Introduction

The MacDougall Trust (Dorset) is a small grant making Trust.  Its income is derived from its own investments and acts as a clearing house and distributor of financial assistance for other local charities to residents of Dorset. This obviates the need for the MacDougall Trust to canvass for financial support from members of the public or other bodies.

The Trustees meet on a quarterly basis to consider applications for assistance from people resident in Dorset who are ’in necessitous circumstances’. Applications are made on the Trust’s application form. Applications have to be supported by a recognised agency or statutory body. Grants are awarded on the basis of the information supplied, and only in exceptional circumstances will they exceed £300. Trustees may, in some cases, make a contribution to a larger project. Generally the trustees require at least 3 years between applications from a single individual, except in exceptional circumstances.

General Data Protection Regulation 2018

On the 25th May 2018 the General Data Protection Regulations will come into force, which builds on existing legislation and which requires organisations to have in place procedures to ensure that any information held on individuals is kept safe and secure and is only used for the purposes for which it is held.

Its guiding principles are that all personal information will be:

  • Processed lawfully, fairly and in a transparent manner.
  • Collected for specific, explicit and legitimate purposes.
  • Adequate, relevant and limited to what is necessary.
  • Accurate and where necessary, kept up to date, with inaccuracies being erased or rectified without delay.
  • Kept in a form that permits identification of data subjects for no longer than necessary for the purposes for which personal data is processed.
  • 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.

All Trustees and the Data Protection Officer (Trust Administrator) are aware of the change in the Regulations and its principles.

The Trust will only hold information on Applicants in order to fulfil its obligations in relation to requests for financial support from people within the County of Dorset. Such information will not be shared with any other organisation. In the unlikely event that such a situation should arise, the Applicant’s permission will be sought to do so.

Applicants to the Trust will be told that the personal information they supply on their application form will only be used to allow the Trustees to make a decision on whether they are eligible for financial support.

The information held by the Trust will only be that information supplied by the Applicant themselves and any supporting professional information relating to the application.

Applicants will be advised that they have right of access to that information.

The Trust has a Retention of Information procedure and will respond positively to any request from an Applicant for information held on them.

The Trust will not use information held on Applicants for any purpose, other than as supporting evidence for their request for financial assistance.

The Trust will not share personal information of Applicants with any other organisation without the consent of the Applicant.

All information held by the Trust will be held in a secure location either by electronic or paper means. In the unlikely event that that there should be a breach of security, both the Information Commission Office and subject, will be notified.

The post of Data Protection Officer will be held by the Trust Administrator.

Personal Information

The Trust does not need to canvass for funds to carry out its aims and does not have or hold any personal information about individual supporters.

Individuals who are seeking financial assistance from the Trust complete an application form on which they supply personal information:

  • Family composition
  • Full names
  • Dates of birth
  • Addresses
  • Telephone number
  • Referring Agent
  • Reason for application
  • Social situation
  • Medical conditions
  • Financial circumstances
  • Assistance required
  • Other statutory bodies involved
  • Other Charities approached
  • Other relevant information

Trustees

The Trust holds personal information on the Trustees

  • Name
  • Date of birth
  • Address
  • Telephone number
  • E-mail address
  • Declaration of Interest details

Process of consideration for assistance

The Trust meets quarterly to consider any applications received. The Trust Administrator will prepare a résumé of the information from each application and send to the Trustees via the internet, or in writing prior to the meeting to allow them to consider the merits of the request, which are more fully discussed at the meeting. A decision will be made on whether the Applicant should be awarded a grant or not. A pledge of financial support can be made if the request is part of a multiple charity application for a sum higher than the Trust’s limit.

Applicants will be advised in writing of the Trust’s decision.

Personal Data

The Trustees fully endorse the principles that underscore and are laid out in the General Data Protection Regulations 2018.

Trustees are mindful of the often adverse personal nature of an Applicant’s circumstances and are vigilant in ensuring that the information supplied to support the application is treated with respect and sensitivity. It is therefore incumbent on all members of the Trust to ensure that any information they handle is kept safe and secure and is only used for the purposes for which it was supplied.

Data Protection Officer

The Administrator of the MacDougall Trust is the nominated person to hold the position of Data Controller under General Data Protection Regulation 2018 and is responsible for ensuring that confidential material is kept secure.

Requests for Personal information held by the Trust

The Trust will ensure that the Application Form clearly states that the Trust will only use the personal information supplied to allow the Trustees to make a decision on the circumstances of their application and will not be used for any other purpose.

This personal information will be retained for a period concomitant with the Trust’s retention of information period.

Following receipt of a request from an individual for information held on them by the MacDougall Trust, the Administrator will respond to that request.

Procedure for responding to an application for assistance and safeguarding of personal information

Applications

On receipt of an application for financial support to the Trust, the Administrator will log this on the Trust’s Applicants system and on a quarterly basis will collate a resume of all applications and distribute them to all Trustees via e-mail.

The Trust Administrator will ensure that all paper and electronic applications will be held in a secure location.

It is incumbent on all Trustees, on receipt of the applications to ensure that this information is stored on their computer in a restricted file to avoid accidental access to that file or, if in writing, in a locked and secure provision.

Following consideration of the applications Trustees will, confidentially destroy all copies of the résumé of the applications held on personal computer or on paper. The exception to this is where the application could not be resolved at the meeting and further information or outstanding issues remain to be clarified and, retention of the information will be required to make a final decision at a future date. Such information will be kept secure until the purpose for which it is retained has been resolved, and then be destroyed.

The Trust will retain the original application for a period of seven years.

Decisions

Following the decision of the Trustees on an application the Administrator will record the name of the applicant, the decision and where successful, the amount awarded.

It will be the responsibility of the Administrator to advise the Applicant of the outcome of the meeting and arrange for the individual processes particular to the case to be progressed. This may be in writing, e-mail or via the telephone.

The original application form will be stored by the Administrator in a secure and confidential manner in line with the Trust’s Retention Policy.

Application for personal information

Should any person who submitted an application, contact the Trust seeking to elicit personal information held on them in relation to a previous application for financial support from the Trust, they will be advised that this must be made in writing. Proof of identity will be requested.

Following a written receipt of an application for personal information, this should be acknowledged in writing by the Administrator within three working days.

In the circumstances where the Trust does not hold any information on the enquirer, or that their enquiry is beyond the date on which information is retained,  they should be informed of this in writing and no further action will be required.

Where information is currently held, a response will be made to the enquirer within 28 working days sending photocopies of all information. It is essential that a correct and secure address is supplied by the Applicant. All information should be sent by Royal Mail Recorded Delivery, at the Applicant’s own risk.

Information relating to children will be part of some applications for financial assistance from the Trust. The Trust will hold personal information on them including their dates of birth, as well as other information which would support the application ie a disability. The Trust will respond to any request from a young person over the age of sixteen years who seeks access to information held on them specifically.

No charge will be made for this service.

Third Party Enquires

It is essential that requests for personal information are scrutinised to ensure that the person requesting the information is the person to whom the information relates. This applies to situations where a person was in the past separated from the applicant or has subsequently separated and is inappropriately seeking information to which they do not have right of access.

Where a third party was mentioned in the application, they can be given that information, but they will be advised that the remaining information will be redacted and that they are not entitled to that information.

The Administrator should, in all cases where a request for personal information is being sought, whether no information is held or where information is held, advise the Chair of the Trust or nominated Trustee in their absence. A written record of all requests should be maintained.

Any breach of confidentiality will be reported to the Information Commission Office immediately it becomes known.

May 2018