Approved by Board of Trustees of OPAL Trust UK – June 2020
Policy Review date by Board of Trustees – June 2023
At OPAL Trust we are deeply grateful for the prayers, gifts and time received from all
our supporters. We could not do our work without your vital help.
OPAL Trust values everyone who engages with us by whatever means, and we are
committed to protecting your privacy and respecting your personal information. While
we cannot guarantee that loss, misuse or alteration of data will not occur while it is
under our control, we will do all we can to protect your privacy and to make sure the
personal data you provide us is kept safe and only used for purposes you have
agreed to and in ways we believe you would reasonably expect. We aim to be clear
about how we collect your details, how we use and store information and what it
feedback about any of our activities and policies, just email us at email@example.com
We aim to communicate with you respectfully and efficiently, and to give you clear
choices as to what information you supply to us. We want to share news of our work
with you by the means you have chosen as the most convenient to you – email,
SMS, phone, post. If you no longer wish to receive information from us, please
contact us on firstname.lastname@example.org
Your continued use of the OPAL Trust website means you are happy for us to use
your personal information as described in this notice.
How we collect information
When you give it directly to us
We collect some personal information each time you contact us. For example, when
you make a donation, ask to receive materials or information about our work, engage
with OPAL Trust through social media channels, sign up for an event, or order
resources or services from us.
From website interaction with us
Non-personal data such as IP addresses, details of pages visited and files
downloaded is collected when you visit the website. Website usage information
Indirectly from third parties
Your information may be shared with us by 3rd parties such as Stewardship, CAF or
through bank payment details, when you give a gift to us. These organisations will
only do so with your consent if you have indicated you wish to support OPAL
Where you give your permission to other organisations
The information we get from other organisations may depend on your privacy
settings or the permissions you give them, so you should check these regularly. We
may collect information that you make publicly available on, for example, Twitter,
Facebook, Whatsapp, LinkedIn or similar organisations. Please check their privacy
policy to find out more information on how they will process your data.
Other publicly available data
We may collect information from Companies House, the Charity Commission, grant
making trusts and information published in articles, newspapers or blogs.
What sorts of personal information we might collect from you
If you are a supporter of our work and make a donation, sign up to receive news of
our work, volunteer, attend an event, or order something from us, we will may collect
details such as:
• Your name
• Your contact details, including postal address, email address, telephone
numbers and information about your preferences as to how you wish us to
contact you in the future. These help us if there is a problem with an order.
• Your bank account details if you make a regular donation by direct debit or
• Debit or credit card details used to make a donation or order resources – this
could be online, over the phone or by mail. Information given will be
processed securely and in accordance with the Payment Industry Standards.
Your details are only used to complete the transaction you requested, and we
do not store your debit or credit card details. If you have provided them
physically, they will be destroyed once your donation or payment has
• Your Gift Aid status and any information relevant to that
• Your position within an organisation or charity (if relevant)
• Other personal information you share with us, such as about your family,
denomination, home church, and any health issue you may have told us about
to help us communicate with you in the most helpful way (e.g. large print)
• Our website and services are targeted at persons over the age of 18. If we
have a reason to believe that we hold personal data of a person under that
age in our databases, we will delete that personal data
Like most websites, we use ‘cookies’ to help us make our site, and the way you
use it, better. A cookie is a text file that is sent from our website as soon as you
visit the 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
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.
OPAL Trust may store information about you and your activities in cookies. If you
want to delete cookies stored on your computer, please use the instructions from
your file management software to locate the file or directory where the cookies
are stored. If cookies are being collected, you will be informed about this when
you visit the website, and you will be given the option to accept or decline.
Most browsers allow you to turn off the cookie function. To do this you can look
at the Help function on your browser.
How do we use the information we collect?
The information we gather helps us send you what you want when you want it, to
fulfil orders for resources, and send you updates and information about our work.
Having accurate information helps us steward our resources so that the maximum
amount goes to supporting the core mission of OPAL Trust.
Processing of requests / donations / calls to action
• We may use the personal data we collect to:
• Keep you up to date on news and stories about our mission and work
• Request support, such as prayer
• Administer donations you give us, or to support your giving to us, including
• Provide information packs, for example, events leaflets or magazines you
• Provide a personalised service, such as customised website content or
• Ensure we know how you prefer to be contacted
• Keep records of your relationship with us, for example, donations you have
made, questions you have asked, or comments or complaints you have made
• Understand how we can improve your experience as a supporter based on
your interest and interaction with us
• Understand how we can improve our services, resources, and the information
we send out
• Contact you in your capacity as a representative of an organisation such as a
church, business, or charity
• Ensure potentially vulnerable people are treated appropriately
• If you make a gift to our work, we will contact you to thank you and discuss
ways in which we can give you further information about our work. This would
include having a discussion with you about the methods of contact most
suitable for you
We do not sell or share personal details to third parties for the purposes of
Basis of processing your data
Supporters joining us on or after 1st January 2018
From 1st January 2018, we will process any new supporters’ data based on the
consent you have given us. 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.
Supporters who joined us prior to 1st January 2018
If you were an existing supporter as of 1st January 2018, we will use your support for
us over the previous three-year period as a legitimate interest reason to continue to
send you the communications you receive from us. This includes if you have made a
donation or updated us with new information to help us send you the right
communications for your needs. If you have previously asked us not to contact you,
we will continue to respect your wishes. 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 below.
Contacting the right supporters at the right time: When you make a donation, a
series of donations, express an interest in our work, or indicate that you may wish to
give to our work, we will rely on our legitimate interest in order to collect additional
information as noted above in ‘Processing of requests / donations / calls to
action’. This helps us to identify those supporters who would benefit from an initial
discussion with us to ensure we use our supporters’ money in the most effective
Legitimate interest for potential supporters
We may rely on legitimate interest to contact you or hold information about you:
• If you publicly share information about your interests and concerns that
overlap with an area of activity of OPAL Trust’s work
• If as a result of publicly available information you are identified as someone
who may have an interest in our work
Any information gathered would be used to help to plan an appropriate approach,
such as a meeting or invitation to an event where we could share information about
OPAL Trust and explore your interest and opportunities for support.
Applying for a job or volunteering with us
• Where you provide personal data and sensitive personal data when applying
for a job or a voluntary position 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, apply online for jobs and to subscribe for alerts
about job types of interest to you
• 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
How and where we store your information
The security of your information is very important to us. We will ensure that there are
appropriate controls are in place 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.
Your information may occasionally be passed to service providers who perform
functions on our behalf, such as sending postal mail, emails, or analysing data.
These companies may only use your information to perform these functions and may
not use it for any other purposes. When we do so, we carry out checks on these
companies, put in place contracts to make sure our expectations and requirements
are clear as to how they manage the personal data that have been collected or to
which they have access, and carry out periodic reviews. They are required to destroy
this information once the function for which it has been transferred has been carried
Credit / debit card security
If you use your debit or credit card to donate to us, or make a payment for goods,
whether over the phone or by mail, we will process your information securely in
accordance with the Payment Card Industry Data Standard.
We do not store your debit or credit card details once your transaction has
completed. All card details are securely destroyed once your donation or payment
We hold bank account details for the purpose of collecting direct debits in
accordance with direct debit mandate rules.
However, despite all the security and protection we put in place, the internet and
postal delivery services cannot be guaranteed to be 100% secure, and you submit
data at your own risk.
Where we store your personal information
Because of the nature of servers and cloud-based storage systems used to store
and to process data, some data may be processed outside of the European
Economic Area (EEA). Although these systems may be in locations that are not
subject to the same data protection laws as in the UK, we will take all reasonable
steps to ensure they provide an adequate level of protection in accordance with UK
data protection law. We take all reasonable steps to ensure that your data is stored
and processed securely in accordance with this policy. By submitting your personal
data you agree to this potential transfer, storing and processing of your information
at a location outside the EEA.
When we share your information
We will only ever share your data in other circumstances if we have your explicit,
informed and unambiguous consent.
In line with our beliefs, we do not share or swap your information with any other
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
Our service providers and third parties
Occasionally we may employ agents to carry out tasks on our behalf, such as
processing donations. These agents are bound by contract to protect your data and
we remain responsible for their actions.
We may provide third parties with general information about users of our site, but this
information is both aggregate and anonymous. However, we may use IP address
information to identify a user if we feel that there are or may be safety and/or security
issues or to comply with legal requirements.
We will keep your personal information only for as long as we consider it necessary
to carry out each activity. We take account of legal obligations, and accounting and
tax considerations, as well as considering what would be reasonable for the charity’s
monitoring of income.
We will keep a record of any personal donations you have made for at least seven
Legacy gifts are an important part of the funding for our work. We may keep data
provided by you or your solicitor indefinitely in order to carry out the administration of
legacies and to communicate with the families of those leaving us legacies.
If you ask us to cease communications with you, we will keep a record of your
contact details and appropriate information to enable us to comply with your request.
If you have any questions about our data retention, please contact us in writing at:
2B Green Street
Contents of Emails
Email messages and any associated files are intended solely for the use of the
individual or entity to whom they are addressed and contain the views of the author.
If you have received an email from OPAL Trust in error, please reply immediately
and delete it from your computer. Because email moves through different servers on
the internet, and different server administrators may be able to read what you send,
we cannot ensure or guarantee that loss, misuse or alteration of data will not occur
as data is being transferred, Email was not built for the transmission of confidential
information, and therefore is not secure. OPAL Trust is therefore not bound by
anything stated in an email purporting to be from OPAL Trust, and shall not be liable
for any losses as a result of virus transmission, although safeguards are in place to
protect against this. Emails and email addresses may be susceptible to alteration.
You should not assume that the contents originated from OPAL Trust, or that they
have been accurately reproduced from their original form. OPAL Trust accepts no
responsibility for information, errors or omissions in an email message, nor for its use
or misuse, nor for any act committed or omitted in connection with it. If you are
suspicious about any email or other message claiming to be from OPAL Trust please
contact the sender by another means to verify its contents.
Your choices and telling us when things change
You can change your preferences on what you receive from us, including marketing
and fundraising materials, or how we contact you, by mail, phone or email, at any
You can do so by:
Emailing us at: email@example.com
Write to us at:
2B Green Street
DARVEL, East Ayrshire
Keeping your information up to date
We do appreciate it if you keep your details up to date. You can do so in the same
way as updating your preferences.
We may use publicly available sources such as Post Office address search,
postcode lists to keep our records up to date and accurate.
We will not use these sources to create data that you have chosen not to provide, for
example, if you have left a telephone number blank. We will normally only update
your contact details (email address, postal address, telephone number) when you tell
us they have changed. We would really appreciate it if you let us know of changes
to any of these details, because this gives us consent to use the updated information
and continue to communicate with you.
We will take appropriate measures to ensure that information is only kept for as long
as necessary, and only for the purpose for which it was given. We will also only use
it when regulations permit us to do so.
Telling us to stop processing your data
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 writing to us at:
Write to us at:
2B Green Street
Or emailing us at: firstname.lastname@example.org
Access to your information – Your rights under DPA 1998 and GDPR
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your
Your right to rectification – You have the right to ask us to rectify personal
information you think is inaccurate. You also have the right to ask us to
complete information you think is incomplete
Your right to erasure – You have the right to ask us to erase your personal
information in certain circumstances
Your right to restriction of processing – You have the right to ask us to
restrict the processing of your personal information in certain circumstances
Your right to object to processing – You have the right to object to the
processing of your personal information in certain circumstances
Your right to data portability – You have the right to ask that we transfer the
personal information you gave us to another organisation, or to you, in certain
You are not required to pay any charge for exercising your rights. If you make a
request, we have one month to respond to you.
If you want to access your information please send a description of the information
you want to see, and proof of your identity, to Opal Trust at the postal address given
above. These requests are not accepted by email, so we can ensure that we only
provide personal information to the right person. We will respond within one month of
receiving your letter. If there are any discrepancies in the details we provide, please
let us know and we will correct them.
For more information about your rights under the General Data Protection Regulation
you can visit the website of the Information Commissioner’s Office http://www.ico.org.uk
Changes to this OPAL Trust Policy
This policy was last updated 19th June 2020. 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 the OPAL Trust website, in our newsletters, or by contacting you directly.
By continuing to use our website you will be deemed to have accepted these
please do not hesitate to contact us at: email@example.com