During the course of its activities, The Clean Earth Trust will process personal data (which may be held on paper or electronically) about the Trust’s Representatives and participants. The Trust recognises the need to treat personal data in an appropriate and lawful manner, in accordance with the relevant Data Protection Legislation. In Guernsey, that legislation is the Bailiwick of Guernsey Data Protection (2017) Law.
This document sets out how we do this. For any questions about this policy please contact the Clean Earth Trust at email@example.com or on 07781 400426. You can also write to us at 77 Mount Durand, St Peter Port, Guernsey GY1 1DY.
Definition of Personal Data
The definition of “Personal data” refers to any information relating to an identified or identifiable natural person (“Data Subject”) who can be identified, directly or indirectly, by reference to an identifier such as name, identification number, online identifier.
Data Protection Principles
The Clean Earth Trust will comply with the following data protection principles, as defined by local Data Protection legislation; which state that personal data must be processed with due care and accountability. Personal data must be:
Processed fairly and transparently;
Processed only for the agreed purpose (Purpose Limitation);
Adequate, relevant and not excessive for the purpose (Data Minimisation);
Not kept longer than necessary to achieve the agreed purposes;
Processed in a manner that maintains integrity and confidentiality.
Data Subject Rights
The Clean Earth Trust interacts with different types of Data Subjects, including Representatives (Volunteers and Employees), participants, sponsors, suppliers, local authorities, and members of the general public.
The Clean Earth Trust will observe all Data Subject Rights as defined by the local Data Protection legislation, including:
The right to access;
The right to rectification;
The right to be forgotten;
The right to restriction of processing;
The right to data portability;
The right not to be subject to decisions based on automated processing
The right to information about how personal information is collected (this is outlined in this document
The right to object to processing for direct marketing purposes
The right to object to processing on grounds of public interest
The right to object to processing for historical or scientific purposes
Processing for Limited Purposes
The Clean Earth Trust will only process personal data for the specific purpose or purposes notified to Data Subjects, or for any other purposes specifically permitted by the Data Protection Authority; and only to the extent necessary.
The Clean Earth Trust will process personal data solely for the purposes of the Trust and for fulfilling its duties as an Employer and a Registered Charity; including, but not restricted to recruitment, employment, communications, events and associated administration.
The Clean Earth Trust may also process personal data in order to comply with legal or regulatory obligations as an Employer and as a Registered Charity; or if the Trust is required to report a concern to a local authority for the purpose of safeguarding a person’s, or other people’s, welfare.
The Clean Earth Trust will not process personal data for the purposes of unsolicited marketing. Marketing materials will only be sent to a person if that person actively subscribes to the Trust’s website, newsletter or social media pages. Subscribers may then unsubscribe at any time by unliking or unfollowing the Trust on social media; or unsubscribing from the Trust’s website or emails.
Fair and Lawful Processing
The Clean Earth Trust will only process personal data where the Data Subject has given consent by engaging with the Trust on a voluntary basis; or where the processing is necessary to comply with our legal obligations as a Registered Charity or Employer. If the Trust can only lawfully process a Data Subject’s personal data through reason of consent the data subject can withdraw their consent for processing at any time by contacting the trust.
In other cases, processing may be necessary for the protection of the Data Subject’s vital interests, for the Trust’s legitimate interests, or the legitimate interests of others.
Categories of Personal Data
The types of personal data the Clean Earth Trust may process will differ according to the Trust’s relationship with the Data Subject.
Examples of personal data processed for the purposes of achieving the Trust’s charitable aims include, but are not necessarily restricted to:
Communications data, including: Person’s name, phone number, email address, physical address, signature, social media ID or alias, and personal opinion expressed in conversation or written record;
Payment data, including: Credit or debit card information, bank account name, number and sort code, PayPal ID, VAT or Tax Code (if applicable);
Image Data, including: Photography and film.
Examples of personal data processed for the purposes of Employment include, but are not necessarily restricted to:
Recruitment Data, including: CV (employment history, training history), cover letter, references (including Communications Data of Referees), date of birth, gender, nationality, emergency contact details (Communications Data of Emergency Contact/s), notes made during interview, correspondence, and a signed contract of employment.
Employment Data, including: uniform size, driving license, Police Disclosure Certificate, Right to Work or other record of permissions, holiday records, sickness records and sickness certificates, data pertaining to injury or illness, Occupational Health record, probation or performance review record, personal data disclosed in the event of a grievance being raised, investigation, hearing, or disciplinary actions, and personal opinion expressed in conversation or written record.
Image data, including: Photography or film
Payroll Data, including: Bank account name, number and sort code, Social Security number, Income Tax Code, salary and discretionary bonus, benefits (sickness/incapacity etc), expenses and receipts.
Training Records, including: Bookings and reservations, travel information, training certifications or other records.
Consent for Images
The Clean Earth Trust will only take photos, video or audio recordings at public or private events for use on the Trust’s website, social media and press releases; if participants consent to them doing so (verbally, or in written notice). If participants are under the age of 18, Trust Representatives will ask the permission of a responsible person, e.g. parent, guardian, teacher or group leader.
The Clean Earth Trust is not responsible for any photographs or recordings taken by members of the general public at public events, for their own use; or photographs or recordings taken by private groups, for their own use.
The Clean Earth Trust will ensure that any member of the Media providing coverage at its events similarly ask for consent prior to taking photos or recordings, for use on media channels.
Special Category Data
The Clean Earth Trust will not request any Special Category data about ethnic origin, political opinions, religious or similar beliefs, trade union membership, health, disability, sexual orientation, criminal proceedings or convictions.
If any person chooses to disclose this information it will be held in confidence, and the data subject may withdraw consent for its processing at any time unless the Trust is required to process the data in the interests of Safeguarding.
The exceptions to this statement may include the request for a Police Disclosure Certificate of nominated Responsible Persons representing the Trust; and any relevant Employee disability, medical or sickness information that may affect the performance of their duties, or their paid employment.
Use of Personal Data
The Clean Earth Trust will obtain most personal data via social media, if a person or business likes or follows any of the Trust’s profiles; or via email, if a person or business contacts the Trust to register their interest.
Personal Data of paid Employees with be obtained during the recruitment process and used throughout the duration of their Appointment.
The Clean Earth Trust may contact individuals and businesses via publicly available email addresses, phone numbers or addresses.
The majority of communications sent via the Charity are likely to be transmitted via social media; or via email.
The Clean Earth Trust will take steps to keep all personal data on file accurate and up to date. Data that is inaccurate or out of date will be erased or destroyed. Data Subjects should notify the Trust if their personal details change, or if they become aware of any inaccuracies in the personal data held about them.
The Clean Earth Trust will not keep personal data for longer than is necessary for the agreed purpose. This means that personal data will be destroyed or erased from the Charity’s digital and hard copy systems when it is no longer required. Generally, personal data will be retained by the Charity for a period of 7 years; unless there is a legal obligation to retain this data for a longer period of time.
Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
The Clean Earth Trust will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
The Clean Earth Trust has in place technical and organisational control measures to maintain the security of all personal data from the point of collection to the point of destruction.
Sharing information with Third Parties
The Clean Earth Trust will not disclose any personal data to a third party without the explicit consent from the relevant Data Subject; with the following exception:
The Clean Earth Trust may share posts on social media, which may mean personal data is visible to other parties beyond the respective project page. The Trust is not responsible, and cannot control, who may see information, posts, likes and comments when sharing its content to other social media pages. All shares will be relevant to the Trust’s purposes, and posts will only be shared with other environmental charities and corporate sponsors involved in environmental protection and sustainability initiatives.
Subject Access Requests
If a Data Subject wishes to know what personal data the Clean Earth Trust holds about them, they should contact the Trust via email or in writing. Subject Access Requests will be processed free of charge; but repetitive requests may be subject to a fee. The Clean Earth Trust will respond to requests within 30 days. All requests should be forwarded to the Chairman. The Clean Earth Trust retains the right to verify the identity of the Data Subject prior to disclosing any personal data.
If a Data Subject believes that the Clean Earth Trust has not followed the data protection principles, or wishes to submit a complaint; the Data Subject should contact the Chairman in the first instance, or the local Data Protection Authority within their jurisdiction.
In the event of a Data Breach the Trust will initiate an investigation and inform the local Data Protection Authority within 72 hours if it is believed that there has been a breach affecting personal data. All affected Data Subjects will be informed, in the event that the breach presents a risk to their respective personal data.
Right To Complain
You have a right to complain about the processing of data by the Trust, and this can be done by contacting the Office of the Data Protection Authority in Guernsey at firstname.lastname@example.org, on 01481 742074 or in writing to St Martin’s House, Le Bordage, St Peter Port, Guernsey GY1 1BR.