Legals
Oursankalpa C.I.C (we, us, Oursankalpa or sankalpa) is a company limited by guarantee registered in England and Wales under company number 10781557.
We are the owners of this website: https://oursankalpa.org (our site).
1. What is the purpose of this policy?
1.1. We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which we collect any personal information from individuals who engage with us, and how this information will be processed by us.
1.2. This privacy notice applies to donors, supporters and beneficiaries of Oursankalpa; individual applicants for and recipients of support, guidance, grant funding, investment or loans; visitors to our site; and all individual contractors and service providers who provide services to our organisation ("you").
1.3. We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
1.4. Please read this notice carefully to understand what we do with your personal information and what rights you have in relation to our activities. This notice will be reviewed periodically. Any changes will be posted on this page and will become effective on that date. We encourage you to review this page for significant changes from time to time.
2. What is personal information and our lawful basis for processing it?
2.1. Personal information means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information (known as special category personal information) which require a higher level of protection (see further at section 4, below).
2.2. We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
2.3. We may only rely on our legitimate interests (or those of a third party eg. The Oxford Community Foundation) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest in the table below.
2.4. We will only use your personal information for the purposes for which we initially collect 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.
2.5. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
3. Information we collect from you and about you, and how our use complies with the law
Information we collect from you | |||
Information | How we use your information | How our use complies with the law | |
If you are an applicant for or recipient of any form of support or investment we collect your name, address contact details (including email), bank details and the details of your application and any grant or investment we have made to you or your organisation. | To enable us to contact you and assess your application. | For the legitimate interests of assessing the grant application and managing and promoting the work of sankalpa and sankalpa Changemakers. | |
If you are an applicant for, or recipient of, a loan we collect your name, address, contact details (including email), date of birth, bank details, credit checks, criminal background checks, and the details of your application and any loan we have made to you or your organisation. | To enable us to contact you and assess your application.
| With your consent (where required for criminal background checks) and for the legitimate interests of assessing the loan application and managing and promoting the work of sankalpa and sankalpa Changemakers.
| |
For grant funding or investment applications made by organisations, we collect the name, job title and business contact information of your (relevant) individual employees and other representatives (and references to 'you' in this notice is to the individual employee or representative). | To enable us to contact you and assess the grant application. | For the legitimate interest of assessing the grant application and managing and promoting the work of sankalpa and sankalpa Changemakers. | |
For loan applications made by organisations, we collect the name, job title and business contact information of your (relevant) individual employees and other representatives, credit checks (and references to you in this notice is to the individual employee or representative) | To enable us to contact you and assess the loan application. | For the legitimate interest of assessing the loan application and managing and promoting the work of sankalpa and sankalpa Changemakers. | |
For recipients of guidance, support, grant funding, investment or loans and the end recipients of that guidance, support, grant funding, investment or loans, it is likely that we will publish your photograph and information about you (as a sankalpa Changemaker) and the work you will / have undertaken that received support, guidance, grant funding, investment or a loan. | To promote the range of Changemakers (support) and to demonstrate the scope and impact of their work | For the legitimate interest of promoting the people and projects supported by sankalpa. | |
For individual donors and supporters of sankalpa we collect your name and contact details, and information relating to your past donations and fundraising activities. | To enable us to contact you about your support for sankalpa and (with your consent) to send marketing information about further fundraising activities. | This processing is necessary for our legitimate interest of raising funds to support the work of sankalpa and sankalpa Changemakers. | |
For corporate donors and supporters of sankalpa we collect the name, job title and business contact information of your individual employees and other representatives (and references to 'you' in this notice is to the individual employee or representative). | To enable us to contact you about your support for sankalpa and (with your consent where applicable) to send marketing information about further fundraising activities. | This processing is necessary for our legitimate interest of raising funds to support the work of sankalpa and sankalpa Changemakers. | |
The content of any messages you send us. | To enable us to respond to your queries. | This processing is necessary for our legitimate interest of managing sankalpa and improving our services. | |
Feedback you provide to us on our services. | To review and improve our services and to promote the range of sankalpa Changemakers and to demonstrate the scope and impact of our work. | This processing is necessary for the legitimate interest of managing sankalpa and improving our services. | |
Your marketing preferences. | To send you marketing materials. | This processing is necessary for the legitimate interest of promoting sankalpa. We only send unsolicited marketing by email with your consent. | |
For corporate contacts and suppliers of services to our organisation, we collect the name, job title and business contact information of your individual employees and other representatives. | To receive your services. | This processing is necessary to enter and to perform the contract between us and our supplier. | |
Information we collect about you | |||
Information about your preferences and the types of services you are interested in via the cookies on our website (please see our Cookies Policy https://oursankalpa.org/legal/terms-and-conditions/ for further information). | To improve the services we offer to you and others. To provide you with information about other products and services which we think may be of interest to you. | This processing is necessary for our legitimate interests to ensure the smooth running of our website. You can disable cookies on your browser. | |
We may take information collected from you in your application and combine it with information collected from third parties (including from publicly available sources). | We do this to enable us to assess your application for support, guidance or investment | This processing is necessary for the legitimate interest of assessing your application for support, guidance or investment. | |
Background information relating to our past dealings with you. | To inform and improve our service. | This processing is necessary for the legitimate interest of informing and improving the service we provide to you. | |
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform via cookies on our website. | To improve the services we offer to you and others.
| This processing is necessary for our legitimate interests to ensure the smooth running of our website. You can disable cookies on your browser. | |
4. Special Category Data
4.1. The law recognises some types of personal information as particularly sensitive ("special category data"), this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Special category data requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.
4.2. We do not process particularly sensitive personal information as part of our usual course of business. However, we may process information:
4.2.1. Relating to a health condition or disability in order to meet our legal obligation to make reasonable adjustments in the provision of our services;
4.2.2. Relating to racial or ethnic origin, religious or other beliefs and sexual orientation to ensure meaningful equal opportunity and diversity and inclusion monitoring and reporting. Such information will be anonymised to the fullest extent possible;
4.2.3. Where it is needed to protect your vital interests (or someone else's interests) and you are not capable of giving your consent;
4.2.4. Where it is necessary to establish, exercise or defend a legal claim;
4.2.5. Where you have manifestly made the information public; or
4.2.6. Otherwise with your explicit consent.
4.3. 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.
5. Sharing your information
5.1. Your information will not be shared with third parties outside sankalpa, used for marketing purposes, or used in any other way, except as set out in this notice or where required by law.
5.2. If you are an applicant for support, guidance, grant funding or investment, your application will be shared with our board of directors to enable them to assess your application.
5.3. If your application is approved we may contact your referees to obtain confirmation of the information in your application, we only do so with your consent.
5.4. We may share your application with our consultants and partner organisations to enable them to provide support and guidance to you.
5.5. We may share information with third parties to the extent necessary to permit good governance of sankalpa, as follows:
5.5.1. With our professional advisors and auditors;
5.5.2. The Office of the Regulator of Community Interest Companies
5.5.3. With HMRC or other government or law enforcement agencies;
5.5.4. With our insurance provider;
5.5.5. Where necessary, with Oxfordshire Community Foundation
5.5.6. If we sell or otherwise dispose of any part of sankalpa or its assets, in which case we may disclose your personal information to the prospective acquirer of sankalpa or its assets;
5.5.7. If we have a legal obligation to do so; and
5.5.8. For the purposes of fraud protection and credit risk reduction.
5.6. If you object to our sharing or continuing to use your personal information with any specific third party please contact us at hello@oursankalpa.org
5.7. We use third-party service providers, such as Gmail and Google Drive and other businesses that provide certain services on our behalf. All of our third-party service providers 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 information for their own purposes.
6. If you fail to provide personal information
6.1. You are required to provide the personal information set out in sections 1 of the table. Without this we will not be able to provide our services to you.
6.2. We want to be sure that the personal information we hold about you is accurate and current. Please contact hello@oursankalpa.org to update your details.
7. How is your personal information kept safe?
7.1. Protecting your personal information is extremely important to us. Access to your personal information is only provided to our team and third parties who help us to process personal information.
7.2. We have put in place:
(a) Appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed; and
(b) 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.
7.3. Any personal information that you submit to us will be held on secure servers within the UK or the European Economic Area (EEA).
7.4. We only transfer information outside the UK or EEA where we are permitted by law, or with your express consent. We take appropriate measures to ensure that your personal information is treated by our directors and consultants in other jurisdictions in a way that is consistent with and which respects the EU and UK laws on data protection.
7.5. If you are based outside the UK or EEA we may transfer personal information to the correspondence address you provide to us. We will take all reasonable steps to ensure that such transfers are secure. By contacting us from outside the UK or EEA you acknowledge and agree that such transfers are necessary for us to provide services to you.
8. How long will we keep your personal information for?
8.1. We will only keep 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. How long it will be kept for depends on the information and what it is being used for.
8.2 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, regulatory, tax, accounting or other requirements.
8.3. Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 12 months to allow time for us to anonymise or delete information in accordance with our internal data management processes.
9. Your rights
9.1. You have the following rights:
9.1.1. To be told what we are doing with your personal information. We do this by providing you with this notice;
9.1.2. To correct or update the personal information we hold about you;
9.1.3. To object to the processing of your personal information;
9.1.4. To request a copy of the personal information we hold about you;
9.1.5. To ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
9.1.6. To ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
9.1.7. To ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;
9.1.8. To ask us to send your personal information to another organisation in a computer-readable format;
9.1.9. To complain to the Information Commissioner's Office if you are unhappy with our use of your personal information: you can do this at https://ico.org.uk/concerns/. Do contact us straight away if you consider that we are not handling your personal information properly so we can try to quickly resolve any issues.
9.2. If we delete your personal information or restrict our use of it, we will not be able to continue supporting you.
9.3. If you want to exercise any of your rights, please contact hello@oursankalpa.org 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 privacy policy was last updated 17th December 2020.