Woodley Pilot Light Trust Privacy Policy



The objectives of this Privacy Policy are:

  • To coordinate the information security and data handling procedures in force at the Charity to protect clients, volunteers and trustees
  • To promote confidence in the Charity’s information security and data handling procedures
  • To provide assurances for third parties dealing with the Charity
  • To comply with data protection legislation
  • To provide a benchmark for trustees and volunteers on information security, confidentiality and data protection issues.




The Trustees have overall responsibility for ensuring that the organisation complies with its legal obligations.


Managing Data Protection

We will ensure that our details are registered with the Information Commissioner.

Purpose of data held by Woodley Pilot Light Trust:

Data may be held by us for the following purposes:

  1. Volunteer Administration
  2. Donations
  3. Realising the Objectives of the Charity: to provide services to our clients
  4. Accounts & Records

Data Protection Principles

  1. Fairly and lawfully processed personal data


We require all clients to give their explicit consent to process their personal data.


Counselling: On initial contact, we will verbally require the clients’ permission to hold their contact details and basic ‘assessment’ information in order to contact them and assign them to a counsellor.   Before commencing counselling, clients will be required to read and sign a Counselling Agreement giving their explicit consent to process their personal data.  This consent will be kept on file by the counsellor.


Foodbank: Initial contact with clients may occur in 2 ways and information processing will then operate accordingly.  In the event of a client making direct contact with our staff (employees and volunteers included) they will be required to read and sign the Food Bank agreement giving their consent to us holding their information.  This information will be held for 3 months in signed format and then transferred to secure computer database accessible only by the coordinator.  In the event of a referral being presented by another agency, we will be presented with data without having a signed consent form.  This data will be held on the secure database only.


  1. Processed for limited purpose

We will not use data for a purpose other than those agreed by data subjects in the relevant agreement. We will not share personal data outside Woodley Pilot Light Trust, except under the following circumstances:

  • Receipt of a request from volunteer/client or their representative, and where the release of the notes is not judged by Woodley Pilot Light Trust as likely to cause the subject significant harm or harm to another person
  • Where there is a specific legal requirement for Woodley Pilot Light Trust to do so
  • Where there is an ethical duty for Woodley Pilot Light Trust to do, for example to avoid serious harm to the client, volunteer or another person, including the safeguarding of children or vulnerable adults.


  1. Adequate, relevant and not excessive

The Charity will monitor the data held for our purposes, ensuring we hold neither too much nor too little data in respect of the individuals about whom the data are held. If data given or obtained are excessive for such purpose, they will be immediately deleted or destroyed.

  1. Accurate and up-to-date

Individuals should notify us of any changes, to enable personnel records to be updated accordingly. It is the responsibility of the Woodley Pilot Light Trust to act upon notification of changes to data, amending them where relevant. All amendments will be made immediately and data no longer required will be deleted or destroyed.


  1. Not kept longer than necessary

We discourage the retention of data for longer than it is required. All personal data will be deleted or destroyed by us:

(In the case of a counselling relationship): three years after the cessation of the counselling relationship;

(In the case of a food parcel recipient): three years after the last food parcel was delivered;

(in the case of a volunteer): three years after cessation of volunteering for the charity;

(in the case of gift-aided donations): 6 years after the donation was made

except where there is a mutually agreed decision to retain it for longer or where Woodley Pilot Light Trust believe that it is in their best professional interests to do so.  After this period, the information will be deleted and/or destroyed.


  1. Processed in accordance with the individual’s rights

All individuals that the Charity hold data on have the right to:

  • Be informed upon their request of all the information held about them within 40 days.
  • Prevent the processing of their data for the purpose of direct marketing.
  • The removal and correction of any inaccurate data about them.
  • Be informed within three working days if Woodley Pilot Light Trust become aware of a situation where their personal information may have accidentally or maliciously been obtained by a third party.
  • Make a complaint to the Information Commissioner’s Office if they are unhappy with the Charity’s handling of their information.


  1. Secure
    Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of data.



Promotion of the policy


This policy will be communicated to clients as appropriate. They will be required to give their consent by signing an agreement which will be kept on file.

The policy will be made available within the Charity as part of the induction process to all new volunteers and board trustees.

The policy will be promoted to all current volunteers and trustees by requiring acknowledgement and acceptance of its aims and objectives in writing.

All trustees and volunteers should be required to read, understand and accept any policies and procedures that relate to the personal data they may handle in the course of their work.


Date of issue: 20 May 2018