PRIVACY NOTICE

Updated 15th November 2022

INTRODUCTION

WTC values everyone who engages with us by whatever means, and as such we do all we can to protect your privacy and to make sure any personal data you provide us is kept safe and only used in line with your wishes.

This policy explains how we collect data, how we use and store information and what it means for you.

We aim to treat anyone who engages with us in line with our values and we welcome any feedback on any of our actions. Just call us on 0300 040 6200 or email operations@wtctheology.org.uk

WHO WE ARE

WTC is a charity registered in England and Wales, number 1123573. We are also a company limited by guarantee, number 6506007. Our registered office address is:

Suite 5 Winchcombe House
5-39 Winchcombe St
Cheltenham
Gloucestershire
GL52 2NA

For the purposes of this Policy, ‘us’, ‘we’ and ‘our’ refer to Westminster Theological Centre (WTC).

WHAT INFORMATION DO WE COLLECT?

From public website interaction with us

We collect non-personal data such as IP addresses, details of pages visited and files downloaded. Website usage information is collected using cookies, see the section on Cookies below.

From student applications

If you apply to become a student with us, you will supply us with quite a lot of information about yourself, including sensitive information, such as physical or mental health conditions, or unspent criminal convictions.

Indirectly from 3rd parties

We collect information from 3rd parties such as event organisers (i.e. EventBrite) or fundraising sites like Just Giving. You may wish to check the privacy policies of such organisations when you give them details about yourself.

From publicly available data

We may collect information about you from Companies House, the Charity Commission, and information published in articles or on websites.

Directly with us

Each time you deal with us we collect your personal information. For example, when you email us, sign up for an event, request information, donate or complete a survey, we collect the information you provide.

Sensitive data

Where you provide the information, we may collect sensitive personal data, including, but not limited to, your religious beliefs, or your physical or mental health.

WHAT DO WE DO WITH YOUR DATA?

Processing of requests / donations / calls to action

We may use the personal data we collect to:

• – Respond to questions that you have asked us
• – Keep you up to date on events that we are planning
• – Provide information on new courses that we are offering or other resources which you may find interesting
• – Provide prospectuses or flyers for events
• – Keep records of your relationship with us e.g. questions you have asked or details about conversations we have had about your studies / potential studies
• – Ask for financial and non-financial support, such as volunteering or prayer
• – Process donations you give us, or to support your fundraising for us, including gift aid
• – Analyse the personal information we collect about you to aid our understanding of our students and potential students
• – Conduct market research to aid our understanding of our partners and supporters.

We may use publicly available information such as newspaper articles, or information you have given permission to other organisations to share, such as Linkedin, to identify supporters and non supporters, including trustees, who have expressed an interest in giving major gifts or having a public profile with charities like WTC.

Processing of Student Personal Data

If you become a student on one of our validated programmes you will have provided a lot of personal information on your application form. Below are some examples of why we need this information:

• – To assess your suitability to study
• – To enable us to tailor necessary support to ensure you succeed in your studies
• – As the basis for how we communicate with you during your studies
• – To register you with the University of Chester
• – To comply with Higher Education Institution requirements for submission of generic and anonymised statistics relating to our students
• – If you have a conviction which is unspent, then we will also use your data to conduct a risk assessment before you begin your studies with us.

Processing of Student Bursary Applications

If you apply for a WTC student bursary we collect information from you relating to your household income and other pertinent facts relating to the criteria for bursary assessments. This application is only accessible to WTC employees on a ‘need to know’ basis in line with our Data Handling Policy and the information supplied is only used in assessing eligibility for a bursary.

Processing of Principal’s Bursary Fund Applications

If you apply for a Principal’s Bursary you will have provided us with details of past convictions and addictions in order that we can assess whether you meet the criteria to be awarded this bursary type. You will also have given us your permission to contact your church leader or mentor to discuss your suitability for study. All information in this application will only be made available to employees of WTC on a ‘need to know’ basis.

Basis of processing your data

The basis of processing all our data is in line with the regulations contained within the General Data Protection Regulation coming into force on 25 May 2018.

• – Consent as a Student: When you apply to become a student on one of our validated courses, you provide information to us on the basis that it is used to maintain contact with you and provide support throughout the duration of your studies
• – Consent as a Student of non-validated programmes (i.e. WTC Resource): When you register for one of our short, free courses, you provide your information to us in order that we can give you access to our online learning platform. We also collect additional information that helps us to understand who is interested in our courses and for market analysis
• – Consent as a Supporter: If you are a new supporter coming on board for the first time, on or after 25 May 2018 we will process your personal data on the basis of the consent you provided us with. You are free to change your preferences at any time by contacting us by telephone, post or email as shown in the section ‘Your choices and telling us when things change’ below
• – Consent as a Customer: If you purchase something from us, we use your personal information to enable us to fulfill your order. We also collect additional information that helps us to understand who is interested in our products and for market analysis
• – Legitimate interest: If you are an existing supporter or contact as at 25 May 2018, we may continue to contact you by email where you have previously given us your consent. We may also contact you by post or telephone where we have a legitimate interest to do so. For example, where you are or have previously been a student with WTC or made a donation to us, we may continue to send you information about the work your donation is making possible or events that we are running which you may be interested in. Where you have previously asked us not to contact you in this way we will continue to respect your contact preferences. You can change your preferences at any time or object to us processing your data by contacting us by telephone, post or email as shown in the section‘Your choices and telling us when things change’ below.

Applying for a job or volunteering with us

Where you provide personal data and sensitive personal data when applying for a job with us, such as the information on your CV we will process, store and disclose the personal data we collect to:

• – Support the recruitment process
• – Enable you to submit your CV, and apply online for jobs
• – Answer any questions you may have
• – Use third parties to provide services such as references, qualifications, criminal referencing, checking services, verification of information you have provided, health screening and psychometric evaluation or skills tests
• – Provide anonymised data to monitor compliance with our equal opportunities legislation.

If you have applied for a Hub Director, or associated post, where your appointment is contracted to the Hub Church, your application details will be shared with the church in question.

HOW AND WHERE WE STORE YOUR INFORMATION

All data is used and stored in line with our Data Handling Policy (available on request from operations@wtctheology.org.uk).

How long ?

We will keep your personal information only for as long as we consider it necessary to carry out each activity.

We will retain details of donations and all financial transactions for 7 years to meet tax and accounting requirements.

We will retain details of job applicants for 6 months following an interview.

Legacy income is an important source of income for WTC. We may keep the data indefinitely of those leaving us legacies in order to administer them and to communicate with the families of those who have left us a gift.

Security

We ensure that we have in place appropriate technical controls to protect any personal  data you provide.

We ensure that access to personal data is restricted only to those staff members or volunteers whose job roles require such access and that suitable training is provided for these staff members and volunteers.

However, we need to remind you that despite all our efforts, the internet cannot be guaranteed to be 100% secure, and that you submit data at your own risk.

COOKIES

What are Cookies?

The use of cookies is an industry standard for most major websites. A cookie is a text file that is sent from our website as soon as you visit our site. It is stored on your computer’s hard drive and helps us to identify your computer (not you) and collects information in an aggregate, anonymous way.

Cookies may be used to collect information about your visit to our website, for example, traffic data, location data, device information, the date and time of your visit and the pages that you visit.

To enjoy the WTC websites to the full, we recommend that you leave cookies turned on. If you turn off cookies then you may not be able to enter parts of the site.

The cookie data that we collect may be used to:

• – Customise the content on our website and to help understand the visitors current and future needs
• – Process any requests, applications or transactions you may make
• – Aid internal administration and analysis.
  

Managing Cookies

Most browsers allow you to turn off the cookie function. To do this you can look at the help function on your browser.

Third-party Cookies

WTC works with a number of third-party suppliers who set cookies on our websites to enable them to provide us with services. These are mainly used for reporting and advertising purposes so we can improve the way we communicate.

We use websites such as Youtube and Vimeo to embed videos and you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third party website for more information about their cookies and how to manage them.

WTC also uses third party suppliers such as Facebook and Google Analytics, these providers may use cookies. They may also use tracking pixels, which are commonly found in advertising to track the effectiveness of adverts.

As some of these services may be based outside of the UK and the European Union, they may not fall under the jurisdiction of UK courts. If you are concerned about this you can change your cookie settings (see above).

WHEN WE SHARE YOUR INFORMATION

We do not share or swap your information with any other charities or marketing organisations.

If you are a student on one of our validated programmes, we share some of your personal data with the University of Chester in order to enrol you as a student.

Legal duty

We may need to pass on information if required by law or by a regulatory body. For example, a Gift Aid audit by the HMRC, or if asked for details by a law enforcement agency.

YOUR CHOICES AND TELLING US WHEN THINGS CHANGE

Preferences

You can change your preferences on what you receive from us, including marketing and fundraising materials at any time.

You can do so by:

• – Clicking on the relevant link at the bottom of emails you receive from us
• – Calling us on 030 0040 6200
• – Emailing us at operations@wtctheology.org.uk

Updating your details

Please let us know if you details change so that we can keep them up to date. You can do this by emailing us at: info@wtctheology.org.uk

Telling us to stop processing and storing

You have the right to ask us to erase your personal data, to ask us to restrict our processing or to object to our processing of your personal data. You can do so at any time by emailing us at info@wtctheology.org.uk or by writing to us at:

Director of Operations
WTC
Suite 5 Winchcombe House
5-39 Winchcombe St
Cheltenham
Gloucestershire
GL52 2NA

ACCESS TO YOUR INFORMATION

You have the right to request details of the information we hold about you. To receive a copy of the personal information we hold please write to our Data Protection Lead at the address given above, and we will respond to you within 30 days of receipt of your letter.

CHANGES TO WTC’S PRIVACY POLICY

We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other legislation. If we make any significant changes to this policy we will show this clearly on our website or by writing to you directly. By continuing to use our website or our services, you will be deemed to have accepted these changes.