Last updated: 28.12.2021

1. Your personal data – what is it?

Personal data relates to an individual who can be identified from data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”). 

2. Who are we?

Smile Burundi, Charity No ######, is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes. 

3. What data do the controllers listed above process?

They will process some or all of the following where necessary to perform their tasks: 

  • Names, titles, and aliases, photographs; 
  • Contact details such as telephone numbers, addresses, and email addresses; 
  • Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependants; 
  • Where you make donations, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers; 
  • The data we process is likely to constitute special category data because of the religious beliefs an individual may share with Smile Burundi in support of their work.  

4. How do we process your personal data?

Smile Burundi complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the following purposes:

  • To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our memorandum and articles of association; 
  • To administer the running of various activities such as fundraising events. 
  • To fundraise and promote the interests of Smile Burundi 
  • To manage our volunteers; 
  • To maintain our own accounts and records (including the processing of gift aid applications); 
  • To enable us to meet all legal and statutory obligations; 
  • To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments; 
  • To inform you of news, events, activities, and services running in partnership with Smile Burundi 
  • Sharing your details (with your explicit consent) with other members for the purposes of congregational communication; 
  • To comply with legal obligations with regard to health and safety and safeguarding

5. What is the legal basis for processing your personal data?

  • Explicit consent of the data subject so that we can keep you informed about news, events, activities, and services and process your gift aid donations and keep you informed about diocesan events. 
  • Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement; 
  • Processing is necessary to carry out the legitimate interests of Smile Burundi in terms of the administering of fundraising events and donations for the benefit of the public; 

6. Sharing your personal data

Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks where we are legally required to share your personal data, where we share your personal data to protect a Smile Burundi member or another individual, or where you first give us your prior consent. It is likely that we will need to share your personal data with some or all of the following (but only where necessary):

  • Other members of Smile Burundi (with your consent);
  • Public Bodies and Government departments (e.g. HMRC for Gift Aid Claims;
  • On occasion, with churches with which we are carrying out joint events or activities. 

7. How long do we keep your personal data?

We keep data in accordance with our data retention policy. Smile Burundi will retain data only for as long as is necessary and no personal data in any form will be held for longer than is necessary. This means that we may delete it when it is no longer needed. 

Certain types of data will therefore be kept for longer periods than others based on what is deemed necessary or based on certain legal requirements. 

Certain data may be processed for a number of different purposes and therefore different access and use policies will be in effect. When it is deemed that it is no longer necessary to retain data for one particular use, but it is necessary to retain data for other uses, then the policy of access and use for the remaining necessary purposes will be followed. 

For example: a person and their contact details may be removed from our active user database whilst their details are retained on the gift aid database and form with the appropriate limited access and security overuse. The active database will be reviewed by relevant Smile Burundi trustees with access on a quarterly basis. The purpose of this review will be to check the accuracy of the data and remove any data where the retention period has lapsed. 

A full data review of all digital and physical personal data will be conducted annually for the purpose of complying with the data retention policy. Specifically, we retain visitor, congregation, and supporters data whilst it is still current; employment information and records for 6 years after the financial year to which they relate; gift aid declarations, financial records, and paperwork for up to 6 years after the financial year to which they relate; children’s group registers for 7 years and the baptism register and any records relating to safeguarding matters permanently. 

8. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: 

  • The right to request a copy of your personal data which Smile Burundi holds about you; 
  • The right to request that Smile Burundi corrects any personal data if it is found to be inaccurate or out of date; 
  • The right to request your personal data is erased where it is no longer necessary for Smile Burundi to retain such data; 
  • The right to withdraw your consent to the processing at any time;
  • The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, (where applicable)
  • The right to lodge a complaint with the Information Commissioner’s Office. 

9. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing. 

10. Changes to this notice

We keep this Privacy Notice under regular review, and we will place any updates on our website. If we make a significant change, we will notify you. This Notice was last updated in December 2021. 

11. Contact Details

To exercise all relevant rights, queries or complaints please in the first instance contact: contact@smileburundi.org.

You can also contact the Information Commissioner’s Office on +44 (0) 303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.