Confidentiality and Privacy Policy
- Introduction
- One of the underlying principles of Sussex Police Charitable Trust (SPCT) is that it provides help and support to members on a confidential basis, enabling people to enjoy the benefits membership brings, without the worry of exposing personal difficulties and other information to Sussex Police, or colleagues. Accordingly, confidentiality is an important aspect of how SPCT is managed.
- All data held by the Sussex Police Charitable Trust will be processed in full accordance with UK GDPR and the Data Protection Act (2018).
- In particular information will:
- be processed solely to enable the SPCT team to conduct their services effectively;
- be adequate, accurate, up to date, relevant and not excessive;
- not be kept for longer than is necessary and will be kept securely.
- A common law duty of confidence exists between SPCT staff and members. Confidentiality would only be compromised in the most exceptional circumstances, such as:
- you give explicit consent;
- there is an agreement in place with Sussex Police (see point 2.3);
- the breach is to prevent harm to anyone;
- a legal duty overrides. Wherever possible we will always seek to discuss any concern directly with you before taking any such action.
- Information sharing with Sussex Police
- As separate legal entities, Sussex Police and SPCT are responsible for their own data control, in line with UK GDPR and the Data Protection Act (2018).
- Details of the Trust’s membership are jointly maintained by Sussex Police and the Trust, with only essential information shared to identify individual membership and process subscriptions.
- SPCT use Sussex Police IT systems to store their data. While it is technically possible for Sussex Police to view data owned by SPCT that is held on its IT systems, a Memorandum of Understanding exists between the two organisations that stipulates that information will only be accessed or shared between Sussex Police and SPCT where there is a lawful business purpose, such as criminal and misconduct investigations.
- However, where Sussex Police is carrying out a misconduct investigation, emails sent to and from the work account of the individual being investigated may be viewed but not the SPCT accounts themselves as the Trust is not under investigation. Therefore, emails sent to and from an individual’s personal account and SPCT will not be monitored.
- How we collect information from you
- When you join Sussex Police Charitable Trust or the Death Benefit Scheme (a Sussex Police initiative administered by SPCT), you give your name and address, date of birth and personnel number either on a paper or online form. When you join the Death Benefit Scheme you may also give the name of someone you would like to be your beneficiary in the event of your death.
- Should you approach the Trust for support, you are likely to give other personal data and information which is sensitive, such as details about health.
- When you retire from Sussex Police, or if you contact us and have already retired, we ask you if you would like to go on our mailing list. We then collect your email address and/or your postal address if you would prefer to receive information by post.
- The ‘legal basis’ on which we collect information from you is known as ‘legitimate interests’ under UK GDPR. SPCT has used self-assessment questionnaires provided by the Information Commissioners Office (ICO) to ascertain this.
- Collecting the information from you allows the Trust to confirm that you are a member of SPCT and/or the Death Benefit Scheme so that you to benefit from these services.
- Sensitive data is collected from you, if you volunteer it, on occasions when and if you require the services of the Trust.
- How your information is used
- Only your membership of SPCT and the Death Benefit Scheme will be noted on the Sussex Police personnel system.
- If you are in paid employment with Sussex Police, applications for SPCT and Death Benefit Scheme membership are sent to the Sussex Police payroll team. Payroll then recover membership fees from your salary.
- Any sensitive information you give to SPCT is to enable appropriate support to be given to you.
- Where your data is used for any other reason, we will first obtain your consent.
- Depending on which services you engage us to deliver, we may use your information to:
- contact you by post, email or telephone;
- understand your needs and how they may be met;
- process financial transactions;
- administer and manage our service.
- We are required to retain your data for six years from when you have ceased to be in contact.
- Who has access to your information
- SPCT staff and volunteers with access to your information have a duty of confidentiality as described above.
- Information is not given to third parties without your consent or an alternative lawful purpose, bearing in mind that membership details are shared with Sussex Police.
- Any applications to SPCT’s Funding Panel for grants or loans are anonymised. Individual situations are described in applications to demonstrate that a member is in hardship, need and/or distress. However, to protect members’ privacy, details such as names, rank, role in relation to Sussex Police and protected characteristics are not revealed, as far as is practicably possible.
- How your information is stored
- All personal and sensitive information is held securely in lockable storage and electronic files, accessed only by SPCT staff and volunteers for service delivery purposes. See point 2.3.
- How you can access and update your information
- You have the right to ask for a copy of the information SPCT holds about you.
- You have the right for SPCT to transfer your data to a third party with your explicit consent.
- If you would like any further information about how SPCT uses your personal and sensitive data or you have any concerns about how your data is or may be used, please contact:
Karen Barford, Charity Manager, Sussex Police Charitable Trust
Tel: 01273 404535 Extension 544133
Email: [email protected]
Last reviewed and approved by Trustees: 25 April 2024