Surrey Federation of Womens Institutes, a company limited by guarantee registered in England and Wales under number 02836301 which is also a charity registered with the Charity Commission for England and Wales under number 1026988, whose registered address is at 6 Paris, Parklands, Railton Road, Guildford, Surrey, GU2 9JX (the Charity) processes your Personal Data in accordance with the General Data Protection Regulation (the GDPR) and the information set out in this Subject Information Statement.
1. Background
1.1. The Charity is the federated organisation which is responsible for the operation and management of the WI in Surrey, its members are the individual WIs in Surrey and south-west London, its overall charitable purpose is the education of women.
1.2. The purpose of this Subject Information Statement is to provide information to individuals whose Personal Data are Processed by the Charity as donors.
1.3. This statement applies to all individuals who are donors to the Charity.
2. Purposes and Legal Basis
2.1. The Charity Processes your Personal Data and, where you have provided it, your Special Categories of Personal Data, for the following purposes:
2.1.1. acknowledging and processing any donations made by you;
2.1.2. providing you with information about the activities of the Charity and its partners;
2.1.3. administration in relation to the support that you provide to the Charity;
2.1.4. statutory and regulatory compliance;
2.1.5. processing any enquiries or complaints raised by you and responding to any communications from you;
2.1.6. transferring to third parties with whom we have a relationship;
2.1.7. transferring your Personal Data to HMRC in respect of any Gift Aid claims; and
2.1.8. sending electronic communications to you keeping you informed about the activities falling into any of the above categories.
2.2. The legal basis on which the above Processing takes place is the legitimate interests shared by SVP and you as set out below.
2.3. The legitimate interests which permit the Processing set out above to take place are:
2.3.1. you have made a donation to the Charity and as a result have shown a willingness to support the work of the Charity;
2.3.2. the need to comply with regulatory requirements in relation to your donation, for example, the need to keep donation records for a minimum of seven years for accounting purposes;
2.3.3. that the Processing is reasonable in relation to the activities to which they relate;
2.3.4. the Processing is such as you would reasonably expect to be undertaken by the Charity in respect of the management of your donation;
2.3.5. that the Processing is necessary in respect of the activities that are undertaken and is in the interests of SVP and the relevant third parties and does not limit your interests or fundamental freedoms guaranteed by the GDPR;
2.3.6. that if you sought to terminate your consent to the Charity Processing your Personal Data, we would still be required to retain information on your donation for at least seven years, meaning that consent is not freely available.
2.4. When making your donation to the Charity you created a relationship between us. Where you did not opt out of receiving electronic communications from us, we have treated your action as consent to send you communications electronically (commonly called “a soft opt in”). As the legal basis of the processing SVP undertakes in relation to electronic communications is your consent, please note that you may withdraw this consent at any time. Should you withdraw your consent SVP shall cease to send you electronic marketing information. You may revoke your consent to receive such updates by changing your preferences with an email to info@surreyfedwi.org.uk or by using the unsubscribe function included in each communication.
2.5. You may notify us at any time if you wish us to stop contacting you. We will stop all further contact; however, we will be required to continue to Process your Personal Data in relation to any donation made by you until the period where we are required to keep donor information. This is seven years from the date of the final donation was made.
3. Source
3.1. You are the source of all of the Personal Data about you which we Process.
4. Recipients
4.1. The Charity may transfer your Personal Data to the following organisations or category of organisations:
4.1.1. the National Federation of Womens Institutes (NFWI);
4.1.2. local WIs; and
4.1.3. central and local government and their agencies;
4.1.4. HMRC.
5. International Transfers
5.1. It is the intention of the Charity that your Personal Data will remain within the UK, the countries forming the European Economic Area (the EEA) and countries where the European Union has decided that the country has adequate data protection laws in line with those in the European Union.
5.2. Your Personal Data will only be transferred outside of the UK, EEA or a country which has been declared as having adequate data protection laws where:
5.2.1. the transfer is necessary for the performance of any contract with you;
5.2.2. you have entered the information into our Website and the information has been transmitted from your server to our server using systems based outside of the EEA;
5.2.3. we have entered into an appropriate contract protecting your rights and freedoms, which is enforceable by you or the data protection authorities; or
5.2.4. we have obtained your explicit consent.
6. Storage
6.1. We will generally store the Personal Data that we hold in relation to you for the duration of our relationship with you and for seven years after that relationship ends.
7. Your Rights
7.1. You have a right to obtain from the Charity conformation as to whether or not your Personal Data are being Processed and, if your Personal Data are being Processed by the Charity, to access the Personal Data and the specific information set out in Article 15 of the GDPR. To access your Personal Data please contact info@surreyfedwi.org.uk. Please note that we will not provide any Personal Data to you until you have provided evidence to us to establish your identity. This may include a copy of your passport or other identification document. We will only provide information to you at an address which we have verified as belonging to you.
7.2. You have a right to rectification of any inaccurate Personal Data which we Process about you, or where Personal Data is incomplete to have the information completed. To obtain rectification or completion, you will need to provide the correct information to the Charity. An explanation of why you believe the information is inaccurate or incomplete would also be of assistance.
7.3. Where certain grounds, as set out in Article 17(1) of the GDPR, apply, you will be entitled to have the Charity erase certain Personal Data relating to you. Where you wish to exercise your right of erasure, please contact info@surreyfedwi.org.uk setting out the grounds under which you would like the Personal Data the Charity holds about you erased.
7.4. Where certain grounds, as set out in Article 12(1) of the GDPR, apply, you will be entitled to have the Charity restrict the Processing of certain Personal Data relating to you. Where you wish to exercise your right to restrict Processing, please contact info@surreyfedwi.org.uk setting out the grounds under which you would like the Personal Data the Charity holds about you restricted.
7.5. In certain circumstances, where the legal basis of the Processing undertaken by the Charity is “consent”, you have a right to request the Charity transfers your Personal Data to a third party. If you wish to exercise your right to data portability, please contact info@surreyfedwi.org.uk.
8. Complaints
8.1. If you have any complaint about the Processing of your Personal Data undertaken by the Charity, please contact info@surreyfedwi.org.uk.
8.2. Please note that you have a right to lodge any complaint about the Processing of your Personal Data by the Charity by contacting the Information Commissioner’s Office.
8.3. The Charity is not required to have a data protection officer under the GDPR and one has not been appointed, therefore please address all communications in relation to Personal Data to info@surreyfedwi.org.uk.
9. Definitions
9.1. The following terms have the following meaning in this Statement:
9.1.1. Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
9.1.2. Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
9.1.3. Special Categories of Personal Data means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
10. Contact
10.1. The Charity can be contacted:
10.1.1. in writing at SWFI, 6 Paris Parklands, Railton Road, Guildford, Surrey, GU2 9JX;
10.1.2. by email at info@surreyfedwi.org.uk; or
10.1.3. by telephone by calling 01483 233230.
11. Further Information
11.1. It is not intended that the Charity will undertaking any further Processing of your Personal Data other than that which is set out in this Statement. However, if this position does change, the Charity will provide you with further information.
11.2. This Statement was last updated on 14 June 2020.
