Johnny Foundation GDPR Policy


Contents Page

Introduction 2

1. Why is data protection important? 2

2. How does it apply to staff and volunteers? 2

3. What trustees and volunteers need to do 2

Data stored needs to be:

a) Fairly and lawfully processed

b) Processed for specified purposes 

c) Adequate, relevant and not excessive

d) Accurate and, where necessary, kept up to date

e) Not kept for longer than is necessary

f) Processed in line with the rights of the individual

g) Kept secure) Not transferred to countries outside the European Economic Area unless the information is adequately protected. 

4. Privacy Statements for website 5

5. Contact details 7








The Johnny Foundation staff and volunteers process and work with personal data to enable children to be sponsored to attend school, and on occasion obtain and pay for medical and other needs. These guidelines have been produced as a guide to ensure that the Johnny Foundation complies with current Data Protection legislation. The information in this policy is derived from the Guide to the General Data Protection Regulation (GDPR), the requirements of the Data Protection Act 1998, the Privacy and Electronic Communication (EC Directive) Regulations 2003 and guidance issued by the Information Commissioner’s Office (ICO). Further detailed guidance can be obtained from the Information Commissioner’s website – see organisations/guide-to-the-general-data-protection-regulation-gdpr/

1. Why is data protection important?

All public and private organisations are legally obliged to protect any personal information they hold. This document provides guidance to staff and volunteers who work with congregation members’ and visitors’ personal data. Personal data includes names and contact details.

2. How does it apply to staff and volunteers?

As part of the Johnny Foundation, trustees and volunteers need to comply with the requirements of the legislation. The trustees hold, maintain and enforce the policy and guidance. The Trustees are required to ensure that any personal records they keep are maintained using the guidance included in this document. Data Protection legislation requires organisations to take care over the personal information on individuals that they hold and to use it only for relevant communication. Broadly, the Act covers any information held on a computer that relates to living individuals. For example, this may include information such as name, address, date of birth and opinions about the individual, or any other information from which the individual can be identified.



3. What staff & volunteers need to do

Trustees, are responsible for ensuring that any personal data is processed in accordance with the principles of the Data Protection Act. Where an issue arises with respect to data protection, volunteers should follow the advice provided on these pages.


a) Fairly and lawfully processed

The General Data Protection Act requires organisations to ensure that all personal data is processed fairly and lawfully and that they are open and honest (transparent) about the reasons for obtaining the data. In practice, this means that trustees and volunteers must be clear as to why they are collecting personal data and what they intend to do with it. The privacy notice / statement stipulates that individuals must give their consent to the processing of personal data for the purposes specified. It is suggested that they are also asked for their preference in how they wish to be contacted. If they are vulnerable adults or children, permission to use the specified methods of communication should also be sought.

Registration data should only be used for:
i. Managing membership status and subscriptions
ii. Providing effective and appropriate membership services
iii. Communicating with members with regard to organisational issues

b) Processed for specified purposes

Trustees must never pass on information about sponsors or children to other individuals or organisations without explicit consent being obtained.

c) Adequate, relevant and not excessive

Only data needed for the specific purpose should be asked for or recorded. Information that is not relevant for the purpose must not be collected simply because it might be useful in the future.

d) Accurate and, where necessary, kept up to date

The Data Controller should ensure that any database is maintained and kept updated to ensure effective communication with those people sponsoring or supporting children. The Data Controller and Trustees should ensure that sponsors are able to simply update or change their contact details, (to make any changes that are required). On receipt of any updated information, previous information should discard or archive previous records and replace them with the new information where appropriate. It is important that inaccurate and out of-date information is regularly deleted/destroyed and inaccurate records corrected (i.e. archived either digitally or in hard copy and stored in accordance with diocesan rules on how long records should be kept. Where paper records are to be destroyed they should be shredded.)



e) Not kept for longer than is necessary

It is important that appropriate data retention periods are defined and adhered to. In essence, data should not be retained for any longer than is necessary to fulfil the reason it was collected.

f) Processed in line with the rights of the individual

Under the GDPR in the UK, children are able to give consent for their photos to be used at the age of 13. (Further details of how to obtain consent for taking pictures and video can be found in All Saints guidelines for taking of photos and video).

g) Kept secure

In all cases great care must be taken to secure and maintain any personal data held, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. Volunteers processing data must ensure that: 

i Access to laptops/computers where personal data is stored is restricted to authorised users only;

ii Any database passwords are kept secure and not shared with other people;

iii Computers/laptops containing personal data should always be stored securely – i.e. not left in a vehicle overnight;

iv. Data collection through the website must be done with appropriate security policies and the latest security software in place;

v. All paper records are stored securely and locked away.

h) Not transferred to countries outside the European Economic Area unless the information is adequately protected.

If you are using bulk email tools or storing data on websites it is possible that the servers are located outside the European Economic Area. It is recommended that you only use services provided by companies who host data within the UK or have signed the appropriate safe harbour agreements. For more information on this please see organisations/guide-to-the-general-dataprotection-regulation-gdpr/



4. Privacy policy statements and registration forms.

The following statements will be displayed on the Johnny Foundation website. They will be used in conjunction with the consent forms and in line with the social media guidelines and the guidelines for taking photos and images (including videos).


DATA PRIVACY NOTICE for the Johnny Foundation

Your 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 likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

Who are we? The Data Controller (contact details below) decides how your personal data is processed and for what purposes.

How do we process your personal data? The Trustees of the Johnny Foundation complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We may communicate with you by email or SMS (text) but this will not be encrypted and therefore not a fully secure means of communication. Whilst we do our best to keep our systems and communications protected against viruses and other harmful effects, we cannot be responsible for all communications to be virus free.

We use your personal data for the following purposes: -

• To administer sponsorship records;
• To fundraise and promote the interests of the charity;
• To manage our volunteers;
• To maintain our own accounts and records (including the processing of gift aid applications); • To inform you of news, events, activities and services relating to the Johnny Foundation, and update sponsors on progress of the child(ren) they are sponsoring.

What is the legal basis for processing your personal data?

• Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and process your gift aid donations and keep you informed about diocesan events.

• Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;

•    Processing is carried out by a not-for-profit body

•    Sharing your personal data - Your personal data will be treated as strictly confidential. We will only share your data with third parties outside of the parish with your consent.


Your rights and your personal data

- Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -

• The right to request a copy of your personal data which the Johnny Foundation holds about you;

• The right to request that the Trustees of the Johnny Foundation corrects any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary for the Johnny Foundation to retain such data;

• The right to withdraw your consent to the processing at any time

• The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]

• The right to lodge a complaint with the Information Commissioners Office.

Further processing - If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Contact details:
Data controller: Katie Dawson