Privacy Policy

This privacy notice tells you what to expect us to do with your personal information.
• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Security
• Breach
• How to complain

Contact details

Wheelwrights, West End, Northleach, CHELTENHAM, Gloucestershire, GL54 3EZ
Telephone: 01451 861284
Email: clerk@slytrust.co.uk

What information we collect, use, and why

We collect or use the following personal information for research or archiving purposes:
• Names and contact details
• Addresses
• Recorded images, such as photos or videos
• Records of consent, where appropriate

We collect or use the following personal information to comply with legal requirements:
• Name
• Contact information
• Identification documents
• Financial transaction information
• Criminal offence data

We collect or use the following personal information for recruitment purposes:
• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)

We collect or use the following personal information for In connection with the provision of housing:
• Names and contact details
• Gender
• Addresses
• Date of birth
• Emergency contact details
• Next of kin details
• Criminal offence data (including Disclosure Barring Service (DBS))
• Records of meetings and decisions
• Information about income and financial needs for funding or personal budget support
• Payment details (including card or bank information for transfers and direct debits)

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure - You have the right to ask us to delete your personal information.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing - You have the right to object to the processing of your personal data.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for research or archiving purposes are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o The charity receives donations of records, photographs and artefacts as one of its charitable objects to create an archive and museum of the history of the town. These may and often do identify individuals.

Our lawful bases for collecting or using personal information to comply with legal requirements are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o We use data for the purpose of providing affordable housing to the community and in order to ensure we comply with statutory obligations as to the creation of tenancy agreements.

Our lawful bases for collecting or using personal information for recruitment purposes are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for In connection with the provision of housing are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o We use data for the purpose of providing affordable housing to the community and in order to ensure we comply with statutory obligations as to the creation of tenancy agreements.

Where we get personal information from

• Directly from you
• Credit reference agencies
• Third parties:
o Letting agents

How long we keep information

Governance
Examples: Minutes of meetings, accounts, annual reports, policy documents
Retention term: Permanently

Effectiveness / impact
Examples: Decision making, processes and procedures, policies, correspondence, reports relating to AGM
Retention term: Minimum of 6 years

Donor data
Examples: Donor information, research and archiving
Retention term: Minimum of 7 years, or as agreed with donors

Safeguarding
Examples: Policies, volunteer checks, DBS
Retention term: Dependent on data

Risks (e.g. fraud, whistleblowing)
Examples: Documentary evidence and correspondence
Retention term: Review after 7 years, may need to be held longer if complaints contentious

Information about individuals
Examples: Trustee recruitment and contact details, tenancy information
Retention term: 7 years after the end of the term that the individual is associated with the Trust

Who we share information with

Data processors: Savills
This data processor does the following activities for us: They process information for the creation and management of tenancies

Others we share personal information with:
• Organisations we need to share information with for safeguarding reasons
• Professional advisors
• Legal bodies or authorities
• Local authorities or councils
• Relevant regulatory authorities
• Organisations we’re legally obliged to share personal information with
• Professional consultants

Security

The Charity shall ensure that personal data is stored securely using modern software that is kept up to date.

Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

When personal data is deleted, this will be done safely such that the data is irrecoverable.

Appropriate back-up and disaster recovery solutions shall be in place.

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioners Office within 72 hours (including weekends or out of working hours).

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

Last updated: March 2025