unfortunately, 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 the security of your data transmitted to and/or through our Website and via the Internet (email); any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. For more information about the specific periods for which we retain your data, please contact us using the contact details provided under the “How to contact us” heading below.
- Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
You can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, see the section headed “contacting the regulator” below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
- Contacting the regulator
If you feel that your personal information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to raise a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns (please note we cannot be responsible for the content of external websites).
- How to contact us
If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer at the following address email firstname.lastname@example.org or post to Hilary’s Dream Trust, 3 Cooper Drive, Wentworth Park, Herne Bay, Kent CT6 5FF
The data controller of your personal information will be one of the trustees of Hilary’s Dream Trust. The current data controller is Kim Mason.