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Data Protection & Privacy Policy 

Date of publication: 18 May 2018 

Date for review: 18 May 2020


Personal Data: information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, cookies and network identifiers.

Charity: means The Adsum Foundation, a registered charity (NIC 102284)

GDPR: means the General Data Protection Regulation

Responsible Person: means designated person responsible for data protection within the Charity

Personal Data Register: means a register of all systems or contexts in which personal data is processed by the Charity 


1. Data Protection Principles 

The Charity is committed to processing data in accordance with its responsibilities under the GDPR. 

Article 5 of the GDPR requires that personal data shall be: 

  1. processed lawfully, fairly and in a transparent manner in relation to individuals; 
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes; 
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; 
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; 
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and 
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General Provisions

  1. This policy applies to all personal data processed by the Charity.
  2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
  3. This policy shall be reviewed regularly.

3. Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Personal Data Register.
  2. The Personal Data Register shall be reviewed regularly.
  3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
  4. Individuals have the right to be forgotten and have their information securely deleted from the Personal Data Register. Should you wish for your personal data to be removed, contact the Charity directly.

4. Lawful purposes

  1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. The Charity shall note the appropriate lawful basis in the Personal Data Register.
  3. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and reflected accurately in the Charity’s systems.

5. Data minimisation and accuracy

  1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. The Charity shall take reasonable steps to ensure personal data is accurate.
  3. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

6. Archiving and removal of data

  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process regularly.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

7. Security

  1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 
  2. 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.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. 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 ICO (more information on the ICO website).

8. Online/Digital Privacy

a. Cookies

Cookies are text files stored on your computer, and accessible only to the websites which create them. The Charity website may from time to time use cookies and log files for statistical analysis, to understand user behaviour, to administer the site, to tailor the information presented to a user based on their preferences, and to improve user experience. Any information gathered by use of cookies is compiled on an aggregate, anonymous basis. Most web browsers automatically accept cookies; however, you may delete, or disable cookies by following the instructions at Further information about cookies can be found on the Interactive Advertising Bureau’s website

b. Social Media

If you share content through social media, for example by liking, following or tweeting about the Charity on various social media platforms, they will record that you have done so and may set a cookie for this purpose. In some cases, where a page on the Charity website includes content from a social network, such as a Twitter feed, or Facebook comments box, those services may set a cookie even where you do not click a button. As is the case for all cookies, the Charity cannot access those set by social networks, just as those social networks cannot access cookies set by the Charity.

c. Google Analytics

The Charity website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The information generated by the cookie about your use of the Charity website (including your IP address) will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the Charity website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Further information about Google’s privacy policy may be obtained from

d. e-Communications

By signing up to updates on the Charity website, you acknowledge having read this policy. The Charity may use your personal information to contact you with newsletters, marketing material or project updates. You may opt out of receiving these communications from the Charity by following the unsubscribe link or instructions provided in any email sent.

e. Links to other websites

This policy does not apply to the practices of companies that the Charity do not own or control or to people that they do not employ or manage. The Charity may provide a link or otherwise provide access to Third-Party Sites. These links are provided merely for your convenience. The Charity have no control over, do not review, and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. This policy does not apply to Third-Party Sites, and any data you provide to Third-Party Sites, you provide at your own risk. You are encouraged to review the privacy policies of any Third-Party Sites with that you interact with.

9. Policy Changes

The Charity reserve the right to update or change this policy at any time and you should check this privacy policy periodically. Your continued use of the Charity website and other services after any modifications to the policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.


If you have any questions about this policy, please contact the Charity.


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