Data Protection Policy

Last UpdatedMarch 2022


Charitymeans The Charity for Mary Anne Rawson for Wincobank School , a Charitable Incorporated Organisation Number 1107105, which owns Upper Wincobank Undenominational Chapel (UWUC), and The Old School House ( OSH).
GDPRmeans the General Data Protection Regulation. 
Responsible Person means the Data Protection Officer as assigned by the Trustees of the Charity  
Register of Systems means a register of all systems or contexts in which personal data is processed by the Charity. 

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;

  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.” 

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 at least annually.  

  4. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data, unless exempt.  

Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.

  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.

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 Register of Systems.

  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data. 

  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems.  

Data Minimisation

  1. The Charity shall ensure that personal data collected is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.


  1. The Charity shall take reasonable steps to ensure personal data is accurate.

  2. 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.  

Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Charity shall review tdata held annually

  2. Personal data will only be retained if there is reason to do so in line with the original consent.  


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


  1. 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).  


The trustees of the Charity of Mary Ann Rawson for Wincobank School, which owns Upper Wincobank Undenominational Chapel are committed to being transparent about how we collect and use personal data and to meeting our data protection obligations. 

What is personal data? 

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

Who are we? 

This Privacy Notice is provided to you by the trustees of the Charity of Mary Ann Rawson for Wincobank School, which is the data controller for your data. This means it decides how your personal data is processed and for what purposes. 

What information do we collect? 

The trustees or their representatives may collect and processes a range of information about you. Depending on your involvement with the Charity this will include some or all of the following: 

  • Your name, title, address and contact details, including email address and telephone number 
  • Demographic information such as gender, age, date of birth, marital status, nationality, education, work histories, academic and professional qualifications, hobbies, family composition and dependents 
  • Information about your next of kin, dependents or emergency contacts 
  • Information about your criminal record 
  • Details of any voluntary activities you undertake at Upper Wincobank Undenominational Chapel 
  • Information about medical or health conditions, including whether or not you have a disability for which Upper Wincobank Undenominational Chapel needs to make reasonable adjustments 
  • Bank details and payment card numbers 

The Charity may collect this information in a variety of ways 

  • Consent forms (for activities and groups) 
  • Email, written or telephone requests for further information 

How do we process your personal data? 

The trustee board of The Charity for Mary Anne Rawson for Wincobank School complies with its obligations under the General Data Protection Regulation (GDPR) by: 

  • Keeping personal data up to date 
  • Storing and destroying personal data securely 
  • Not collecting or retaining excessive amounts of data 
  • Protecting personal data from loss, misuse, unauthorized access and disclosure 
  • Ensuring that appropriate technical measures are in place to protect personal data 

Why do the trustees process personal data? 

We use your personal data for the following purposes: 

  • to enable us to meet all legal and statutory obligations  
  • to carry out comprehensive safeguarding procedures 
  • to administer records of participants at groups we run 
  • to fundraise and promote the interests of the charity 
  • to manage our employees and volunteers 
  • to maintain our own accounts and records 
  • to inform you of news, events and activities running at Upper Wincobank Undenominational Chapel 
  • to send you communications which you have requested and may be of interest to you 
  • to process a grant or application for a role 

Some special categories of personal data, such as information about health or medical conditions, is processed to allow appropriate action to be taken in the event of a medical emergency. 

The data we process may constitute sensitive personal data. 

What is the legal basis for processing your personal data? 

Most of our data is processed because it is necessary for our legitimate interest. An example of this is safeguarding to protect children and adults at risk. 

Some processing is necessary for the performance od a contract or entering into a contract. An example of this would be hiring out of the premises. 

Where your information is used other than in accordance with one of these legal basis, we will first obtain your consent to that use. For example, your explicit consent will be sought so that we can keep you informed about news, events and activities at the Chapel. 

Who has access to your data? 

Your personal data will be treated as strictly confidential and will only be shared with other trustees or group leaders in order to carry out a service or for purposes connected with Upper Wincobank Undenominational Chapel. We will only share your data with third parties outside Upper Wincobank Undenominational Chapel where it is necessary for the performance of our tasks or with your consent. 

Upper Wincobank Undenominational Chapel may also share your data with third parties in the context of transfer of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements. 

How do the trustees protect data? 

The trustees take the security of your data seriously. The trustees of Upper Wincobank Undenominational Chapel have internal controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by office holders and volunteers in the performance of their duties. 

Data will be stored in a range of different places including 

  • on password protected files on computers 
  • on paper in secure storage 

How long do the trustees of the Charity keep personal data? 

Data will be retained only as long as is necessary for the original purpose of consent or for legal purposes.  Data will be reviewed on an annual basis.