Privacy Policy 1 — Inner Circle Educational Trust

Privacy Notice

Inner Circle Educational Trust (Inner Circle, we or our) takes data privacy very seriously and this privacy notice is designed to help you understand how we use your personal information.

We encourage you to read the whole notice.

1.0 The purpose of this privacy notice

1.1 Identity

Inner Circle is a registered charity in England and Wales (charity number 291583) and a private company limited by guarantee without share capital registered in England and Wales (company number 01791760).

Inner Circle is a charity that funds programmes for Looked After Children, primarily in the London Boroughs of Camden and Westminster to assist them to attain further education – in particular, to help them gain a place at, and keep on attending, University and then to obtain employment thereafter.

1.2 Our use of personal information

In common with most organisations, we collect, use and share information including personal information. In our case, we collect, use and share information, including personal information, in connection with our charitable activities, the fulfilment of our charitable objectives and the running of our organisation more generally.

1.3 This privacy notice

This is our main general privacy notice that applies across our organisation, although we may publish additional

privacy statements that apply to specific activities that we undertake from time to time.

If an additional privacy statement is relevant to you because of the way in which you engage with us and there is a conflict between the information set out in this notice and the additional privacy statement, then the additional privacy statement will take precedence over the information set out in this notice.

We do not currently engage any staff members. However, if that position changes, we will prepare a separate privacy notice that sets out how we process the personal information of our staff, which all prospective, current and former members of staff should refer to.

1.4 Updating this privacy notice

This notice may be updated from time to time. This version is dated August 2022.

1.5 What is personal information?

Personal information is information that relates to you or allows us to identify you. This includes obvious things like your name, address and telephone number but can also include less obvious things like information about how you interact with us. There are different types of personal information. The most important types for you to know about are:

Special categories of personal information – these categories of personal information have additional protection under data protection laws. These categories include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership, your genetic data and biometric data, and information concerning your sex life or sexual orientation. Data protection laws in the UK place additional limitations on the way in which we can use this information when compared to, for example, your name and address.
Criminal convictions information – this is information relating to your criminal convictions and offences. Data protection laws in the UK restrict the way in which we can use this information when compared to, for example, your name and address.

Given our charitable objectives, we necessarily collect and use personal information relating to young people under the age of 18. Most frequently, these young people are aged between 14 and 17 and are either individuals that may be eligible to receive our charitable support, or who are already receiving our charitable support. We take even greater care than usual to protect the young people we support and their personal information. Other than in the fulfilment of our charitable activities, ordinarily we do not need, nor do we look, to process children’s/minors’ personal information.

Unless we request it, we ask that you do not send us, and you do not disclose, any special categories of personal information, criminal convictions information or other types of information such as those listed above which may be deemed to be particularly sensitive. We describe the various types of personal information we collect in the “Your personal information” section below.

1.6 Our responsibility to you

We process your personal information in our capacity as a controller. This means that we are responsible for ensuring that we comply with relevant data protection laws when processing your personal information.

2.0 Your personal information

2.1 Why are we collecting personal information about you?

We collect personal information about you in connection with our charitable activities, the fulfilment of our charitable objectives and the running of our organisation more generally. We will hold information about you if:

you are a prospective, actual or former beneficiary of Inner Circle;
you are responsible for or related to a prospective, actual or former beneficiary of Inner Circle – for
example, you are a parent, carer or guardian;
you act as a fundraiser for Inner Circle or make a donation;
you are a trustee, volunteer or supporter of Inner Circle or otherwise assist us in the carrying out of our charitable activities, the fulfilment of our charitable objectives or the running of our organisation;
you volunteer or work for, or otherwise support, another charitable organisation with whom we partner in the fulfilment of our charitable objectives;
you work for an educational establishment, such as a secondary school or higher education institution;
you represent or work for a regulator (such as the Charities Commission), certification body or
government body which has dealings with us;
you provide services to us (or you represent, work for, or own an organisation which provides services to us);
you visit our website or interact with us on social media platforms such as LinkedIn or Facebook, as applicable; or
you attend our events and/or receive our updates.

2.2 What personal information do we collect about you?

The types of information we process about you may include:

Individual details Name, address, other contact details (for example, email and telephone numbers); gender; date and place of birth; nationality; employer; job title; information about your background circumstances, including details of your relatives, parents, guardians and other carers; information about your social and economic circumstances, for example whether you are in receipt of welfare or benefits.

Identification details Identification numbers issued by government bodies or agencies, such as your national insurance number, passport number, tax identification number and driving licence number.

Academic information Academic history, including qualifications; predicted and actual grades; names of schools, colleges, university and other higher education institutions or establishments that you attend or wish to attend; career aspirations.

Employment information Information about potential job opportunities that may be suitable for you; information about interviews you have had or may have with prospective employers; names of employers that are of interest to you.

Financial information Income and other financial information; information about your entitlement to welfare and benefits; information on donations and other financial support that you provide to us.

Special categories of personal information Information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership.

Identifiers and location information Information which can be traced back to you, such as an IP address.

2.3 Where do we collect your personal information from?

We collect your personal information from various sources, including:

you;
your employer or the organisation that you represent, work for or own;
organisations involved in our charitable activities, the fulfilment of our charitable objectives and the running of our organisation more generally;
third parties with whom we work, such as organisations involved in our charitable activities, the fulfilment of our charitable objectives and the running of our organisation more generally;
government agencies and publicly accessible registers or sources of information;
our service providers;
social media outlets; and/or
by actively obtaining your personal information ourselves, for example the information we collect through your use of our website.

The sources that apply to you will depend on why we are collecting your personal information. Where we obtain your information from a third party – in particular, your employer or the organisation that you represent or work for – we may ask them to provide you with a copy of this privacy notice (or a shortened version of it) to ensure you know we are processing your information and the reasons why.

3.0 Our use of your personal information

3.1 How do we use your personal information?

We may process your personal information in many different ways – including collecting, recording, organising, storing, analysing, modifying, extracting, sharing, deleting or destroying it.

In this section we set out in more detail:

the main purposes for which we process your personal information; and
the legal bases upon which we are processing your personal information.

Providing information about our charitable activities

If you wish to receive information about our charitable activities, we ask you to provide us with a limited amount of information (normally your name and contact details, and sometimes the name of the organisation you work or volunteer for together with your role at that organisation). We use this information in order to communicate with you and provide information about Inner Circle’s work or activities that you have requested or that may interest you. We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests

We have a legitimate interest in keeping you informed about our charitable activities that may be of interest to you.

Please be aware that, in the event that we ever send you any form of marketing communication, there are separate laws regarding marketing communications that we adhere to, in addition to data protection laws. You may opt out of receiving marketing communications from us at any time, and each communication we send will provide a straightforward means of doing so.

Fundraising and donations

Carrying out fundraising activities

We may use your personal information to fundraise in accordance with our internal policies and procedures. We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests

As a charitable organisation, we have a legitimate interest in using your personal information to carry out fundraising activities.

Accepting and processing donations and other funding from our supporters and other benefactors

Legitimate interests

As a charitable organisation, we have a legitimate interest in using your personal information to accept and process any donations or other forms of funding you provide or are otherwise involved with.

Carrying out our charitable activities

Responding to enquiries and providing information about our charitable activities

We may collect and use personal information such as your name and contact details to respond to enquiries from you and to provide you with information about our charitable activities. We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests

We have a legitimate interest in using your information where this is necessary or appropriate to respond to enquiries from you and to provide you with information about our charitable activities.

Provision and administering of funding to the young people that we support

We may collect and use personal information such as your name, address, information about your personal background and circumstances, educational history and career aspirations, and socio- economic circumstances in order to:

process and respond to any application or request you have submitted to us to be supported by us, financially or otherwise, in connection with the completion of your education; and provide and administer financial and other charitable support to you where you are a person that we have agreed to support.

We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

To manage our contractual relationship with you

Where we agree and commit to funding your education.

Administering our charitable activities

We may use your personal information in connection with the administration of the Inner Circle and its charitable activities, such as:

for internal record keeping, including with respect to any donations or to manage feedback or respond to complaints; and
to analyse and improve our activities regarding fundraising and supporting the charity.

We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests.

We have a legitimate interest for us to run Inner Circle as a charitable entity effectively and in pursuit of our objectives. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. We will always ensure that your personal data will not be used where our interests are overridden by the impact on you.

Conducting research about potential new charitable activities that we may undertake and gathering your opinions and feedback in connection with our charitable activities and the development and improvement of the same:

We may use your personal information when carrying out research about your opinions, views and feedback on potential new charitable activities that we may undertake from time to time and gathering your opinions and feedback in connection with our charitable activities and the development and improvement of the same. We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests

We have a legitimate interest in conducting research about your opinions on our potential new charitable activities that we may undertake and gathering your opinions and feedback in connection with our charitable activities and the development and improvement of the same.

Service and products providers

We collect information about you in connection with your provision of products and services to us or your position as a representative or worker of a provider of products or services to us. We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests

We have a legitimate interest in contacting and dealing with individuals involved in providing products and services to us.

Visitors to our website

Our website may invite you to provide us with your personal information. Where you provide us with your information, we will only use it for the purpose for which it has been provided by you.

Most of our website use cookies to help them work more efficiently and to provide us with information on how the website is being used. Where we are legally obliged to provide you with further information about the cookies we use on our website, we have prepared separate cookies notice which you can find on our website and which provide you with the information you need to know.

We do not generally look to collect special categories of personal data and criminal convictions data on our website.ose.

Legitimate interests

We have a legitimate interest in providing to you the facilities on our website that you have requested and in understanding how our website is used and the relative popularity of the content on our website.

Establishing our legal position

We may use your personal information, including sharing it with our legal advisers, when looking to establish our legal position. In some cases, this information will include special categories of personal data and criminal convictions data.

For all information - Legitimate interests

We have a legitimate interest in understanding and establishing our legal rights and obligations.

For special category and criminal convictions data – the establishment, exercise, or defence of legal claims or prospective legal claims.

Accomplishing our organisation purposes

We may use your personal information for data analysis (for example, to improve the efficiency of our charitable activities and website), for audits and for operating and expanding our organisation’s activities.

We do not generally look to collect special categories of personal data and criminal convictions data for this purpose.

Legitimate interests

We have a legitimate interest in carrying out our organisation’s purposes and activities.

We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

3.2 Failure to provide your personal information to us

We cannot force you to provide your personal information to us and you can choose not to provide us with your personal information. Where we need to collect your personal information by law or in order to process your instructions, carry out our activities or perform a contract we have with you and you decide not to provide that information when requested, we may not be able to carry out your instructions, carry out our activities or perform the contract we have or are trying to enter into with you. In other circumstances where you choose not to provide us with your personal information we request, your decision not to provide us with your personal information may affect our ability to carry out certain of our charitable activities.

3.3 Consent

We do not generally process your personal information based on your consent (as we can usually rely on another legal basis). Where we do process your personal information based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent please email us at info@innercircle.org.uk or, to stop receiving our email updates, please click on the unsubscribe link in the relevant email you receive from us. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose(s) to which you originally consented unless there is another legal ground for the processing. Please note that where we rely on your consent to process your personal information and you choose to withdraw your consent, your decision may affect our ability to carry out certain of our charitable activities.

3.4 Do we share your information with anyone else?

We do not sell your information. But we do share your information in the following circumstances:

we may work with, or use the services of various external organisations, to help us run our organisation efficiently – for example, charities, educational establishments and other organisations that we work or partner with in connection with our charitable activities or who help us to administer our organisation or fundraise. We may share your personal information with our trusted third-party service providers, to facilitate services they provide to us, such as internet services, website hosting, data analytics, information technology and related infrastructure provision, email delivery, marketing, event organisation and hosting, and other services. In each case where we share your information with one of our service providers, the service provider is required to keep it safe and secure. They are also not permitted to use your information for their own purposes;

if we use external companies to organise or host events for us, we may need to provide these service providers with your relevant information;
to protect the rights, property and safety of Inner Circle and others. Such information will be disclosed in accordance with applicable laws and regulations. This includes where we share information with other parties in the context of litigation discovery and in response to subpoenas and court orders;
we share your personal information with other third parties, such as relevant public and government authorities, including regulators (such as the Charities Commission) and law enforcement, where we are required or requested to do so to comply with legal or regulatory requirements;

to comply with applicable law and regulations, which may include laws outside your country of residence;
to enforce our policies;
to prevent, investigate and identify persons or organisations potentially involved in activity that
appears to us to be illegal or we believe may expose us to legal liability; and
in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that the information in any way relates to that threat.

4.0 Other important things you should know

4.1 Keeping your personal information safe

We take security issues seriously. We implement appropriate steps to help maintain the security of our information systems and processes and prevent the accidental destruction, loss, or unauthorised disclosure of the personal information we process.

4.2 Profiling and automated decision making

We do not use profiling (where an electronic system uses personal information to try and predict something about you) or automated decision making (where an electronic system uses personal information to decide about you without human intervention).

4.3 How long do we keep your personal information?

We keep your personal information for no longer than necessary and, in any event, no longer than we are permitted to under applicable law.

4.4 Third party services

This privacy notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which our website link.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organisations, such as Apple, Google, Microsoft, or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organisations through or in connection with our social media pages.

4.5 Cross border transfers of your personal information

Occasionally, we may need to transfer your personal information across national boundaries, including, potentially, to countries that do not require organisations by law to look after your personal information in the way in which you have come to expect in your own country.

Where we transfer your personal information across national boundaries, we will protect your personal information by ensuring that those transfers are made in compliance with all relevant data protection laws. For example, where we transfer personal information outside of the United Kingdom to a country that is not recognised as providing an adequate level of data protection, we normally do so subject to safeguards that assure the protection of your personal information, such as the approved standard contractual clauses.

If you would like further details of how your personal information is protected when transferred from one country to another then please email us at info@innercircle.org.uk.

5.0 Your rights

5.1 Contacting us and your rights

If you have any questions or complaints in relation to our use of your personal information, please email us at info@innercircle.org.uk.

Under certain conditions, you may have the right to require us to:

provide you with further details on the use we make of your personal information;
provide you with access to the personal information we hold about you;
update any inaccuracies in the personal information we hold about you;
delete any of your personal information that we no longer have a lawful ground to use;
where processing is based on consent, stop that processing by withdrawing your consent;
object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
restrict how we use your personal information whilst a complaint is being investigated; and/or
transfer your personal information to a third party in a standardised machine-readable format.

In certain circumstances, we may need to restrict your rights to safeguard the public interest (for example, the prevention or detection of crime) and our interests (for example, the maintenance of legal privilege).

We are obliged to keep your personal information accurate and up to date. Please help us to do this by advising us of any changes to your personal information.

5.2 Your right to complain

If you are not satisfied with our use of your personal information or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the Information Commissioners Office. If you have any questions about this, then please email us at info@innercircle.org.uk.