The John Laing Charitable Trust (the Trust) provides welfare visits, other contact and support to former employees (and their spouses) of the John Laing Group of Companies (Group).
This Privacy Notice explains how the Trust collects, uses and discloses your personal data, and your rights in relation to the personal data it holds. Please note that this Privacy Notice only applies to the Trust and not to other entities within the Group.
If you are a member of one of The John Laing Senior Citizens’ Clubs (Clubs), please see the separate Privacy Notice issued by the relevant Club for an explanation of how the Club will use your personal data.
The Trust may change this Privacy Notice from time to time. However, any major changes will be notified directly to individuals whose personal data we hold, wherever practicable.
This Privacy Notice is effective from September 2019, when it was last updated.
The Trust is the data controller of your personal data and is subject to EU Regulation 2016/679 (the GDPR) and the UK Data Protection Act 2018 (the DPA).
In this Privacy Notice, us, we and our all refer to the John Laing Charitable Trust.
How we collect your data
We may collect your personal data in a number of ways, for example:
• Information may be passed to us by the Group (including to the Pensions and Payroll department of John Laing Limited) in order for us to be able to contact you about the charitable services and support we offer;
• From the information that you provide (or is obtained by us) when you meet with one of our welfare officers or representatives;
• When you complete and send us a financial statement that allows us to determine whether you qualify for financial assistance;
• When you register or enter your details on our website or at www.laingpastandpresent.co.uk;
• When you communicate with us by post, telephone, fax, email or other forms of electronic communication;
• If you are a spouse or other ‘next of kin’ of a previous employee of the Group your details may be passed to us by your partner or relative (i.e. the individual who was employed by the Group);
• When you attend one of the events or meetings that we support;
• When you provide bank details on the financial statement, by email or over the telephone in relation the receipt of financial assistance from us; and
• When you complete our surveys and questionnaires.
The categories of the data we collect
We may collect the following categories of personal data about you:
• Your name, date of birth and contact information such as address, email address and telephone number and those of your carers and ‘next of kin’ (and, on an ongoing basis, any change of address details);
• Previous history of your employment within the Group (this would only include your job title at retirement, your length of service at the Group, which part of the Group you were employed by and where you were employed);
• Medical information such as dietary requirements where we require this information to provide catering services to you at one of the events or meetings that we support. We may also record information about your health (including more comprehensive medical details) that is obtained from welfare visits, calls or other contact in connection with your welfare;
• Financial information you provide on the financial statement such as your income, your capital assets, country of tax residency, any benefits and allowances (including disability allowance) you receive, and your living situation;
• Information you provide about yourself when you post content on the Websites;
• Information concerning your engagement with the Trust, including records of communications between you and us and your attendance at events and meetings supported by the Trust; and
• Your opinion and feedback in relation to any surveys or questionnaires issued by the Trust that you complete, such as feedback on our charitable services and events.
The basis for processing your data, how we use that data and with whom we share it
1. Legitimate interests and public interests
We may process your personal data because it is necessary for our or a third party’s legitimate interests. This will always be weighed against your rights, interests and expectations. Examples of where we process personal data in accordance with our legitimate interests include:
• To correspond with you about our charitable services, including details of events and of our welfare services, that you have requested from us;
• To correspond with you about your welfare, where appropriate, and to provide support to you in relation to your welfare and any particular disability or medical condition that you may have;
• To evaluate whether you may qualify for financial assistance;
• For journalistic purposes, including to author and produce Trust newsletters (where you feature in them) and to send you these newsletters and other similar updates from time to time;
• Making certain of the contact information you provide us available on the Websites so that former colleagues may contact you;
• Processing technical information about your use of the Websites to ensure that content on our Websites is presented in the most effective manner;
• Processing enquiries, complaints and analysing our charitable services;
• Passing your name and contact details to The John Laing Senior Citizens’ Clubs (and/or to one of the Retirement Clubs in your local region) and the John Laing Limited pensions fund so that they can make contact with you;
• Researching our beneficiary database, including being made aware of retirees who become eligible to receive the Trust’s charitable services as beneficiaries; and
• Marketing our services, events and resources by post, telephone and electronic mail – except in situations where it is required or appropriate to seek your specific consent.
In this respect, we may also provide your personal data to the following (where this is necessary for our or a third party’s legitimate interests):
• The John Laing Senior Citizens’ Clubs (and/or to one of the Retirement Clubs in your local region) including those Clubs’ committee members, vice-presidents and president (currently, Lady Stephanie Laing), and/or to third party service providers who we may engage to assist in delivering the services to you: for example, event organisers, caterers, speakers and instructors;
• Our bank, to whom payment details are provided in order to process a payment made to you for financial assistance;
• Our Websites operator, who may store details such as name and email address to enable you to log in to our Websites;
• Our professional advisers, where it is necessary for us to obtain their advice or assistance; and
• Professionals who assist us in putting together, printing and delivering the Trust newsletter and Websites, and our IT support and data storage provider(s).
2. Legal obligations
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data to comply with subject access requests of others, tax legislation, safeguarding requirements (for example those required by the Charity Commission), for the prevention and detection of crime, and in order to assist the police and other competent authorities with investigations (including criminal investigations). In this respect, we may provide your personal data to our professional advisers, where this is necessary for us to obtain their advice or assistance.
In some circumstances the Trust may seek your specific consent to process your personal data: for example, if we wish to use your name, likeness or an attributed quote in our newsletter, on our Websites or in marketing materials.
If you have given your consent and you wish to withdraw it, please contact us using the contact details below. Please note that where our processing of your personal data relies on your consent and you then withdraw that consent, we may not be able to provide some aspects of our charitable services to you. Equally, where our processing of your personal data does not rely on your consent, we may not be able to fulfil your request (please see “Your rights” section below).
4. Use of medical information
We will occasionally seek consent when processing your medical information such as dietary requirements or other information about your health, such as for our records. At times the processing of personal data concerning your health may be necessary for private charitable purposes, substantial public interest purposes (including providing welfare support), or to protect your vital interests (such as your immediate safety) and it may not be appropriate to seek your consent in such circumstances.
Retention of your data
We may retain your personal data only for so long as is necessary to deliver our charitable services to you, and to protect our legal interests (for example where required by relevant authorities, or for a reasonable legal limitation period after we have ceased providing services to you) or as otherwise stated to you when your data is collected.
We will aim to review our beneficiary database annually and delete any information we consider no longer relevant.
Information about a deceased individual will only be held if they have a surviving spouse. After the death of the surviving spouse, both their details will be archived.
Under the GDPR and the DPA, you have the following rights:
• To be informed what personal data we hold about you and/or to obtain access to it (i.e. by receiving a copy of it in a permanent form);
• To require us to correct the personal data we hold about you if it is inaccurate;
• To request that we erase your personal data in certain circumstances;
• To request that we restrict our data processing activities in certain circumstances;
• To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• To object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights; and
• where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.
Please note that the above rights are not absolute, and we may be entitled or required to refuse requests where exceptions apply: for example if we have reason to believe the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Privacy Notice.
You can find out more about your rights under data protection legislation at www.ico.org.uk.
Questions and concerns
If you have any questions or concerns about how we process your personal data, or you wish to exercise any of the rights set out above, please contact the Trust’s data protection representative (Mr Alex Finkenrath) below by using the following details:
• By post: Data Protection Officer, The John Laing Charitable Trust, 33 Bunns Lane, London, NW7 2DX.
• By email: JLCT.email@example.com
• By telephone: 020 7901 3429
If you are not satisfied with how we are processing your personal data, you can raise a concern with the Information Commissioner (www.ico.org.uk).
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