Privacy policy

Your privacy is important to the Winston Churchill Memorial Trust (“WCMT”, “we” or “us”). We are committed to safeguarding and respecting your privacy; this privacy statement sets out how we will treat your personal information. We aim to be clear on the circumstances in which we will collect your data and what we will do with it. 

Your personal data is protected by the General Data Protection Regulation (GDPR), and the Privacy and Electronic Communications (EC Directive) (Amendment) 2011.

We will review and update this privacy statement as required, and we will post changes on this page, so you are always aware of how WCMT is using your personal information. Please check this page periodically to ensure that you are happy with any changes.

We hope that this policy statement will answer the questions that you may have about how we manage and protect your details, but if you have any questions which are not answered by this statement, please contact us.

  1. What personal information does WCMT collect?
  2. How does WCMT use your information?
  3. What is the legal basis for WCMT processing personal data?
  4. How long will WCMT keep your information?
  5. Communications
  6. With whom does WCMT share personal information?
  7. Your rights
  8. Personal data security
  9. Cross-border data transfers
  10. Other websites
  11. Contact us

1. What personal information does WCMT collect?

WCMT collects, stores and uses the following types of personal information when it is made available to us in the course of our communications with you:

  • your name;
  • your contact details (including postal address, telephone number, e-mail address and/or social media identity);
  • your date of birth;
  • your gender;
  • financial information such as your bank details where you provide these to make a payment or to receive a Fellowship grant from us;
  • if you apply for a Churchill Fellowship, information necessary to process your application, such as your qualifications, employment history, nationality and age;
  • if you apply for a job or volunteering role, information necessary to process the application, such as your qualifications, skills, experience, employment history, current level of remuneration and entitlement to work in the UK;
  • information about WCMT events that you have attended;
  • information as to whether you are a taxpayer to enable us to claim Gift Aid;
  • where you have left us a legacy, any information regarding next of kin with which you may have provided us to administer this;
  • ethnicity, disability, faith, sexual orientation, gender and gender identity information for monitoring purposes;
  • information about your activities on our website and about the device you use to access it (which may include your IP address, geographical location, browser type and version, referral source, entry page, exit page, length of visit, number of page views, route taken through this website, and similar information) in anonymised form; and
  • any other information that you choose to send to us.

Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this type of sensitive data would be information about health, racial or ethnic origin, religious beliefs or sexual orientation. We only collect this type of information to the extent that there is a clear reason for us to do so, for example where we ask for information for the purpose of providing appropriate services or support. You are under no obligation to provide information for equal opportunities monitoring purposes.

2. How does WCMT use your information?

Personal information submitted to us via this website or directly via email or post will be used for the purposes specified in this privacy statement.

We will use your personal information to:

  • enable your use of the services available on the website;
  • improve your browsing experience;
  • respond to your enquiries and requests;
  • process Fellowship applications and send you email notifications and letters related to a grant application; 
  • administer and monitor Fellowship grants, including make payments for grants and expenses;
  • provide you with information about our activities or about events you sign up to attend;
  • provide you with information about specific areas of interest that you sign up to receive;
  • communicate with you, including manage your membership of WCMT’s Regional Associations and topic-based networks, should you join any of these;
  • alert you when Fellowship applications open, if you register your interest;
  • process the purchase of memorabilia or other sales items;
  • process your donation including processing Gift Aid;
  • fundraise;
  • further our charitable objectives;
  • generate reports on our work, services and events;
  • conduct due diligence;
  • monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
  • process your application for a job or volunteering role;
  • audit and administer our accounts;
  • meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies; and
  • deal with enquiries and complaints made by or about the use of your data.

3. What is the legal basis for WCMT processing personal data?

Personal information is processed according to Article 6 of the General Data Protection Regulation for the following reasons:

  • as necessary for the performance of tasks carried out in the public interest, in this case the disbursement of funds to the individuals who are awarded a Churchill Fellowship or participate in the selection process;
  • as necessary in the pursuit of the legitimate interests of the charity, in this case, to acquire the information necessary to process grant applications, sharing Fellows’ findings and recruiting applicants, staff and volunteers;
  • for compliance with legal obligations, in this case to provide full and accurate information to the Charity Commission;
  • where necessary we ask you for specific consent to use your information in a certain way, and you agree to this (for example when we send you updates about our activities or events via e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.

4. How long will WCMT keep your information?

  • Register for communications about our activities 

If you sign up to receive communications about our activities you will be able to change your preferences or unsubscribe at any point.

  • Registering for alerts 

If you sign up to receive alerts when applications open, your details will be deleted once applications close, unless you apply for a Fellowship. At that point we will ask whether you would like to continue receiving information from us. 

  • Fellowship applications

WCMT reserves the right to hold data related to grant applications for archive purposes and in order to facilitate a high standard of due diligence which will enable the charity to continue to fulfil its charitable objects. 

    1. In the case of unsuccessful applications all personal data will be removed at the end of that annual grant cycle, with the exception of email addresses which allow us to monitor repeat applications.
    2. In the case of successful applicants, personal details pertaining to travel, such as scanned copies of passports and details of next of kin, are deleted following the completion of travel.
    3. Equality and Diversity Data is anonymised and deleted from our database following the award of Fellowships. WCMT retains the anonymised data for monitoring and evaluation purposes. In the case of successful applicants, exceptions are made for disabilities that relate to access requirements as it helps us plan events, and for ethnicity as it helps us match press opportunities. Feedback for unsuccessful applicants who were invited to interview will be provided up to March of the same year.
  • Regional Associations and topic-based networks

We will keep your data as part of any Regional Associations or topic-based networks you may join until you advise us that you would like to be removed from the group.

  • Partners

We will only share your contact details with our partners with your consent.

  • Surveys

As part of our commitment to supporting Fellows before, during and after travel we collect data from Fellows through surveys. Fellows are sent surveys via email on their return from travel, and then at various intervals through the years. Their purpose is to provide us with indicators and case studies of performance or impact.

The data collected by the surveys will be held on our CRM database, currently Salesforce, and will be attributable to the Fellow in question. However, for the purposes of analysis and reporting, information disclosed will be pooled and reported on collectively, rather than individually.

When WCMT does wish to highlight the particular achievements of a Fellow, the Fellow in question will be consulted on such use of their data and their express consent sought before any data is published. Due to the nature of impact assessment and the requirement to consider year on year comparisons, all data collected will be kept indefinitely. We acknowledge that some of the information disclosed in the surveys will be of a confidential nature, therefore the data will not be shared or used for marketing or fundraising activities without your consent. We may use the data as part of our work in building partnerships. However, the previously stated policy on pooling data for collective reporting and seeking express consent for individual mentions will be fully abided by.

  • Recruitment

If your application for employment is unsuccessful, the organisation will hold your data on file for a month.  If you withdraw your consent your data will be deleted or destroyed. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. 

5. Communications

In addition to the above, some information about Fellows may be used for external communications or marketing purposes, but only with express permission from the individual concerned. Communications preferences will be requested on award of a Fellowship and these permissions recorded on our database in relation to the individual.

Members of the public who sign up to receive information from us will be covered by the provisions of this policy.

6. With whom does WCMT share personal information?

We may disclose information about you to any of our employees, Trustees, officers, Advisory Council Members and panellists is as reasonably necessary for the purposes as set out in this privacy statement. All roles mentioned above receive training in matters relating to Data Protection and confidentiality and are required to sign up to WCMT’s Privacy Policy.

We will never sell or rent your information to third parties for marketing purposes. However, we may disclose your information to third parties in connection with the other legitimate purposes as set out in this policy; however, the third parties concerned would be bound by a confidentiality agreement which would prevent them from using this information for any other purpose. These third parties may include:

  • funding partners, suppliers and sub-contractors (including FormAssembly, an online form provider; Mobilize, an online network/community management provider; and Mailchimp, an email marketing platform) who may process information on our behalf;
  • if you are a legacy giver, we may share information with co-beneficiaries;
  • analytics and search engine providers;
  • IT service and website support providers.

In addition, we may disclose your personal information:

  1. to the extent that we are required to do so by law;
  2. in connection with any legal proceedings or prospective legal proceedings;
  3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
  4. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as expressly provided in this privacy statement, we will not provide your information to third parties.

 

7. Your rights 

You have the right to be informed, which is the purpose of this Privacy Policy.

The accuracy of your individual identifying information is important to WCMT. You have the right to have inaccurate or incomplete information we hold about you corrected – at most within one month. If you change your email address, or if any of the other information we hold is inaccurate or out of date, please get in touch with the details.

You have a right to request access to the personal data that we hold about you and also the right to request a copy of the information we hold about you. We will provide you with this unless legal exceptions apply. Provision of such information will be subject to the supply of appropriate evidence of your identity. We aim to issue an initial response to all enquiries within five working days and will offer a full response to all information access requests within thirty working days of receipt. There is no fee for this unless you make repeated requests of the same data. If you want to access your information, please send a description of the information you want electronically or via post to our registered address: Winston Churchill Memorial Trust, 29 Great Smith Street (South Door), London, SW1P 3BL.

You also have the right to restrict or stop the processing of your personal information if you contest its accuracy or object to its processing for example if some information we hold on you isn’t right; we’re not lawfully allowed to use it; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so. In such cases processing will be restricted until the matter is resolved and we will inform you of that resolution.

You have a right to obtain your personal information from us without hindering the usability of the data and you may ask us to provide it to you or another service provider in a machine-readable format. This right applies when we process your data with consent, pursuant to a contract and the processing is being done by automated means.

If WCMT relies on consent as the legal basis for processing your personal data (as set out in ‘What personal information does WCMT collect?’) you may withdraw your consent to that processing. However, we often rely on different legal bases for different aspects of processing, and this means that we may not be able to act on your request if we have a compelling legal reason not to. If we are processing your personal information for direct marketing purposes, and you wish to object, we will stop processing your information for these purposes as soon as reasonably possible.

If you want to exercise any of the above rights, please contact us.

Please note that exceptions apply to a number of these rights; not all rights will be applicable in all circumstances. For more details please consult the guidance published by the Information Commissioner’s Office (ICO).

8. Personal data security

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal data you provide on our secure cloud-based services including Salesforce, Office 365 and an additional encrypted back up on a hard drive. This information is protected using both password management tools and data encryption. We also use FormAssembly (a service mark of Veer West LLC) and Mobilize (run on Intercom), which host data outside the UK and comply with the EU-U.S. Privacy Shield Framework.

9. Cross-border data transfers 

Information that WCMT collects may be stored and processed in and transferred between any of the countries in the EU in accordance with this privacy statement. In addition, personal information that you submit for publication on the website, or that you publish on your profile page, will be published on the internet and may be available around the world.

10. Other websites

The website contains links to other websites that are not under the control of and are not maintained by WCMT. We are not responsible for the content or reliability of the linked websites. WCMT provides these links for your convenience only but does not endorse the material on these sites.

11. Contact us

We are registered with the Information Commissioners Office as a Data Controller under number Z582025X. If you have any questions about this privacy statement or our treatment of your personal information, please contact us electronically or write to us by post to Winston Churchill Memorial Trust, 29 Great Smith Street, (South Door), London SW1P 3BL.

If you have concerns about how we use your personal information, we would like to hear from you so we can address your concerns. WCMT is committed to treating complaints seriously, sensitively, and with discretion and understanding.

We aim to issue an initial response within five working days. If we need to investigate further, we will let you know we have received your complaint and how long it will take to resolve. However, if you are still unhappy you have the right to lodge a complaint about any use of your information with the Information Commissioners Office (ICO), the UK data protection regulator.