What is ‘Personal Data’?
‘Personal data’ is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (GDPR) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice is that of Craigmyle Fundraising Consultants as a data controller.
Craigmyle is made up of a small number of consultants who work together to respond to enquiries and to deliver services as agreed with clients. We keep records of former clients and, by agreement with them, communicate by post, electronically and, less regularly, by phone to pass on information on services or news that we think will interest them.
This is on the grounds of:
a. specific request through sign up to our newsletter / bulletin services;
b. on the grounds of legitimate interest, where we have provided services to the subject in the past.
Records of individuals are kept only where they are the named representative of an organisation or business.
Data is kept on a password protected Customer Relationship Management system. Craigmyle consultants have access to this, with technical support for this system from one contracted supplier that is itself GDPR compliant.
Craigmyle is responsible to you for how we process any of your data. Our internal sharing of data means that, should one consultant with whom you are in touch be incapacitated and unable to continue with communication or a contract, you can be contacted and supported by another consultant of similar standing and skills.
A description of data processed and the reasons for it is in this Privacy Notice. In this document, ‘we’ refers to Craigmyle Fundraising Consultants as data controller.
What data do the data controllers process?
- Names, titles, roles or positions in an organisation;
- Contact details such as telephone numbers, addresses and email addresses.
How do we process your personal data?
We will comply with our legal obligations to keep personal data up to date, to store and destroy it securely, not to collect or retain excessive amounts of data and to keep personal data secure. We will protect personal data from loss, misuse, unauthorised access and disclosure and will ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- To maintain our own accounts and records;
- To notify you of changes to our services, events and role holders;
- To send you communications of a type which you have requested from us or that we consider may be of interest to you. These may include information on fundraising activities or publications, and on events organised by Craigmyle;
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data
Your personal data will be treated as strictly confidential to us and our contractors. For example, we may ask one known commercial provider to send out newsletters on our behalf, or to maintain our database software.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
Your rights with respect to personal data are listed below. To process any request we make regarding personal data, we may need to verify your identity to safeguard your security. In such cases we will ask you to respond with proof of your identity.
- The right to access information we hold on you:
At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
- The right to correct and update the information we hold on you:
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased:
If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. If we receive a request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory need).
- The right to object to processing of your data:
You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability:
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time:
You can withdraw your consent easily by telephone, email, or by post (please see contact details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
If we wish to use your personal data for a new purpose not covered by this notice, we will provide you with a fresh notice explaining the new use before processing. We will set out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you, to exercise rights, or to make queries or complaints at: The Data Controller: Craigmyle Fundraising Consultants
Phone: 01582 762 441
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.