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Privacy policy

About this Privacy Notice

This Notice explains how we collect and use the personal information you provide to us whether online, via phone, mobile, e-mail, letter or other correspondence when you engage with the activities of the Foundation.

We promise to respect any personal data you share with us and keep it safe. We aim to be clear about what personal information we collect, and not do anything you wouldn’t reasonably expect. We will always respect your rights and choices.  In this Notice we tell you what we will and will not do with your personal data.

This Notice includes:

  • who we are
  • why we hold and process personal information
  • what personal information we collect
  • how we collect information about you
  • how we will use your personal information
  • the legal basis for processing
  • who has access to your personal information
  • how we keep your personal information secure
  • how long we will hold your personal information for
  • your choices
  • keeping your information up-to-date
  • your rights in respect of the personal data we hold about you
  • complaints, compliments or comments
  • changes to our Privacy Notice

If you have any questions about our Privacy Notice then please contact us and we will be happy to talk you through it. Our contact details are:

FAO: Geraldine Alexander
Peter Sowerby Foundation
Aspinalls
1 King William Street
London
EC4N 7AF
Tel: +44(0)20 3909 1600

Email: sowerby.foundation@aspinallsgroup.com 

Who we are

Peter Sowerby Foundation was established in 2011, to direct the personal wealth of Dr Peter Sowerby as grants to organisations that meet the charitable objectives of Dr Peter Sowerby and his late wife, Ann. 

Peter Sowerby Foundation has three areas of interest to award grants:

  • Medical research and healthcare provision
  • Education
  • Community and environment

Peter Sowerby Foundation is a registered charity, Charity No. 1151978, and is also a Company limited by guarantee registered in England and Wales, No. 08492424. 

The Foundation’s registered address is:

Peter Sowerby Foundation Oxnead Hall
Oxnead
Norwich
England
NR10 5HP

Visit the About section of our website to find out more about the work of the foundation. 

Why we hold and process personal information

In carrying out our activities we have relationships with our beneficiaries, supporters, staff, trustees, and so we collect, store and process personal information on a day to day basis.  Our use of personal information allows us to meet legal requirements, make better decisions, communicate with all of our stakeholders and carry out our grant making and charitable objectives more efficiently.

We are therefore required to adhere to the requirements of the General Data Protection Regulations which came into force on 25th May 2018 and other associated regulations including, but not limited to, the Privacy and Electronic Communication Regulations.  We take our responsibilities under these regulations very seriously to ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with them.

What personal information we collect

The type of personal information we collect, why we collect it, and the legal basis for this data collection may vary depending on our relationship with you and the purpose for which we are collecting it:

For most purposes we may collect the following

  • your name; contact details (including postal address, telephone number, e-mail address and possibly your social media identity); date of birth; gender; and
  • information about your activities accessing and using our website(s), about the device you use to access these, your location, but only identified by your IP address and not your name.

If you apply for, or accept a role within the Foundation, as an employee, or trustee 

  • we will collect the information necessary for us to process these applications, assess your suitability and support or manage this relationship appropriately;
  • we will collect information required to manage our ongoing relationship which for staff will include personal bank account information;
  • age, nationality and ethnicity information where relevant for monitoring purposes.

If you apply for grant funding

  • we will collect the information necessary to process your application, and pay the grant, which may include personal bank account information.
  • certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive.  Examples of this type of sensitive data would be information about health, race, religious beliefs, political views, or sexuality.  We only collect this type of information about our beneficiaries, supporters, staff or trustees where there is a clear reason for us to do so.

When we use special category personal information we will either do so on the basis of your explicit consent or because we need to process it for employment purposes or because it is in your vital interests.

Examples of where we might collect special category data are:

  • if you are supporting us by participating in publicity for the work of the Foundation (eg for a case study about the work of your cause or organisation) where you or a family member or close friend are involved, we will always ask for your express consent if we propose to use this information in support of promoting or reporting our charitable impact.
  • for employees and trustees we will collect information regarding your individual medical condition and/or disability so that we can ensure that the role is suitable and that we can adapt our processes or environment to address the condition.

How we collect information about you

Information you provide to us directly
We collect personal information from you when you enquire about our activities, sign up to our newsletter, apply for grant funding, apply for or accept a job, engage with our social media channels or otherwise provide us with your personal information. We may also collect this type of information if you make it public or volunteer it to us when engaging with us.

Information you provide to us indirectly
We use third parties to collect data on our behalf to support our activities. This might include processing your grant application and payment, setting up salary payment for staff, and ensuring our records are as up to date as possible through running address and detail verification checks.

Your information may be shared with us by third parties, however they will only do so when you have indicated that you have provided your consent. You should check their Privacy Notice when you provide your information to understand fully how they will process your data.

Information from other sources
In addition to the information you give us, we may add information from publicly available sources including data from, for example, reputable newspapers or publications, company websites, Companies House, the Charity Commission, and LinkedIn/Twitter. 

We may also obtain data from public sources to ensure the addresses and postcode information we hold on you is kept up to date.

Website cookies
Cookies are used to gather information on how you use our website.

Cookies are text files, which identify a website user’s computer to our server. Cookies in themselves do not identify the individual user, just the computer used. The Peter Sowerby Foundation website uses persistent cookies – these are used to track returning visitors. They expire after 12 months and enable us to compare website traffic from month to month.

Cookies help us identify which pages are most visited and which elements are of most interest. This information can be used to help us improve our website and grant making activities and ensure we provide you with the best service. Wherever possible, the information we use for this purpose will be aggregated or anonymised i.e. it will not identify you as an individual visitor to our website.

You can reject cookies. Most browsers allow you to refuse cookies – consult the help section of the browser toolbar. Information on controlling cookies or rejecting cookies is available from several web sites, e.g. www.aboutcookies.org

Website analytics
This website uses Google Analytics tracking codes to measure performance enabling us to enhance and improve services for our audiences. However, we do not collect personally-identifiable information (PII) as all data collected is anonymous. For full details on how Google Analytics works, please visit Google Analytics Terms of Service. If you do not want Google Analytics to use your data, then please visit Google Analytics opt-out browser add-on.

Use of email products for bulk mailing

We use a product for sending emails e.g. our e-newsletter, to larger numbers of people and can identify from this product whether the email has been opened, whether links within the email have been clicked. This enables us to determine whether our emails are of interest to the recipient.

How we will use your personal information

How we may use your information will depend on the reasons why you are providing it and any associated legal/regulatory obligations. This will include the following:

If you are subscribing to our e-newsletter:

  • to provide you with information about our work including grant making activities, unless you have indicated that you do not wish to receive this;
  • for administration purposes e.g. we may contact you about a grant/funding you have expressed an interest in or registered for;
  • for internal record keeping, including the management of any feedback or complaints;
  • to use anonymised personal data to benchmark our activity with other relevant organisations or report information requested by Regulators;
  • collecting information which tells us more about the people who support us which enables us to shape the information we are sending to them (see below).

If you are using our website:

  • to use IP addresses to identify your approximate location, to block disruptive use, to record website traffic or to personalise the way our information is presented to you;
  • to analyse and improve the services offered on our site to make it as user-friendly as possible.

If you apply for, or accept a role within the Foundation, as an employee or trustee: 

  • to process your application for a job or trustee position
  • to support and manage this relationship and pay and/or reimburse you for expenses (as appropriate);
  • to meet our legal obligations; for instance to carry out contractual obligations between you and us, or meet our obligations to regulators, government and/or law enforcement bodies;

If you apply for grant funding

  • to process applications for grants/funding and reimburse individuals for any expenses;
  • to collect information on the impact of our grants and report how our charitable funds have been used in pursuit of our objectives and public benefit.

Collecting information which tells us more about the people who support us about the Foundation

We collect and may analyse information about individuals, or groups of individuals, by combining the data you provide with data we obtain from other sources and carrying out analysis in order to gain a better understanding of our supporters, inform our grant making strategy and target our communications more effectively and appropriately.

Some examples of such activities and the purpose of these activities are as follows:

Segmentation analysis
This analysis helps us to gain a better understanding of our supporters, their interests, of how they are engaging with us and helping to understand broader demographic and geographic trends. This also helps us identify communications of potential interest to each supporter and communicate to our supporters cost effectively.

Research
We may also undertake research on an individual supporter’s personal information to help us understand more about the interests of an individual and ensure our communications are tailored appropriately. This may include research on demographic, philanthropic, business and financial information from publicly available sources, including social media.

Identification of new potential supporters
We would like to find new supporters and interest them in our activities and grant making opportunities. This can be assisted through research aimed at identifying those individuals. The activity could involve looking at publicly available information e.g. press articles, public profiles on networking sites. This activity might also result in us processing data of individuals who we conclude that we will not contact.

Your right to object
If you do not wish your data to be used in any of the ways listed above or have questions about this, you can notify us using the following contact details.

FAO: Geraldine Alexander 
Peter Sowerby Foundation Aspinalls
1 King William Street London 
EC4N 7AF
Tel: +44(0)20 3909 1600 

Email: sowerby.foundation@aspinallsgroup.com 

The legal basis for processing

There must be a legal basis for each use we make of personal information. The relevant legal bases are set out in the data protection regulations.

Specific consent

Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you informational or marketing material via email).  Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.

Legal obligation

We may have a legal basis to use your personal information in order to comply with one of our legal/ regulatory obligations.  For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, the Information Commissioner, or HMRC, or to use information we collect about you for due diligence or ethical screening purposes.

In connection with a contract which you are party to

We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract.  Examples of this would be if you are applying to work/volunteer with us, supporting us through participating in an awareness raising campaign or event, or otherwise being funded by us.

Vital interests

We have a basis to use your personal information where it is necessary for us to protect your life or health.  For example, if there were to be an emergency impacting individuals in our offices, which required us to contact people unexpectedly or share their information with emergency services.

Legitimate interests

We have a basis to use your personal information if it is reasonable for to do so and in our “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities carried out by the Foundation involving the use or processing of personal information.  Some examples where we are relying on legitimate interests, rather than the bases mentioned above, are:

  • keeping you informed of the Foundation’s activities Including ways in which you can find out about grant/funding opportunities by email, website, or phone;
  • using personal information to administer, and keep records of the people we work with, including staff and trustees of the Foundation;
  • using personal information when we are monitoring use of our websites or social media for technical purposes;
  • recording information relating to personal executors with whom we need to communicate regarding bequests to the Foundation;
  • analysis and profiling of our supporters and grant/funding recipients.

This list is not exhaustive. We rely on legitimate interests where we consider that our interests in using your information are not over-ridden by any resultant potential negative impact on you and your rights under data protection laws.

When we use special category personal information (please see the “What personal information we collect” section above), we will either do so on the basis of your explicit consent or we need to process it for employment, social security or social protection law purposes or it is in your vital interests.

Who has access to your personal information?

Your personal information is stored on our systems, access to which is limited to staff working in Peter Sowerby Foundation, Aspinalls, IT staff employed by the Foundation and Aspinalls who support our IT systems and some other trusted subcontracted parties.

We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process grant/funding payments and send out mailings). When we use third-party service providers, we only disclose information necessary to deliver that service and there will always be a contract in place to ensure your data remains secure. We will not share or sell your data to third parties to use for their own purposes unless we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Although most of the information we store and process stays within the UK, some information may be transferred to countries outside the European Economic Area (EEA). This may occur if, for example, one of our trusted partner’s servers are located in a country outside the EEA. These countries may not have similar data protection laws to the UK/EU however, we will take steps to make sure they provide an equivalent level of protection in accordance with UK data protection law. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.

How we keep your personal information secure

We ensure that there are appropriate technical controls in place to protect your personal details; for example our online forms are always encrypted and our network is protected and routinely monitored.

We also take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.

Any payment details, such as bank account or credit/debit card information, on paper grant forms are destroyed once the payment has been processed and we are sure it has been received.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff or volunteers and third-party organisations contracted to provide specified data processing services to the Foundation.

How long will we hold your personal information for?

We will keep your information for as long as required to enable us to operate our services but we will not keep your information for any longer than is necessary. We will take into consideration our legal obligations and tax and accounting rules when determining how long we should retain your information. When we no longer need to retain your information we will ensure it is securely disposed of, at the appropriate time.

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive marketing communications from us about the grant making work we do, then please let us know at any time by contacting us, tel: +44(0)20 3909 1600 or email: sowerby.foundation@aspinallsgroup.com.

We will not contact you for marketing purposes by email unless you have told us you agree to us contacting you for this purpose by such channels.  If the telephone number we hold for you is registered with the Telephone Preference Service (TPS) then we will not contact you on that phone number except for administrative purposes, unless you have given us consent.

If you unsubscribe from communications from us, from any or all of the communication channels mentioned above and in addition from post, then we will update our records to stop further communication as quickly as we can.

Due to some communications already being in progress at the point you opt out, please be aware that it can take up to 6 weeks for your preferences to be fully implemented.

We will only ever share your data if we have your explicit and informed consent and we have explained the rationale for doing so.

Keeping your information up-to-date

The accuracy of your information is important to us. You can update your information with us, including your address and contact details at any time. If you would like to change your preferences or update the details we hold about you, please contact us, tel: +44(0)20 3909 1600 or email: sowerby.foundation@aspinallsgroup.com. 

Your rights in relation to the personal information we hold about you

You have the right to:

  • request access to, and a copy of, the information we hold about you (see contact details below);
  • update or amend the information we hold about you if it is wrong;
  • restrict how we process or use some or all of your personal information;
  • change your communication preferences at any time;
  • ask us to remove some or all of your personal information from our records unless we have a legal obligation to retain it;
  • object to the processing of your information for marketing purposes;
  • request that information held electronically be transferred to another third party either directly or through you.

You have the right to raise a concern or complaint about the way in which your information is being used (see Complaints section below).

You also 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

The Information Commissioner
Wycliffe House
Water Lane
Wilmslow 
Cheshire SK9 5AF

Tel: 01625 545 700
Data Protection Help Line: 01625 545 745

Complaints, compliments or comments

If you are unhappy with our work or something that we have done or failed to do, we want to know about it. We also welcome your views on what we do well. Your comments enable us as an organisation to learn and continuously improve our services.  If you would like to make a complaint, compliment or comment then please get in touch with our Administrator. Contact details are at the top of this page.
You can find out more and read our Complaints Policy.

Changes to our Privacy Notice

We may change this Privacy Notice from time to time.  If we make any significant changes in the way we treat your personal information we will make this clear on this website and by contacting you directly.

If you wish to talk through anything in our Privacy Notice, find out more about your rights, or obtain a copy of the information we hold about you, please contact Geraldine Alexander. Contact details are at the top of the page.