At The Valley Trust we are committed to protecting your personal data and being open and transparent about how we store and use your personal information.
For the purpose of Article 6 of the General data protection Regulations (GDPR) the data controller is The Valley Trust, of Meadow View, Tannery Lane, Bramley, Surrey, GU5 0AJ.
Who are we?
The Valley Trust is a registered charity (no. 293983) which focuses its work on providing professional independent counselling to children in the school environment. We assist them to recognise, confront and resolve or come to terms with a range of difficulties in their lives – for example, family breakdown, abuse, bullying, bereavement and loss, depression and other mental health issues, and identity issues. We thereby to help them to achieve emotional stability, greater self-esteem and improved performance at school and at home.
Lawful bases for collecting your data
The Valley Trust, like all organisations in the European Union, needs a lawful basis to collect and use your personal data. Under article 6 of General Data Protection Regulation (GDPR), there are six lawful grounds for processing data, of which the following are more relevant to The Valley Trust’s activities:
- Consent: where an individual has given us clear consent to process personal data e.g. when we have obtained your consent to contact you by email, phone or SMS.
- Contract: the processing is necessary for a contract we have with an individual e.g. contracts of employment we have staff or counsellors.
- Legal obligation: the processing is necessary for us to comply with the law e.g. we are legally required to hold donor transaction details for Gift Aid and accounting/tax purposes.
How do we obtain your personal information?
We collect personal Information from you when you interact with The Valley Trust, for example this could be when you:
- Apply for a job
- Apply for a role as a self-employed counsellor or supervisor
- Apply for a role as Trustee
- Make an enquiry
- Make a complaint
- Support our work by donating
- Contact us or become involved with us in any other way not listed above
What information do we collect?
When you communicate with us we may collect ‘personal information’. This may include your name, address, email address, telephone numbers, and bank account details.
We may collect other personal details, based on the services sought from The Valley Trust. If you contact us, we may keep a record of that correspondence.
In August 2016, the EU-US Privacy Shield framework came into effect, which “protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield.” – European Commission website.
However, after the Court of Justice of the European Union (CJEU) ruling of 16 July 2020, this Privacy Shield framework became invalidated due to significant differences between EU and US privacy laws. To date, a workable alternative has not been developed or deployed by US tech companies like Google or Facebook for EU citizens.
As a result, you should be aware that currently, Google analytics data from statistics cookies will be processed in the United States under less strict privacy laws with all the associated risks of sending the data to the US with who can access it (for example the US government).
You have the right to withdraw your consent to this international transfer of google analytics data to the US at any time by clicking cookie preferences.
Sensitive Personal Information
Data protection law recognises certain categories of personal information as being more sensitive. They are referred to as ‘sensitive personal data’. Under GDPR they are known as ‘special categories of personal information’ and cover racial and ethnic information, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data and health information.
The Valley Trust does not collect sensitive personal data. However, if it ever became necessary to do so, before collecting any sensitive personal information about you, we will make it clear what information we are collecting and why we need it.
All sensitive personal data would be stored on a secure database, to which only a limited number of relevant staff would have access. It will be deleted when no longer relevant, never shared with third parties, and available to you at any point should you wish to see it.
How do we use your information?
We will use your information for the following purposes:
- Process a job or counselling application
- Staff administration
- Complying with our legal obligations, policies and procedures
- To carry out our obligations arising from any contracts entered into between you and us
- Providing you information about our activities and services
- Responding to your enquiries and complaints
- Processing your donations
Who do we share your information with?
We only share your information with third parties who have a legitimate need for it, e.g. schools at which we proved a counselling service.
These third parties are subject to contractual obligations containing strict data protection agreements, on the conditions of confidentiality and security. We will take all reasonable care to ensure that they keep your data secure.
We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant and lawful request in writing).
How we keep your information up to date
We are dependent on you to keep our data current, and we therefore really appreciate it if you let us know whenever your contact details change.
How long will we keep your information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity. This may be laid down by law (e.g. HMRC PAYE and National Insurance data).
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to contact you.
How do we protect your information?
We hold your information in our office, where it is only accessible by our Co-ordinator and one Trustee. We hold hard copies in a locked filing cabinet, and soft copies are only held on the computers in the office, which are password-protected.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our web site, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.
Despite all of our precautions, no data transmission over the internet can be guaranteed to be 100% secure. Therefore, while we strive to protect your personal information using strict procedures and security features to prevent unauthorised access, we cannot guarantee the security of any information you disclose to us online, and you must understand that you do so at your own risk.
The Valley Trust does not hold any personal data about any of the children who receive counselling from our self-employed counsellors. Our counsellors hold all such data directly. We require them to ensure that they properly protect this data at all times, and they typically will agree their procedures with each school at which they work.
Accessing and updating your personal information
The General Data Protection Regulations give you the following individual rights:
- Right to be informed about the information we hold and what we do with it.
- Right to access copies of the personal information that The Valley Trust holds about you.
- Right to rectification, should there be errors or changes to your data.
- Right to erasure, such that The Valley Trust stops using and removes your personal information (except if overridden by legal obligations).
- Right to restrict processing.
- Right to data portability.
- Right to object.
- Rights related to automated decision-making including profiling.
More information on your rights is available from the Information Commissioner’s Office.
You can request access to any information we hold about you by contacting us at The Valley Trust, Meadow View, Tannery Lane, Bramley, Surrey, GU5 0AJ, emailing firstname.lastname@example.org or calling 01483 898637. We may make a small charge to cover the administrative costs involved in providing the data requested.
You have the right to request that we delete data if its retention is no longer necessary in relation to the purpose for which it was originally collected. In such cases we undertake to ensure that the data is deleted within 30 days.
Your personal preferences and keeping your data accurate are of utmost importance to us. If at any stage you do not want to hear from us or want to update your details you can write, email or call us on the contact details shared above.