WHO WE ARE
When we refer to "PWCF" in this policy, we mean The Prince of Wales's Charitable Foundation trading as The Prince of Wales's Charitable Fund. Registered charity number 1127255 and registered company 06777589 of 105 Victoria Street, London, SW1E 6QT. Further details are available here. PWCF is a data controller within the meaning of the Data Protection Act 2018 (DPA).
Our relationship with our stakeholders in particular (but not limited to) our subsidiary companies, supporters and the public at large is of great importance to PWCF. This policy, together with other notices provided from time to time (for example on collection forms, communications with you or on this website), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us (whether by your access to this website or otherwise).
OUR SUBSIDIARIES AND NETWORK OF CHARITIES
PWCF works (and may from time to time share information) with its charitable and trading subsidiaries in the United Kingdom and Romania. Further details of the entities within the PWCF 'group' are available at here.
Furthermore, PWCF may from time to time work and share information with The Prince of Wales's charities namely The Prince's Trust group, The Prince's Foundation and The Royal Founding Patronages listed on this website. These organisations are together referred to as "the Charities". Each PWCF subsidiary and charity is a data controller in its own right, separate from PWCF.
The relationship between PWCF, its subsidiaries and the Charities may involve a limited degree of relevant and proportionate information sharing within the group, carried out in the legitimate interests of both PWCF, subsidiaries and the Charities in supporting their individual and collective aims, as well as being in the legitimate interests of our supporters as explained below.
DATA PROTECTION STATEMENT
We are committed to making sure that our communications with you are secure, proportionate and targeted. All personal data is held and processed in accordance with PWCF's own policies, the DPA and the General Data Protection Regulations (GDPR). Our policy is that staff who handle personal data have received relevant data protection training.
Any personal data we hold on members of the public is generally held on PWCF's secure CRM and servers or sometimes in hard copy in secure rooms or filing systems, and are accessed by authorised staff only. Most information that we hold will have been obtained directly from you, with some from publicly available sources such as those mentioned below.
INFORMATION WE COLLECT
Personal data held and processed by PWCF may include:
Contact information, such as:
- Your contact details.
- Your communication preferences.
- Records of communications and interactions we have had with you.
- Biographical details.
Information about grant applicants and beneficiaries such as:
- Your name and contact details.
- Any personal information you include in your application.
- If you are successful, details of how you have used the information you provided.
- Images of beneficiaries and grant recipients.
Please note that we will only use and publish case study information and images of beneficiaries with your written consent.
Where relevant, for example in keeping records of Trustees, donors and potential donors, PWCF may obtain biographical information, such as:
- Your name, gender and date of birth.
- Your family and partner/spousal details.
- Your professional activities and employment.
- Information you have publicly shared on social media.
- Your charitable and philanthropic interests.
Financial information, such as:
- Information necessary to process any donations made, including Gift Aid status.
- Your donation history with us (which we must keep for 7 years).
- Donations made with other organisations, notably the Charities
- Our assessment of your ability to make donations.
- Bank details of suppliers.
Please note that we do not store any credit/debit card details in our database.
We may use external data agencies to ensure that our contact details for you are up to date, allowing us to continue to communicate with you in accordance with your existing preferences. If you do not wish PWCF to do so, please contact The Board of Trustees, The Prince of Wales's Charitable Fund, 105 Victoria Street, London, SW1E 6ET.
WHY DO WE COLLECT THIS DATA?
We collect data out of contractual necessity or because it is a legitimate interest of PWCF to process the information.
HOW WE USE THE DATA
- Provide you with information about the work and activities of PWCF, its subsidiaries and the Charities. This might include sending you publications, e-newsletters, invitations to events and details of volunteering opportunities.
- Conduct donor research to gain a better understanding of our supporters, inform our fundraising strategy and target our communications more effectively and appropriately.
- Share information within the PWCF group to ensure any approaches to donors are handled sensitively and proportionately, and to prevent the same donors receiving multiple approaches at the same time from our charitable subsidiaries.
- Internal record keeping, including the management of any feedback or complaints.
- Administrative purposes e.g. regarding a donation you have made or an event you have registered for or attended, including security for that event.
- We also use your data to ensure that the ways in which we communicate with you do not conflict with your chosen communication channel preferences (for example, by post, telephone or electronic means).
- Paying you for good and services if you are a supplier.
- Making grant award payments if you are a grantee.
Electronic tools may be used to monitor the impact of PWCF's communications, such as using email tracking to record when an email we send to you has been opened.
YOUR DATA AND THIRD PARTIES
If you interact with PWCF or any of the Charities through a third party (for example, making a donation via JustGiving or a crowdfunding page) then we may obtain information about you from that third party, but only if you have given your explicit consent to that third party sharing your information.
Data will not be disclosed to external organisations other than those acting as agents for PWCF, or suppliers who manage (for example) guest lists for events; with the Royal Household where it needs access to relevant guest lists; with relevant agencies such as the police or security services for ensuring screening and safety at events; with the principal or any special guest at a specific event who will be involved in thanking the supporter; or with Charities with whom PWCF has a legitimate interest to do so. PWCF does not sell any of its data to third party organisations.
We engage third parties to provide software and IT solutions to support our processes. They operate as data processors on our behalf and do so on the basis of written instructions. They are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
The third party data processors we use are:
- Salesforce – for the provision of our CRM system and the storage of contact information. Data stored in Salesforce is maintained on servers located in EEA. Here is a link to Salesforce’s Privacy Notice.
- Kroll - for donor due diligence and risk assessment. Here is a link to Kroll's Privacy Notice.
We may have to share certain information with relevant authorities upon request, for example the Charity Commission, or to HM Revenue and Customs in respect of any Gift Aid claims.
USE OF PUBLICLY-AVAILABLE INFORMATION FOR PROFILING RESEARCH AND DUE DILIGENCE
To ensure that we understand you and your philanthropic interests, and identify new prospects of interest to our charitable aims, we may use additional information where available from external sources to improve our understanding.
This will be a combination of publicly-available information, for example drawn from search engines, company resources and news media; information from third parties, mutual contacts and databases; and what you have provided to us, such as past donations and career information. We may also use data from social media sites like LinkedIn, Facebook and Twitter, depending on your privacy settings and/or interactions with the Fund or the Charities.
Please note however that before seeking or accepting major donations we are required, at law and in accordance with good governance and reputational practice, to conduct a certain level of due diligence, including reviewing publicly available personal data relating to political exposure, criminal convictions and offences. Due diligence is conducted in accordance with PWCF's gift acceptance policy.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We keep your information in accordance with our retention policy. We will keep your personal data for as long as we continue to have a relationship with you. We will delete personal data at your request or if we do not have contact with you for more than 7 years. Please note that we will keep your name and the relationship we had with you permanently as part of our historic record.
We are also bound by legal requirements to retain some information for set periods. For example we keep information relating to Gift Aid for 7 years in accordance with tax legislation as well as best practice and we must keep details of financial transactions for 7 years in accordance with the Charities Act 2011 for accounting and auditing purposes. Further information about our retention periods are available on request.
PWCF commits to holding this data securely, both in its electronic systems and in staff protocols, and treating it with sensitivity. Data will only be held for as long as it is necessary for the above purposes. PWCF is committed to periodically reviewing the data it holds in accordance with the DPA and our retention policy.
IP ADDRESSSES AND COOKIES
During your use of the site we may collect information about your computer, including where available your IP address, operating system and browser types, for system administration and to report aggregate information to third parties (including organisations connected with PWCF). This is statistical data including your IP address, operating system and browser type and does not identify any individual. This means that while your user session, browsing actions and patterns will be logged, you will remain anonymous to us.
For the same reason, we may obtain information about your general Internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve the site and to deliver a better and more personalised service. For more information about cookies, please visit www.allaboutcookies.org.
YOUR INFORMATION RIGHTS
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- ask us to change incorrect or incomplete data;
- ask us to delete or stop processing your data, for fundraising purposes (except as necessary to maintain suppression lists);
- object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing;
- request a copy of the data you have provided to us in an agreed format, so that you can reuse it or transfer it to another data controller if you wish;
- ask us whether we use automated decision making or profiling when processing your data.
Please note that none of these rights are absolute and we reserve the right to refuse your request where exceptions apply.
CONTACT AND FURTHER ADVICE
Please contact The Prince of Wales's Charitable Fund by email email@example.com or in writing to105 Victoria Street, London, SW1E 6QT for any requests or related enquiries.
If you have concerns about the use of your personal data, the Information Commissioner's Office is an independent body set up to uphold information rights in the UK. They can be contacted through their website: www.ico.org.uk or their helpline on 0303 123 1113, or in writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
12th January 2022