Privacy & Fair Processing Notice
The Basil Death Trust strives to protect the privacy of all personal data collected during the course of our activities and it is important for you to know how we process your data. We will process your personal data under the terms of this policy and in accordance with any agreement with you.
We are a “controller” in terms under data protection law (including the UK General Data Protection Regulation and the Data Protection Act 2018) (“Data Protection Laws”).
We need to process personal data relating to our self-employed workers, our trustees, employees or representatives of grant applicants, employees or representatives of grant receivers, employees of professional advisers and employees of suppliers in order to function effectively as an organisation, ensure good governance, for audit purposes, to train our staff, to perform our business and to enable us to meet our legal obligations as an employer, a trust and as a registered charity.
Personal data is processed for commercial, charitable, administrative, statutory, support, marketing/promotion, archival, and health and safety purposes. All such personal data is collected and held in accordance with all applicable Data Protection Laws.
What personal data will The Basil Death Trust use?
This list includes all the ways we may use your personal data, and which of the reasons we rely on to do so. This is where we tell you what our legitimate interests are.
| Personal Information We May Process: | Our Reasons for Processing | Our Legitimate Interests |
|---|---|---|
| Trustees
• Name | • Our legitimate interests • Our legal obligations | • Administering our business |
| Employees of suppliers
• work addresses and contact details | • Our legitimate interests | • To keep in contact with suppliers • Administering our business |
| Self-employed worker(s)
• Name | • Our legitimate interests • Fulfilling contracts | • Administering our business |
| Employees or Representatives of Grant Applicants
• Name | • Our legitimate interests • Fulfilling contracts • Consent | • Administering our business |
| Employees of professional advisers
• Name | • Our legitimate interests | • To purchase services required to effectively run the Trust |
Where do we obtain your personal data?
In most cases we will obtain this data from you directly. Where you are an employee or representative of a grant applicant or grant receiver, we will obtain your personal data from the grant applicant in the course of their application to us or from a grant receiver in the course of our dealings with them in relation to our grant support activities.
In some cases, we might use an internet search engine as part of our research when awarding grants. When conducting such research, we may come across publicly available personal data about employees or representatives of grant applicants and/or grant receivers.
Processing Conditions
We process the personal data referred to above for the purposes of any contract or potential contract with self-employed workers, our trustees, employees or representatives of grant applicants, employees or representatives of grant receivers, employees of professional advisers and employees of suppliers; or for our legitimate interests in order to function effectively as an organisation, ensure good governance, for audit purposes, to train our staff, to perform our business and grant support activities; and to enable us to meet our legal obligations that we may be subject to as an employer, a trust and as a registered charity, as well as preserving our archives.
Who do we share your personal data with?
The personal data you provide to us may be accessed by our staff, our Trustees, auditors and our professional advisors in the course of providing services to us (such as Anderson Strathern LLP and Rossie House Investment Management LLP) under suitable obligations of confidentiality.
We may also publish some names and personal details, including photographs and video recordings, relating to grant receivers for our case studies and for marketing and promotional purposes. Individuals can request that personal data relating to them not to be published in this manner and we will deal with such requests in accordance with the law.
We will provide the names of our Trustees to the Office of the Scottish Charity Regulator (OSCR) as required by law. We may also need to share personal data where it is relevant to an inquiry undertaken by OSCR or where we need to report a matter to OSCR to comply with the law and any regulatory requirements.
We may also use information in aggregate, where personal data is removed, in order to improve and support our activities.
In the event of the winding up or dissolution of The Basil Death Trust, we may disclose your personal information to other organisations, including other charities, in order to discharge any obligation owed to you or to dispose of our assets. We may also disclose your information to other charities and their professional advisors where we are considering either a reorganisation or change of legal form of The Basil Death Trust or an amalgamation, merger or takeover with one or more other charities.
Security
We employ administrative, electronic and physical security measures to ensure that the personal data that we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.
Please be aware that unfortunately the transmission of information via the internet or by email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to us and any transmission is at your own risk.
The period for which the personal data will be processed
We will retain personal data securely and only in line with how long it is necessary to keep for our purposes or for a legitimate and lawful reason.
Our typical retention periods are as follows:
| Document Containing Personal Data | Retention Period |
|---|---|
| Grant Application Forms | 3 years from the date the Grant Application Form is received |
| Successful staff and Trustee CVs | 3 years from the date the staff and Trustees cease to be employed by or provide services to the Trust |
| Unsuccessful staff and Trustee CVs | 1 year from the date the CV was received |
| Email correspondence of grant applicants, grant receivers, Trustees and staff | 3 years from the date the email was sent |
| Photographs or video footage of grant receivers | 7 years from the date the photograph is published |
Some personal data may be retained for longer where it is in our legitimate interest to do so, such as to protect and defend our legal rights; or for research, archiving or statistical purposes. Individuals can request that other personal data relating to them be erased and we will deal with such requests in accordance with the law.
Transfers outside the United Kingdom
We do not send any personal data to countries outside the UK. However, if personal data ever was to be sent outside the UK, there will be protections in place to ensure the recipient protects the personal data to the same standard as the UK.
Data subject’s rights
As an individual, you have the following rights as a data subject under applicable Data Protection Laws in relation to the processing of your personal data:
- The right to request from us access to personal data held about you
- The right to request that inaccurate data held about you is rectified
- The right to request the erasure of personal data
- The right to restriction of processing
- The right to object to processing, and
- The right to data portability.
For more information and guidance about any of these rights please go to the website of the Information Commissioner’s Office at https://ico.org.uk/.
Complaints
If you think there is an issue in the way in which we handle your personal data, you have a right to raise a complaint with the Information Commissioner’s Office. Their website contains details of how to make a complaint.
However, we would welcome an opportunity to deal with the issue in the first instance, if you wish to contact us at: admin@basildeathtrust.co.uk.
Changes to this Privacy & Fair Processing Notice
We keep our Privacy & Fair Processing Notice under regular review and reserve the right to update and amend it. This notice was last updated on 24 January 2025.
Further information
For further information about the proposed data sharing set out in this notice, or about any aspect of the Basil Death Trust’s processing of your personal data, please contact us at the following email address, admin@basildeathtrust.co.uk.
January 2025