Welcome to the Privacy Policy of The Nazareth Trust.
We are committed to properly protecting the personal information of everyone who interacts with us (whether as a supporter, a donor, a volunteer or a visitor to an event of ours or our websites or a person who otherwise interacts with us by sending us an enquiry or other communication of any kind).
We have developed this Privacy Policy to explain how we manage and use this personal information and to ensure we comply with our legal obligations under applicable data protection laws.
It is important that you read this privacy policy carefully so that you are fully aware of how we collect and process personal information.
THE NAZARETH TRUST – WHO WE ARE
This Privacy Policy covers the personal information collected and held by The Nazareth Trust.
Following the teaching and example of Jesus of Nazareth, the Trust, unique in its position in the Middle East, aims to reach out to the local population and to the wider world, irrespective of faith, political persuasion or tradition, through healthcare, education, proclamation and service. We work towards this in our four main areas of work, the Nazareth Hospital EMMS, the Nazareth Academic School of Nursing, the SERVE international volunteering programme and the Nazareth Village.
The Nazareth Trust is the operating name of EMMS Nazareth, a company registered in Scotland (company no. SC225661) and a Scottish Charity (no. SC032510).
Our registered address is: Annan House, 10 Palmerston Place, Edinburgh EH12 5AA, UK
THE CONTROLLER OF YOUR PERSONAL INFORMATION
Under applicable data protection laws, we are required to advise you who is the controller of your personal information. The controller of, and the person responsible for, the personal information covered by this Policy is the Nazareth Trust. Contact details for the controller are set out below under “HOW TO CONTACT US“.
TERMINOLOGY USED IN THIS POLICY
“Special categories of personal data” may include information about race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions an/or, trade union membership, as well as information about health and genetic and biometric data.
“TNT“, “we” “us” and “our” refer to The Nazareth Trust.
“you” and “your” refer to a person whose personal data we hold because of some interaction between us and that person, whether that person is a supporter, a donor, a volunteer, a contact, a visitor to our website or an enquirer.
PERSONAL INFORMATION WE COLLECT AND HOLD AND THE PURPOSE FOR WHICH WE USE IT
What personal information do we collect about you?
The personal information we collect may include:
(i) title, name, email address, home and/or business address, phone number;
(ii) date of birth, gender;
(iii) job title, education and career, church affiliation;
(iv) bank account and payment card information;
(v) transactional data including details about donations from you;
(vi) information relating to our interactions with you, i.e. emails, letters, phone calls, meeting notes;
(vii) marketing preferences; and
(viii) any other personal information you may provide during interactions with us.
Special categories of personal data will only be collected where necessary, for example we may need to collect health information from you when you register with an event or volunteer in certain ways. If so, we will explain to you at the time we need to ask for this information why we need it.
How is your personal data collected?
We will collect this data from you when you provide it to us by phone, email, post, through our website or in person.
What do we use your personal information for?
We intend to use your personal information for the following purposes:
(i) to process donations, which includes claiming Gift Aid;
(ii) to respond to your enquiries and other communications;
(iii) to carry out fundraising and send you direct marketing and promotional materials (see below under MARKETING TO YOU);
(iii) to administer and manage our relationship with you, which may include asking you to complete surveys or feedback forms;
(iv) to conduct profiling of our supporters or potential supporters, such as analysing your interactions with us, your responses to appeals or event attendance. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications.
(v) in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, processing your order and payment for a product from our Nazareth Village online shop.
(vi) where required to comply with a legal obligation; and
(vii) where necessary to protect your health or well-being or that of another individual.
Legal basis for processing your information
We will only use your personal information as the law permits. By law we are required to tell you the legal bases upon which we rely in processing your personal information. The legal bases we principally rely upon are these:
(i) you have given your consent to the processing; and/or
(ii) it is necessary for the performance of a contract between us or in order to take steps at your request prior to entering into such a contract; and/or
(iii) it is necessary for the purposes of our legitimate interests in pursuing and developing our charity, where such interests are not overridden by your rights or interests.
Occasionally we may also rely upon the following legal bases for processing:
(iv) it is necessary for us to comply with a legal obligation on us; and/or
(v) it is necessary to protect your vital interests or those of another individual.
Where we rely on consent to process your personal information, you may withdraw that consent at any time by contacting us using the contact details set out under “HOW TO CONTACT US” below.
MARKETING TO YOU
You may receive marketing communications from us: –
(i) if you have specifically requested that information from us; or
(ii) by email or post if you have opted in to receiving marketing from us;
(iii) by post, if you are a previous donor or supporter and have not opted out of receiving that marketing (which you may do by contacting us using the contact details set out under “HOW TO CONTACT US” below).
Otherwise, we will not send you any marketing communications unless we have your explicit consent.
Please note, you can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the contact details set out under “HOW TO CONTACT US” below.
SHARING YOUR PERSONAL INFORMATION WITH OTHERS
We will not disclose personal information we hold about you to any third party except where required by law or as follows:
(i) to third parties who provide services to us, and act as data processors for us, such as mailing houses;
(ii) to professional advisers including lawyers, bankers, auditors and insurers;
(iii) to HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
Our principal activities take place in Israel so we may require transferring your data to Israel. Israel is considered by the EU authorities as a country with adequate protection for personal data.
Our main supporter database is hosted at a data centre located in the U.S. with a company certified under the EU-US Privacy Shield, which requires it to provide similar protection to personal data as is required in Europe.
Whenever we do transfer your personal data out of the EEA (except to Israel), we shall ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards applies:
• the countries to which it is transferred have been deemed to provide an adequate level of protection for personal data by the relevant regulators;
• we have put in place with the transferee specific contracts approved by the relevant regulators which give personal data similar protection to that it has in Europe; or
• if the transferee is in the US, it is registered with the Privacy Shield (or any similar replacement scheme).
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see under YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS/ to request erasure below for further information.
We will take all reasonable steps to destroy, or erase from our systems, all the personal information we hold about you when it is no longer required
YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. It also enables you to request that we delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
to request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
to request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; or
to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to take actions you have requested. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us by using the contact details set out below under “HOW TO CONTACT US” below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you wish to exercise any of those rights, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO THIS POLICY
We may need to make changes to this Privacy Policy from time to time to take account of changes in law or for other reasons. Please refer back to this page regularly to see any changes or updates to this Policy.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
HOW TO CONTACT US
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:
By Post: The Nazareth Trust, Annan House, 10 Palmerston Place, Edinburgh EH12 5AA, UK
By Email: dataprotection@nazarethtrust.org
COMPLAINTS
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection laws you have the right to lodge a complaint at the Information Commissioner’s Office (ICO) (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Last updated 24.08.2022
