This Policy applies to The Berkeley Charitable Foundation ("the Berkeley Foundation"), a charity and company registered in England & Wales with company registration number 8548400 and charity registration number 1152596 whose registered office is at Berkeley House, 19 Portsmouth Road, Cobham, Surrey, KT11 1JG
The Berkeley Foundation is supported by The Berkeley Group of companies. The Berkeley Group operates through the following 'Brands': Berkeley, St Edward, St George, St James, St Joseph and St William. A full list of Berkeley Group companies can be found here.
References in this Policy to "our website" refer to the website https://www.berkeleyfoundation.org.uk/.
Our website is not intended for children. We do not knowingly collect the personal information of children under the age of 13 via our website. If you are under the age of 13, please do not access our website at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 13.
Your privacy and this Policy
We take the privacy of your personal information very seriously and know that you will wish to understand how we will use your personal information.
will inform you about what personal information we collect and why, how we use it, who we share it with, as well as giving you other important information;
covers personal information collected via our website as well as information that you may provide when corresponding directly with us.
Which personal information do we collect?
Personal information that you provide voluntarily:
Contact information, such as your name, postal address, telephone number, mobile phone number, and email address;
Where you have provided your feedback we will record your opinions and the text that you have written;
When you register to and/or attend our events we may receive your contact information as well as any information you choose to supply to us in relation to such event such as your dietary or accessibility requirements;
When you 'follow', 'like', post to or interact with our social media accounts, including YouTube, LinkedIn, and Instagram;
If you provide us with donations we will also receive your billing and payment details;
If you are or are connected with a beneficiary of one of our charitable activities, you may supply your personal information (including a photo and short biography) for inclusion in our marketing materials or charity reports, where we have requested such information from you and you have consented to provide it (or if you are under 16 or a vulnerable adult, where we have the consent of your parent, carer or guardian);
If you are a beneficiary of one of our charitable activities, you may supply your personal information (including your CV) to us in order for us to secure work placements or employment opportunities with the Berkeley Group and with third parties;
There are generally no adverse effects for you if you choose not to provide your personal information. You will still be able to use our website to view our material. However, without some of this information, we may not be able to communicate with you and/or take certain actions that you request, for example because this personal information is required to respond to your enquiries.
Collecting sensitive personal information
In certain circumstances, we will collect information that is deemed sensitive or referred to as special categories of personal data. This is most likely to include information about:
your health (for example if you ask us to provide you with special assistance to attend an event, if you specify dietary requirements which indicate a medical condition such as celiac disease, or if you include information relating to your health in any material you provide to us explicitly for our marketing material and reports);
your religion (for example if you specify dietary requirements which indicate a particular religion such as a kosher or halal meal, or if you include information relating to your religion in any material you provide to us explicitly for our marketing material and reports); and
your race, ethnicity, religious or philosophical beliefs and sexual orientation if you include information relating to these aspects in any material you provide to us explicitly for our marketing material and reports.
We need to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such information. We process special categories of personal information in the following circumstances:
in limited circumstances, with your explicit written consent;
where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent; or
where you have already made the information public.
Cookies and Personal Information that is collected automatically
A cookie is a small text file which is placed onto your computer (or other electronic device) when you use our website.
When you visit our website, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we collect includes information about your internet service provider, your operating system, browser type, domain name, the internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the web pages you request and the date and time of those requests. This may allow us to find out which parts of the website are popular or need changing. This is done in a way which does not identify any individual and we do not try to identify visitors to our website or to link this information with any personal information we collect.
You can set your browser not to accept cookies and the website below tells you how to disable cookies from your browser. However, some of our website features may not function as a result.
How do we collect your personal information?
Personal Information provided by you:
The main way that we collect your personal information from you when you provide it to us. This could be through our website or when speaking to one of our staff, either in person, via email or on the telephone.
Personal information provided by third parties:
Occasionally we may receive information about you from other sources such as our charity partners, to aid or promote our support of and work with those partners (such as through including that information in our marketing material or using it to secure work placements or employment opportunities, as described above). These partners are not required to provide your details to us but may do so when they have your requisite consent.
We may receive your initial name and contact details from an introducer or other person(s) when you have told them that you would like to hear from us.
Why will we use your personal information?
Uses of your information:
The most common purposes for which we will use your information are:
We will use your information to communicate with you and provide you with information that you have requested and to respond to any enquiries you may have.
We may send you information by post and email to keep in contact with you about our reports, news, and events that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our CRM and marketing services provider (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so).
We keep a record of when we receive consent from individuals and do not use information provided in such circumstances for any other purposes. We act on withdrawals of consent as soon as we can.
Additionally and as required, we may use your information:
To analyse and improve our website content and service.
For general operational administration
To comply with our legal, contractual and regulatory obligations
To comply with court orders and to exercise or defend legal rights.
What are the legal grounds for the Berkeley Foundation using your information?
Depending on which of the above purposes for which your information is used, it will be processed on one or more of the following legal grounds:
The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
The processing is necessary to comply with a legal obligation to which the Berkeley Foundation is subject;
The processing is necessary for the purposes of the Berkeley Foundation's legitimate interests or those of any third party that receives your personal information, except where these are overridden by your interests or fundamental rights and freedoms.
The only exception to the above is where we have asked for your consent for the processing.
Who will we share your personal information with?
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management), or other third parties who provide services to us. These include but are not limited to members of the Berkeley Group, IT service providers, solicitors, auditors and anyone acting on your behalf.
When we use third party service providers, we will retain control over and we will remain fully responsible for your personal data and we will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.
We may also share your personal information with law enforcement and regulatory agencies (including the Charity Commission) when appropriate or required to do so.
Personal information about other people that you provide to us
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and that:
- They have given their consent for their details to be passed to us;
Keeping your personal information safe
We will use technical and organisational measures to safeguard your personal information, for example:
by delivering data protection training to our staff;
by ensuring the physical security of our offices and other sites;
by limiting access to your personal information to those in our organisation who need to use it in the course of their work;
our IT systems are protected by firewalls; regular software updates; anti-virus protections and intrusion detection systems; and
we store your personal information on secure servers located in the UK and Europe.
While we will use all reasonable efforts to safeguard your personal information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see 'How can you contact us?' below).
Transferring your personal information abroad
We do not intend to transfer your personal information outside the EEA. If we believe a transfer of your personal information outside of the EEA will arise, we will implement contractual or other measures to comply with legal requirements on the transfer of personal information, ensuring that there is an adequate level of protection in place.
Where you are located outside the EEA then we will transfer your personal information to the UK and Europe where our systems and servers are located. This will naturally entail your personal information being exported back out to the jurisdiction that it originated from or from where you are located (for example when we reply to your emails or we write to you).
How long will we keep your personal information for?
Your personal information will be deleted when it is no longer reasonably required for the relevant purposes and we are not legally required or otherwise permitted to continue storing such information. The Berkeley Foundation will, in particular, retain your personal information where required for us to assert or defend legal claims until the end of the relevant retention period or until the claims in question have been settled.
Your rights in relation to your personal information
Subject to certain legal conditions, you have a number of rights in relation to the personal information that we hold about you. These include:
The right to request a copy of the information we hold about you;
The right to be informed of the ways in which we use your information, as we seek to do in this Policy;
The right to correct any mistakes in your information or information which is out of date;
The right to erase certain information;
The right to request a restriction of the processing of your information;
The right to ask us not to process your personal data for marketing purposes;
The right to object to certain information and automated decisions being processed;
The right to withdraw your consent where we have requested it; and
The right to transferring your personal information in a structured file (data portability).
Should you wish to exercise any of your rights, please contact us directly (see 'How can you contact us?' below) and we will be happy to assist.
Please note that we may ask for proof of your identity and address (such as a copy of your driving licence or passport - please do not send any original documents).
Additionally, you should be aware that not all of these rights are absolute and there may be circumstances in which we will not fully comply with your request because of a specified legal ground or exemption. For example, you will not be able to request that we delete all of your information if you have entered into a contract with us because it will be necessary for the contract you have entered into. We will always let you know the legal basis for this.
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your information, and for any additional copies of the personal information you request from us.
This policy was last updated on 30 May 2018.
How to contact us
If you want to contact us to know more about the use of your information, ask us to correct it, or to exercise any of your rights, please contact us by email using firstname.lastname@example.org. We will endeavour to send you a response as soon as possible. Your patience is much appreciated during busy periods.
Your right to lodge a complaint
You have the right to complain to the UK Information Commissioner's Office (ICO) (as well the relevant authority in your country of work or residence) if you believe we have not handled your request in an appropriate manner. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
For information on contacting the ICO please see their website at https://ico.org.uk/.