Privacy Policy for Trustees

What information do we hold about you and why?

Applying to become a Trustee

When you apply to become a Trustee, we will collect the following information about you:

Your full name and contact details – to manage the application process and contact you regarding your application
Your skills and experience – to consider your suitability as a Trustee
Confirmation that you are a fit and proper person – to meet the requirements of the Finance Act 2010, as set out in HMRC guidance
Information obtained through due diligence checks (including, but not limited to, details obtained from the bankruptcy register, director disqualification records and media reports) – to consider your suitability as a Trustee

Our legal grounds in relation to this processing is legitimate interests, in that we consider the processing to be necessary for considering your application and supporting you as a Trustee.

Supporting you as a Trustee

If you are successful in being appointed as a Trustee, we will also collect the following information about you:

Bank details – to pay expenses
Emergency contact details – to contact your next of kin in the event of an emergency
Equal opportunities data – to monitor and report on protected characteristics at the Trust
Identification data (including, but not limited to, DOB, place of birth and photographic ID) – to facilitate Trust governance checks in relation to anti money laundering and licence applications, if required by our trusted third parties (please see further information in the section below)

Our legal grounds in relation to this processing is legitimate interests, in that we consider the processing to be necessary for effectively supporting you as a Trustee, meeting our equalities monitoring obligations and facilitating essential Trust governance checks.

Who will have access to your data and who will we share it with?

As part of the election process, we will release your name and any statements provided in your application to our members.

Access to other personal data contained within your application or any relevant National Trust for Scotland forms completed by you (for example, volunteer forms) will be restricted to Trust employees and members of our governance structure on a need-to-know basis. Access will be provided for the purposes of considering your application and, if successful, for supporting you as a Trustee.

We will only share your information with third parties if it relates to supporting you as a Trustee or is necessary for auditing the governance practices of the Trust. We will share your information with the following third parties:

Our core systems provider – for the purposes of maintaining accurate Trustee records
Our merchant bank – for the purposes of facilitating Trust governance checks in line with the requirements of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Our fundraising partner – for the purposes of facilitating Trust governance checks in line with the requirements of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Local authorities in Scotland – for the purposes of facilitating Trust governance checks when applying for licences managed by local authorities

Where these third parties are acting as data controllers, they are required to handle your personal data in accordance with all applicable data protection laws. For further information about how they do this, please refer to their privacy policies.

Where the third parties are acting as data processors, processing personal data on behalf of the Trust, we have contracts in place with these third parties which require them to process your personal data on our instructions only. They will not process your personal data for any other purpose, and they will retain it securely.

In some cases, your data will be processed outside of the UK. Where this is the case, we will ensure that there are adequate safeguards in place (for example, the use of Standard Contractual Clauses) for the protection of your personal data.

How long will we keep your personal data?

Information held on your application form: 5 years from date of election if unsuccessful; permanent if successful
Information held on your Trustee file – permanent