Privacy Policy
1. Purpose
Hampshire Cultural Trust is committed to protecting the privacy and security of your personal
information.
This privacy notice describes how we collect and use personal information about you during and
after your volunteering relationship with us, in accordance with the UK General Data Protection
Regulation (UK GDPR). It applies to all volunteers.
Hampshire Cultural Trust is a “data controller”. This means that we are responsible for deciding how
we hold and use personal information about you. We are required under data protection legislation
to notify you of the information contained in this privacy notice.
2. Scope
This notice applies to current and former volunteers. This notice does not form part of any
volunteering agreement or other contract to provide services. We may update this notice at any
time. Nothing in this agreement shall affect the status of a volunteer or render them an employee or
worker of Hampshire Cultural Trust.
It is important that you read this notice, together with any other privacy notice we may provide on
specific occasions when we are collecting or processing personal information about you, so that you
are aware of how and why we are using such information and what your rights are under the data
protection legislation.
3. Data protection principles
We will comply with data protection law. This says that the personal information we hold about you
must be:
▪ Used lawfully, fairly and in a transparent way.
▪ Collected only for valid purposes that we have clearly explained to you and not used in any
way that is incompatible with those purposes.
▪ Relevant to the purposes we have told you about and limited only to those purposes.
▪ Accurate and kept up to date.
▪ Kept only as long as necessary for the purposes we have told you about.
▪ Kept securely.
4. The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).
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There are “special categories” of more sensitive personal data which require a higher level of
protection, such as information about a person's health or sexual orientation. Information about
criminal convictions also warrants this higher level of protection. These are referred to separately in
this privacy notice.
We may collect, store, and use the following categories of personal information about you:
▪ Personal contact details such as name, title, addresses, telephone numbers, and personal
email addresses.
▪ Date of birth.
▪ Gender.
▪ Marital status and dependants.
▪ Next of kin and emergency contact information.
▪ National Insurance number.
▪ Bank account details, where required for the payment of expenses.
▪ Information relating to claims for expenses.
▪ Qualifications, training certificates and other skills or educational certificates.
▪ Initial volunteering date.
▪ Location of volunteering.
▪ Information relating to your ability to volunteer.
▪ Details of any training that you undertake as a volunteer.
▪ Copy of driving licence, driving insurance and MOT information.
▪ Photographs.
▪ If applicable, results of HMRC employment status check, details of your interest in and
connection with the intermediary through which your services are supplied.
We may also collect, store and use the following “special categories” of more sensitive personal
information:
▪ Information about your race or ethnicity, religious beliefs and sexual orientation.
▪ Information about your health, including any medical condition that you voluntarily supply
to us, for example when providing details of any periods where you were unable to
volunteer due to ill health.
▪ Information about criminal convictions and offences.
5. How is your personal information collected?
We typically collect personal information about employees, volunteers, workers and contactors
through the application and recruitment process, either directly from candidates or sometimes from
an employment agency or background check provider. We may sometimes collect additional
information from third parties including former employers, credit reference agencies or other
background check agencies.
We will collect additional personal information in the course of job-related activities throughout the
period of you volunteering for us.
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6. How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use
your personal information in the following circumstances:
▪ Where we need to perform the contract we have entered into with you.
▪ Where we need to comply with a legal obligation.
▪ Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
▪ Where we need to protect your interests (or someone else’s interests).
▪ Where it is needed in the public interest or for official purposes.
6.1. Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our
contract with you and to enable us to comply with legal obligations. In some cases we may use your
personal information to pursue legitimate interests of our own or those of third parties, provided
your interests and fundamental rights do not override those interests. The situations in which we
will process your personal information are listed below.
▪ Making a decision about your request to volunteer with us, making decisions about your
continued engagement, making arrangements for the termination of our volunteering
relationship, and, if applicable, providing volunteer benefits to you.
▪ Determining the terms of your volunteering agreement.
▪ Making payment to you of properly claimed expenses.
▪ Administering the volunteering agreement we have entered into with you.
▪ Business management and planning.
▪ Assessing suitability for a particular volunteering opportunity or task.
▪ Education, training and development requirements.
▪ Dealing with legal disputes involving you, other volunteers, employees, workers and
contractors, including accidents at work.
▪ Complying with health and safety obligations.
▪ To monitor your use of our information and communication systems to ensure compliance
with our IT policies.
▪ To ensure network and information security, including preventing unauthorised access to
our computer and electronic communications systems and preventing malicious software
distribution.
Some of the above grounds for processing will overlap and there may be several grounds which
justify our use of your personal information.
6.2. Providing information regarding your family members
We will ask you to provide personal contact information relating to your family members or other
individuals, for example, for the purposes of collecting emergency contact details. By providing these
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details to us you are confirming that you have the relevant individual's consent to provide such
information to us and for us to process this in accordance with this Privacy Notice.
6.3. If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the
contract we have entered into with you (such as paying you or providing a benefit), or we may be
prevented from complying with our legal obligations (such as to ensure the health and safety of our
workers and volunteers).
6.4. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with
the original purpose. If we need to use your personal information for an unrelated purpose, we will
notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
7. How we use particularly sensitive personal information
”Special categories” of particularly sensitive personal information, such as information about your
health, require higher levels of protection. We need to have further justification for collecting,
storing and using this type of personal information. We have in place an appropriate policy
document and safeguard which are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
▪ In limited circumstances, with your explicit written consent.
▪ Where we need to carry out our legal obligations.
Less commonly, we may process this type of information where it is needed in relation to legal
claims or where it is needed to protect your interests (or someone else’s interests) and you are not
capable of giving your consent, or where you have already made the information public.
7.1. Our obligations
In general, we will not process particularly sensitive personal information about you unless it is
necessary for performing or exercising obligations or rights in connection with your volunteering. On
rare occasions, there may be other reasons for processing, such as it is in the public interest to do so.
The situations in which we will process your particularly sensitive personal information are listed
below.
We will use your particularly sensitive personal information in the following ways:
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▪ We will use information relating to any medical condition that you voluntarily supply to us,
for example when providing details of any periods where you were unable to volunteer due
to ill health.
▪ We may use information you voluntarily supply to us about your physical or mental health,
or disability status, to ensure your health and safety at our premises.
7.2. Do we need your consent?
We do not need your consent if we use special categories of your personal information in
accordance with our written policy to carry out our legal obligations or exercise specific rights in the
field of employment law.
In limited circumstances, we may approach you for your written consent to allow us to process
certain particularly sensitive data. If we do so, we will provide you with full details of the information
that we would like and the reason we need it, so that you can carefully consider whether you wish to
consent. You should be aware that it is not a condition of your contract with us that you agree to any
request for consent from us.
We do not need your consent where the purpose of the processing is to protect you or another
person from harm or to protect your well-being and if we reasonably believe that you need care and
support, are at risk of harm and are unable to protect yourself.
8. Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This
will usually be where such processing is necessary to carry out our obligations and provided, we do
so in line with the Trust’s Data Protection Policy.
We envisage that we will hold information about criminal convictions.
We will only collect information about criminal convictions if it is appropriate given the nature of the
role and where we are legally able to do so. Where appropriate, we will collect information about
criminal convictions as part of the recruitment process or we may be notified of such information
directly by you in the course of you volunteering for us. We will use information about criminal
convictions and offences to assess your suitability for your placement.
We will use information about criminal convictions and offences in the following ways:
▪ During the recruitment process, where information regarding criminal convictions or a
disclosure and barring check is legally required due to the nature of the role.
▪ During the recruitment process or during volunteering where you are assigned to volunter in
any environment where information regarding criminal convictions or a disclosure and
barring check is required by law or considered necessary for our legitimate interests and
your interests and fundamental rights do not override those interest. In this situation we will
request your specific consent to us processing this information.
▪ We may be notified of such information directly by you in the course of you volunteering for
us.
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We are allowed to use your personal information in this way to carry out our legal obligations as an
employer and, where appropriate, for our legitimate interests. We have in place an appropriate
policy and safeguards which we are required by law to maintain when processing such data.
9. Automated decision-making
We do not envisage that any decisions will be taken about you using automated means, however we
will notify you in writing if this position changes.
10. Data sharing
We may have to share your data with third parties, including third-party service providers and other
entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the
law.
10.1. Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is
necessary to administer the volunteering relationship with you or where we have another legitimate
interest in doing so.
We may also share your personal information with third parties after your volunteering ends in the
context of responding to reference requests in accordance with our Reference Policy. All reference
requests must be addressed to the People Team.
10.2. Which third-party service providers process my personal information?
”Third parties” includes third-party service providers (including contractors and designated agents)
and other entities within our group. The following activities are carried out by third-parties: payroll,
pension administration, marketing, fundraising and promotional activities, criminal record checks,
background checks, credit reference checks, benefits provision and administration, and the provision
of IT, occupational health, financial, legal and Human Resources/ People Team services.
10.3. How secure is my information with third-party service providers and
other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate
security measures to protect your personal information in line with our policies. We do not allow our
third-party service providers to use your personal data for their own purposes. We only permit them
to process your personal data for specified purposes and in accordance with our instructions.
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10.4. What about other third parties?
We may share your personal information with other third parties, for example in the context of the
possible sale or restructuring of the business. In this situation we will, so far as possible, minimise
the amount of information we share and use anonymised data where possible.
We may also need to share your personal information with a regulator, or to otherwise comply with
the law. This may include, but is not limited to, making returns to HMRC, disclosures to regulators
and disclosures to shareholders, such as directors' remuneration reporting requirements.
10.5. Transferring information outside the UK
We do not anticipate transferring your information outside of the UK. If we do, you can expect a
similar degree of protection in respect of your personal information.
We are aware that due to its operating arrangements, the third-party HR provider which we use is
hosted within the European Economic Area. The provider has confirmed that it is fully compliant
with UK and EU GDPR data protection legislation. The DBS check provider has measures in place and
will take all reasonable steps necessary to ensure that the data is treated securely and in accordance
with their data protection obligations.
11. Data security
We have put in place appropriate security measures to prevent your personal information from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal information to those workers, volunteers, employees, agents,
contractors and other third parties who have a business need to know. They will only process your
personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.
12. Data retention
12.1. How long will you use my information for?
We will only retain your personal information 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.
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Subject at all times to our duty to minimise the data we store and subject to compliance with our
legal obligations and legitimate interests of the Trust, we envisage that we shall store personal data
about individuals for no longer than 6 years after the termination of their volunteering. Following
termination of volunteering we will review, where possible, the personal data we hold and take
steps to minimise the data retained where these requirements are met.
In some circumstances we may anonymise your personal information so that it can no longer be
associated with you, in which case we may use such information without further notice to you. Once
you are no longer a volunteer of the Trust we will retain and securely destroy your personal
information in accordance with our data retention policy.
13. Rights of access, correction, erasure, and restriction
13.1. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep
us informed if your personal information changes during your volunteering relationship with us.
13.2. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
▪ Request access to your personal information (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal information we hold about you
and to check that we are lawfully processing it.
▪ Request correction of the personal information that we hold about you. This enables you to
have any incomplete or inaccurate information we hold about you corrected.
▪ Request the erasure of your personal information. This enables you to ask us to delete or
remove personal information 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 information where you
have exercised your right to object to processing (see below).
▪ Object to processing of your personal information. This applies 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. You also have the
right to object where we are processing your personal information for direct marketing
purposes.
▪ Request the restriction of processing of your personal information. This enables you to ask
us to suspend the processing of personal information about you, for example if you want us
to establish its accuracy or the reason for processing it.
▪ Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the
processing of your personal data, or request that we transfer a copy of your personal information to
another party, please email people@hampshireculturaltrust.org.uk.
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13.3. Do I have to pay a fee?
You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.
13.4. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not disclosed to any person
who has no right to receive it.
14. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection,
processing and transfer of your personal information for a specific purpose, you have the right to
withdraw your consent for that specific processing at any time. To withdraw your consent, please
email people@hampshireculturaltrust.org.uk. Once we have received notification that you have
withdrawn your consent, we will no longer process your information for the purpose or purposes
you originally agreed to, unless we have another legitimate basis for doing so in law.
15. Data protection officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If
you have any questions about this privacy notice or how we handle your personal information,
please contact the DPO. You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
16. Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new
privacy notice when we make any substantial updates. We may also notify you in other ways from
time to time about the processing of your personal information
