Who we are
Accounting for Sustainability (A4S) is a programme of The Prince of Wales’s Charitable Foundation,
When we refer to the "Foundation" in this policy, we mean The Prince of Wales's Charitable Foundation (PWCF), registered charity number 1127255 and registered company 06777589 of Clarence House, London, SW1A 1BA. Further details are available here. The Foundation is a data controller within the meaning of the Data Protection Act 1998 (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 the Foundation. 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, initiatives and network of charities
The Foundation works (and may from time to time share information) with its charitable and trading subsidiaries and programmes (Accounting for Sustainability - A4S) in the United Kingdom and Romania. Further details of the entities within the PWCF 'group' are available at https://www.princeofwalescharitablefoundation.org.uk/about-us/subsidiaries-and-programmes
The Foundation works from time to time with The Royal Founding Patronages, a group of charities (plus their subsidiaries and/or trading entities) as well as the Prince's Trust Group and The Prince's Foundation, listed here: https://www.princeofwales.gov.uk/prince-waless-charities. .Furthermore, the Foundation sometimes works with The Royal Collection Trust https://www.royalcollection.org.uk, The Royal Foundation for the Duke and Duchess of Cambridge and Prince Harry, http://www.theroyalfoundation.org.uk/ and Sentebale http://sentebale.org/ All these organisations are together referred to as "the Charities".
Each PWCF subsidiary and charity is a data controller in its own right, separate from the Foundation.
The relationship between the Foundation, its subsidiaries and the Charities involves a limited degree of relevant and proportionate information sharing within the group, carried out in the legitimate interests of both the Foundation, 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 the Foundation’s own policies, the DPA and the General Data Protection Regulations. 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 the Foundation’s secure CRM, 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.
Personal data held and processed by the Foundation 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 consent.
Where relevant, for example in keeping records of donors and potential donors, the Foundation 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)
- Details of any purchases with us, e.g. event tickets, or competitions entered
- Donations made with other organisations, notably the Charities
- Our assessment of your ability to make donations.
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 the Foundation to do so, please contact The Executive Director, The Prince of Wales's Charitable Foundation, Clarence House, St James's, London, SW1A 1BA.
How the Foundation uses the data
- Providing you with information about the work and activities of the Foundation, its subsidiaries and the Charities. This might include sending you publications, e-newsletters, invitations to events and details of volunteering opportunities.
- Conducting donor research to gain a better understanding of our supporters, inform our fundraising strategy and target our communications more effectively and appropriately.
- Sharing information within the PWCF and Charities 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 different members of the Charities.
- 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.
- Furthering our charitable objectives, including asking you to donate or otherwise help us raise funds, but always in accordance with best fundraising practice.
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).
Electronic tools may be used to monitor the impact of the Foundation'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 the Foundation 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 the Foundation, or suppliers or partner organisations who (for example) help to develop content for and 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 a supporter; or with Charities with whom the Foundation has a data sharing policy. The Foundation does not sell any of its data to third party organisations. Guest lists for certain events may be shared with other participants and within post-event communications.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
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 party consultants, intermediaries, 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 Foundation 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 the Foundation's gift acceptance policy.
How long do we keep your information for?
We keep your information in accordance with our retention policy. Due to the varied activities we undertake we may keep your information for different lengths of time depending on the reason for processing it. 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 your donation history for 7 years for accounting purposes.
The Foundation 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 and is not currently held or shared outside the EEA.
IP Addresses 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 the Foundation). This is statistical data about our users' browsing actions and patterns and does not identify any individual. 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 information and further advice
Please contact the Executive Director at The Prince of Wales's Charitable Foundation, Clarence House, London SW1A 1BA or email firstname.lastname@example.org 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
25th May 2018