PRIVACY & GDPR NOTICE

This Privacy & GDPR Notice governs the manner in which Nottingham Municipal Charities and its sub-charities, Bilby’s & Cooper’s Relief in Need Charity and Sir Thomas White’s Loan Charity, collects, uses, maintains, disposes and discloses data collected from our prospective applicants, current and former borrowers and other individuals (each, a “User”) of Nottingham Municipal Charities and its sub-charities.

Introduction

Nottingham Municipal Charities and its sub-charities and its trustees and employees take the privacy of our Users very seriously.  All data processed by Nottingham Municipal Charities is done so in accordance with the Data Protection Act 1998 and the General Data Protection Regulations (GDPR).

The purpose of this Notice is to inform you of the following:

• Our privacy promise
• Data we collect
• How we collect your data
• How we use or disclose your data
• How we store your data
• Rights of data subjects
• Contacting us

Our privacy promise

We promise:

• To keep your data safe
• Not to sell your data

Data we collect

In the course of our business, primarily the provision of loans and grants, we collect personal and sensitive personal data including:

• Personal data – such as name and title, gender, date of birth
• Sensitive personal data – such as ethnicity
• Contact data – such as postal address, email address, telephone and mobile numbers
• Identification data and copy documentation – such as passport, driving license, proof of qualifications, proof of address, National Insurance Number
• Biographical data – such as academic and other results, institutions attended, employment history
• Financial data – such as bank account details and credit check information
• Transaction data – such as feedback and survey responses
• Any other data you may provide

Data may be collected from you at different times during your interaction and engagement with us and not all your data will be collected or held on every individual who interacts and engages with us.

How we collect your data

We obtain personal data from a variety of sources, as follows:

• Directly from you when you interact with us, for example when you
• Request an application pack
• Submit an application
• Apply for a loan or grant
• Are granted a loan
• Are approved for a grant
• Write to us, including by email
• From an applicant, borrower or third party, for example
• When an applicant submits personal details for prospective guarantors
• When a borrower provides, confirms or updates personal details for guarantors
• When conducting an anti-money laundering and credit check on an applicant or prospective guarantor
• When a third party such as social services or any other government agency, charity or other institution provides personal details for the purposes of obtaining a grant or loan for an individual

How we may use or disclose your data

We may use your personal data for a number of reasons, depending on the reasons for submitting to us/ for us collecting the data.  To process your personal data, we must have a lawful basis and these are listed below:

• Legitimate interests – we process your personal data for our legitimate interests and these include the following
• To conduct and manage our business, primarily but not limited to the provision of loans and grants
• To analyse, improve and update our processes and services for the benefit of our applicants, borrowers and grant recipients
• To deal with and respond to complaints
• Consent – we process your personal data where you have given us specific consent to do so
• Contract – we may process your personal data where there is a contractual obligation
• Legal obligation – we may process your personal data in order to comply with applicable laws

Most commonly we will use your personal data in the following circumstances:

• Prospective applicants – to provide you with an application pack
• Applicants and guarantors – to process the application including credit and anti-money laundering checks
• Borrowers – to process your loan, including payments, missed payments and confirmation of bank details and for ongoing purposes including visits, changes to guarantors etc
• Guarantors – to contact you to ensure your details are up to date and in the event of a loan being recalled or payments being missed by the borrower
• Grant applicants – to process your grant, including arrangement for the delivery of goods or services
• If it is necessary for our legitimate interests and these are not overridden by your own rights or interests
• Where we need to comply with a legal, regulatory or contractual obligation

We may disclose and share your personal data to the following recipients for the purposes set out in this notice:

• Email and mail service providers
• Our Trustees, employees and contractors
• Technical and support partners, such as the companies who host our website, provide financial, technical, legal and other back-up services
• Government, public or law enforcement agencies or officials, regulators or any other person or entity who has the appropriate legal authority
• Any other parties where we have your specific consent to do so

How we store your data

WE take the security of your data seriously.  Only authorised Nottingham Municipal Charities trustees, employees and third parties processing data on our behalf have access to your personal data.  We take all reasonable steps to keep your data secure.  This includes storing data in locked filing cabinets and an alarm protected office and ensuring computer access is controlled through the use of individual computer logins, where passwords are regularly changed.

We consider the personal data we store and we will not store your information in a form which identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law.  All businesses must keep personnel and financial records in order to run their business efficiently and to comply with statutory requirements.  As such, how long we store your data for will depend on the nature of the data, your relationship with us and whether we have statutory or lawful requirements to continue to store the data.

Rights of data subjects

As a data subject you have a number of rights.  These include the following:

• Rights to be informed
• Right of access
• Right to rectification of errors in personal data
• Right of erasure
• Right to restrict or object to processing
• Right to data portability

Contacting us

If you have any questions about this Privacy & GDPR Notice please contact us at:

Nottingham Municipal Charities, c/o Ellis-Fermor & Negus, 2 Devonshire Avenue, Beeston, Nottingham NG1 3BE

Tel: 0115 9221591

Reg. Charity Number: 215185