This Policy sets out how the Equestrian Order of the Holy Sepulchre of Jerusalem ‘we’ processes personal information through the use of this website (other than the members area). It explains how we use your personal data and how we treat it. The data controller of personal information for these purposes is the Chancellor, The Order of the Holy Sepulchre (Lieutenancy of England and Wales), (Charity Number 262033).
What information might this website collect?
Many websites obtain information through ‘cookies’ which are created by a web-browser upon using a website. These can address matters such as the usage of the website, personal preferences and for ‘targeting’ or ‘advertising’.
Such cookies as are required by your browser or the website may be created by or during its use and remain on it. These cookies are necessary for the operation of the website and we do not use such cookies to collect analytical data upon its users (outside of the members portal) save as is provided for below.
What personal data might we collect?
Personal information may be obtained, held and processed by the Order if when using the website:
- You contact us through the ‘contact us’ form
- Make a donation
By using the ‘contact’ facility or the ‘donate’ facility, you consent to the processing of data for those (and related) purposes.
We may collect information from you including:
- Your full name, and title(s)
- Your full postal address
- Your telephone and/or mobile number(s)
- Your email address(es)
- Any means of contact via social media.
How do we use data obtained?
To record contact we have with you.
To fulfil your requests in correspondence.
To process donations and audit, record and/or verify financial transactions (including such submissions to HMRC as are required within the ‘Gift Aid’ Scheme).
Conditions for using personal data
We do so through consent (including by use of the website), by contract, by legal obligation or by legitimate interest.
Who do we provide this data to?
The Trustees of the Order
Any person appointed by the Order to process your request or donation.
HMRC or any government authority with a lawful basis to do so.
To a third party if subject to a legal obligation, or if we believe it is necessary to protect and defend the rights property or safety of the Order or its members.
How long do we retain such data?
In the event of ‘contact’ the information is held for the purposes of responding and recording the reply. Unless required for a statutory purpose such records will be held no longer than 3 years from the inquiry being completed. (Where the inquiry forms a chain of correspondence, the latest date will apply).
In the event of a donation, the information obtained or provided to the Order is held for the purposes of accounting for and complying with charitable and audit regulatory requirements (including anti-money laundering, taxation and/or Gift Aid purposes). Such records are held for 10 years after the tax period to which the donation relates or in which the Gift Aid is reclaimed. Where external platforms such as ‘Paypal’ or ‘Donr’ (for example) are used to facilitate payment, those third parties obtain and provide data in accordance with their own policies.
Processing in relation to donations is only undertaken by or under the supervision of the Treasurer of the Order and is subject to reviewed by the Officers of the Order.
Other than is necessary for the purposes of dealing with donations, personal data obtained is not shared with any external third party or provided to them for commercial gain or other benefit from processing.
Processing in relation to ‘contact’ is dealt with by an appointed member of the Order.
The data held in this context (other than that relating to donation) is reviewed every year, and disposed of within 56 days of the retention period expiring.
How do we hold such data?
Data is held securely. Access to such information is restricted to those who have a need to access it for the performance of a function related to it for the purposes of the Order.
Where this website contains a link to a third-party website or service, those third-party websites or services may collect hold process or retain information in accordance with their own policy and settings. This may include the collection of personal information for processing beyond the scope of that undertaken by the Order.
Your rights include a right of access; a right of rectification; a right of objection; the right to restrict processing; to withdraw consent; to make your data ‘portable’ and to complain.
Right of access:
Where your personal data has been obtained and processed by the Order you have the right to apply for that data, and information about how it was processed. This is not subject to a charge unless that is permitted by law, and, there are conditions in which we may refuse to provide such information. If this is the case, we will advise you of the reason.
Right of rectification:
You may ask for information held by us to be corrected if it is inaccurate or incomplete.
Right of objection:
Where we have obtained consent to process personal data, this may be withdrawn by you at any time and unless we consider that there is an alternative legal basis upon which such data is to be held or processed that processing will cease. If we consider there is an alternative basis for processing we will advise you of this.
Right of restriction:
If your data is provided for more than one purpose you may seek to have those purpose(s) limited, and, provided that there is no alternative basis for us to continue processing, we will do so. In the event that we rely on an alternative basis for processing we will advise you of this.
Right to withdraw consent:
Where we have obtained your agreement to process personal data you may withdraw it. Provided that there is no alternative basis upon which we seek to (or are obliged to) process or hold such data when consent it is withdrawn, processing will cease. Should we consider that there is an alternative basis for processing we will advise you of this.
This right allows you to use your personal information for your own purposes across different services where data has been obtained by consent or to perform a contract, and processing is carried out by automated means. We have not identified that this attaches to any data processing undertaken by the Order. Should it be otherwise, such data will be provided as is required by law.
Should you wish to complain about the way in which your personal data is handled you have the right to lodge a complaint with us. Please use the ‘contact us’ form on the website to do so.
To complain to the Information Commissioner’s Office which can be contacted in the following ways:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113