Privacy Policy

The Froebel Trust is the Data Controller and is committed to protecting the rights of individuals in line with the Data Protection Act 2018 (DPA) and the new General Data Protection Regulation (GDPR).

This Privacy Notice explains what information we collect about you, how we may use it and the steps we take to ensure it is kept secure. It also explains your rights and how to contact us. The Froebel Trust is registered with the Information Commissioner’s Office (ICO) as a body which processes Personal Data.

What information do we collect about you?

We may collect Personal Data from you when you request a publication, subscribe to a service or fill in an application or form we provide. We may also collect information through e-mail, telephone conversations and other written and verbal communications. We may also collect Personal Data through taking photographs at events. We may supplement the information you provide with other information we obtain in relation to our contact with you.

How will your information be used?

We will use the personal information we have gathered in our normal course of business primarily to assess any applications you make and to provide publications you have requested as well as for administration purposes including:

• To confirm your identity and communicate with you regarding an application
• To process applications and administer grants/awards
• For record keeping for the purposes of audit and evaluation

• To monitor the fairness of and trends in application decisions
• To track activity on our website
• To provide publications you have requested
• To provide support services and supply operational information
• To publish details and outcomes of successful grant/award applications
• To contact you about Trust activities and events or to help inform or evaluate these activities and events, Trust application processes and policy work
• To promote Trust activities on our website through use of photographs.

We may contact you by post, email or telephone for these purposes in accordance with any communications preferences you have notified us of. The Froebel Trust may also anonymise your Personal Data and use it for research and statistical purposes.

What is our legal basis for Processing your personal data?

Where you have requested a publication or subscription, you have given us explicit Consent to hold this data for this purpose. For applications to The Trust, Processing of the data is necessary for the assessment and performance of the contract we are about to enter or have entered into with you. We are also required in certain circumstances to hold this data for compliance with a legal or regulatory obligation. We may also use your Personal Data where this is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where our only reason for holding your data is on the basis of Consent, you may withdraw this Consent at any time by contacting us at the address below.

Who has access to your information?

Your personal information may be disclosed only to individuals and organisations connected with The Froebel Trust for the purpose of independent audit, evaluation/assessment of activities funded by grants/awards and their outputs and outcomes. Some of these organisations may be based outside the EEA. All personal data will be stored and used by or on behalf of the Froebel Trust in accordance with Data Protection regulations. Where we transfer your personal data out of the EEA, and we are not transferring your personal data to countries that have been deemed to provide an adequate level of protection for the personal data, or implementing specific safeguards for the transfer of this personal data, we will inform you of the transfer of your personal data, the risks involved and seek your specific consent to the transfer.

Please contact us at the below details if you want further information on the transfer of your personal data out of the EEA.

The Trust may publish or allow to be published details of the recipients of successful grants/awards and their outputs on the Trust’s website including your name, employing organisation, project title, a summary of the grant/award and its value and, in the case of grants/awards funding research, scientific/academic abstracts and lay summaries of research (e.g. via the internet or via publicly accessible databases or other publications, some of which may be accessible from outside the EU).

How long will your information be held?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If we hold your data on the basis of Consent, we will continue to hold it until your Consent is withdrawn, we believe the data to be inaccurate or it is no longer needed for the purpose Consent was obtained. If we hold your data through application or as part of service providing, your data will be held only as required as part of the normal course of our business and to meet legal obligations regarding retention periods for application and financial data.

Details of retention periods for different aspects of your personal data are available in our data retention schedule which you can request from us by contacting us.

Amendments

We may update this policy from time to time by publishing a new version on our website www.froebel.org.uk

Your Rights

You have a right to:

Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Any requests or objections should be made in writing to:

The Froebel Trust

Clarence Lodge

Clarence Lane

London

SW15 5JW

E: sacha@froebeltrust.org.uk

Security of your information

The Froebel Trust will always strive to ensure the security of your Personal Data and carries out regular reviews of both physical and electronic data storage to ensure your data is secure. In the unlikely event that any breach of the security of your data is discovered, we will notify you either in writing or by e-mail within 14 days of discovery.

How to make a complaint

If you are unhappy with the way in which your Personal Data has been Processed you may in the first instance contact the Communications Manager using the contact details above.

If you remain dissatisfied then you have the right to make a complaint directly to the Information Commissioner. The Information Commissioner can be contacted at:

Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire,

SK9 5AF

www.ico.org.uk