Our Policies

Appeals policy for applicants requesting financial assistance

All requests from individuals for financial assistance are considered by the Support and Grants Committee, which meets three times a year. In between meetings, requests that are regarded as urgent are considered by the Chairman of the Support and Grants Committee. These decisions are later noted by the Support and Grants Committee and are recorded in the minutes.

Verification of needs and circumstances

Trustees recognise that it can be difficult to express needs and circumstances in an application form or letter. The Trust therefore aims that where appropriate and possible, every applicant in the UK receives a visit from one of our volunteer visitors to discuss needs and circumstances and to ensure that the Trust has a clear understanding of what these are. The Trust also aims that every UK beneficiary should have the opportunity to receive two contacts a year from a visitor.

While we aim to get the decision right first time, we also recognise that mistakes or misunderstandings might possibly occur from our interpretation of applicant’s circumstances. Therefore, in line with our policies on data protection and privacy, the Trust welcomes applicants to contact us to correct any details that we might have got wrong or are not up to date.

Time taken to assess a request for assistance

Trustees acknowledge that there will be an inevitable delay between the time an applicant may complete their application form and when a decision is made by the Support and Grants Committee and that the applicant’s circumstance might have deteriorated further. The Trust hopes that should this be the case, applicants will contact the Trust as soon as possible, so that the most appropriate decision can be made at the right time on the applicant’s current circumstances.

Process for appeal

The decision of the Support and Grants Committee and/or the Chairman of the Support and Grants Committee is final. However, noting potential mistakes, misunderstandings and time delays, the Trust will receive appeals from applicants or representatives acting on their behalf.

The Trust expects the applicant to contact the Trust where there are changed circumstances or where there is reasonable belief that a mistake or misunderstanding has occurred, with accompanying details to support the appeal.

For example this might be details of changed financial circumstances such as a reduction in the receipt of welfare benefits or an increase in expenditure not previously declared or known about. Where appropriate and possible, the Trust might arrange a visit, where the applicant could discuss their concerns and/or changed circumstances to assist with the appeal.

While we aim to respond to appeals as soon as possible and within 20 days, mindful of potential time delays, the appeal would be considered in the first instance by the Chairman of the Support and Grants Committee. While it is hoped that a decision could be swiftly made, depending on the circumstances of the appeal, the Chairman might determine that the decision is either outside his delegated authority and would need to be reviewed at the next meeting of the Supports and Grants Committee, or in urgent case additionally considered by the Deputy Chairman of the Support and Grants Committee or in serious cases by trustees. Additional liaison might also be needed with the visitor, to ensure that the right and appropriate decision is made.

How to make an appeal

Applicants can submit appeals to:

The Chartered Secretaries’ Charitable Trust,
Saffron House, 6-10 Kirby Street,
London,
EC1N 8TS

By telephone: 020 7612 7048 or 020 7612 7049 or by Email: CSCT@cgi.org.uk

Appeals can be submitted either by letter, email or conversation with the Trust administration or with a visitor.

In order to enable us to fully consider an appeal, applicants should provide as much detail as felt appropriate. If the appeal relates to a matter that occurred more than three months ago, it may be more difficult for the Trust to investigate fully.

The Chartered Secretaries’ Charitable Trust is by the side of Chartered Secretaries and their families through life’s challenges, by supporting them when in need and by promoting excellence in governance. The Trust:

• Serves The Chartered Governance Institute UK & Ireland members, graduates, students, employees and their families to relieve and help prevent financial difficulties,
• Facilitates research to increase good governance for the benefit of the public and
• Encourages the expertise of those in the field of governance with bursaries and prizes.

The Chartered Secretaries’ Charitable Trust endeavours to maintain the highest quality of support through our administration, services and visitors. If you are happy with our overall service or have any comments, please let us know and whether we may share these comments anonymously in our Annual report and publicity material.

We take every case seriously and we are committed to ensuring that all complaints are dealt with promptly, efficiently and deliver an outcome that is acceptable to all concerned.

Complaints and comments may come from any person who has (or has had) a relationship with The Chartered Secretaries’ Charitable Trust. This includes recipients of financial assistance and those who support the work of the Trust through making donations and/or volunteering. This document outlines the process for any complaints relating to services provided by the Trust.

Any appeals relating to a decision made about an application for support will be dealt with by the Support and Grants Committee and in line with our Appeals policy.

Any personal information provided to The Chartered Secretaries’ Charitable Trust as part of the complaints process, will be used in order to help us fully investigate and resolve the matter raised. All information will be held securely and in accordance with the General Data Protection Regulations 2018.

Personal information of an individual making a complaint will only be accessed by those who are investigating or resolving the matter and will not be used for any other purpose.

Your entitlement to receive support will not be affected by making a complaint.

How to make a complaint or comment

You can submit your complaint or comment to:

The Chartered Secretaries’ Charitable Trust,
Saffron House, 6-10 Kirby Street,
London, EC1N 8TS

By telephone: 020 7612 7048 or 020 7612 7049 or by Email: CSCT@cgi.org.uk Or, if you are a beneficiary, during a visit with your assigned visitor.

Complaints and comments can be submitted either by letter, email or conversation.

A definition of key terms is attached to this document. Your attention is also drawn to the Trust’s Privacy policy.

Data Protection Act 2018 and UK General Data Protection Regulation

The Data Protection Act 2018 (DPA) incorporating the UK General Data Protection Regulation is the current UK legislative regime that replaced the previous EU General Data Protection Regulations when the UK left the EU. The DPA places responsibilities on those who control and process personal data and gives rights to individuals (data subjects). The Information Commissioner’s Office (ICO) oversees compliance with the DPA.

The Chartered Secretaries’ Charitable Trust

The Chartered Secretaries’ Charitable Trust (‘the Trust’) is registered with the ICO as a data controller (registration number ZA050205). The Trustees have assessed the scale of our data processing and decided that the quantity of data being processed does not justify appointing a Data Protection Officer. Responsibility is delegated to the Charities Officer, who is responsible for reporting any data breaches to the ICO within 72 hours of our becoming aware of the breach and to the Charity Commission as a significant incident.

Personal data processed by the Trust

The Trust will always respect our data subject’s rights, which are stated in our Privacy policy. The Trust will only process personal data where it has a lawful base to do so, for example where we have obtained consent, where it is determined the Trust has a legitimate interest to carry out our charitable objectives, or where it is necessary to fulfil contractual obligations to provide services, products, or information. Where we rely on a legitimate interest, we will always ensure that it is done in a way that respects the rights of our data subjects.

The collection, processing and storage of personal information by the Trust are regularly reviewed to check that the personal data we hold is accurate, adequate, relevant, secure and limited to that which is necessary. Data protection and security controls are recorded in the Trust’s risk register, which is regularly reviewed. Training is provided for staff, trustees, Support and Grants Committee members and volunteers on data protection matters both on appointment and at least biannually thereafter.

The Trust informs individuals about the data we require from them, and sets out how it will be used in our Privacy policy statement. Additional information for applicants is attached to our Application for assistance form.

The information we receive from individuals will not be shared with any other organisation, unless express permission has been obtained, or the Trust is required to do so by law. For example, the Trust will share information with HMRC to claim Gift Aid on eligible donations, and it may seek permission from an individual to share their information with a trusted third party partner where it is identified they would benefit from receiving a bespoke service. If the Trust partners with a third party organisation, we will always review their data protection practices and ensure they have a published Privacy policy, entering into, where required, an Information Sharing Agreement.

The Trust obtains personal data from individuals who are seeking financial assistance, our volunteer visitors and supporters, trustees and Support and Grants Committee members and from third parties. The data is required to ensure that its charitable objectives are carried out effectively, fairly and in compliance with legislation.

Liaison with The Chartered Governance Institute UK & Ireland

In order to confirm applicants’ relationship to The Chartered Governance Institute UK & Ireland, the Trust has access to the Institute’s database of members’ records. This access also allows the Trust to record donations received from the Institute’s members and assists with the administration of Gift Aid claims and assists with the facilitation of the awards of bursaries and prizes to students. The Trust also seeks liaison with the Institute to confirm and make payment of the Institute’s membership subscriptions as appropriate and seeks liaison with the Institute to raise awareness of the opportunity of support available from the Trust. The Institute services the Trust’s administration, support and IT systems, and staff must also comply with the Institute’s own Data Protection Policy.

Beneficiaries

Information on applications made to the Trust is only accessible by the Trust and all personal data is held on a separate database to the Institute’s database of members’ records and on a separate password protected server. All details are kept confidential and are securely stored or used only to assist with the administration of the individuals request to the Trust and provision of any subsequent benefit. All applications considered by the Trust’s Support and Grants Committee are anonymised. Names and addressed are only available to the administration, and only disclosed where a visitor is appointed to support the individual. For example, each applicant is allocated a reference number.

The information held on applicants is updated annually, on the receipt of completed application forms and authorisation from the applicant. Where an individual has not received any services from the Trust for a period of six clear years, which supports the Trust in complying with accounting and audit requirements, the Trust will write to the individual and if no further services are required, or no response is received, the personal information held will be securely destroyed. Should former applicants exercise their right for erasure of all details either within this six-year period or at any time, the request will be considered and a response given. In the event that the Trust is unable to comply with the request at that time, the individual will be given a clear reason and provided with information on how they may escalate the matter with the Information Commissioner’s Office (ICO).

Visitors

All visitors are required to sign a non-disclosure agreement to confirm that they will maintain confidentiality in line with the Trust’s policies and will report to the Trust any breach or loss of personal data of beneficiaries within 24 hours of being aware of the breach or the loss.

Contributors

Paper and electronic records are also securely held on any individual who makes a donation to the Trust, with or without a supporting Gift Aid declaration. These details include full names and addresses, amounts of donations and when and how these donations have been paid. Copies of the Gift Aid declaration are scanned in an electronic format and records held only for the purpose of facilitating Gift Aid claims in accordance with HMRC requirements.

Recipients of Bursaries and Prizes

Paper and electronic records are securely held on recipients of bursaries and prize-winners. These details include full names, examination centres and the Institute’s membership numbers. These records are held only for the purpose of facilitating awards and to publicly record achievement in the Annual report, where permission to do so is granted by the individual. The Trust might contact recipients to obtain comment on the value of the bursary or prize, in order to monitor the impact of the award and would seek permission prior to using these comments for marketing and/or publicity purposes.

Trustees will continue to monitor this policy and ensure that appropriate operational procedures are in place to safeguard information held.

Definition of key terms:

Personal data: information about an individual, who they are, where they live, what they do etc. It’s any and all information that identifies the individual as a “data subject”. This may include names, addresses, photographs, customer reference numbers, health and financial information. In addition, there is a category of ‘special category personal data’ which includes genetic, biometric and medical data; racial and ethnic identity; religious and political beliefs; and sexual orientation.

Data controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data.

Data processor: a natural or legal person, public authority, agency or other body which is responsible for processing personal data on behalf of the controller.

Data processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject: the individual to whom the personal data belongs. This could be an applicant, beneficiary, donor, trustee, visitor, contractor, or any other individual whose personal data are held by us.

Consent: means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

The Chartered Secretaries’ Charitable Trust will consider requests for financial support from individuals who find themselves in need who:

• are or have been members on the register or registers of The Chartered Governance Institute UK & Ireland.
• or current or former affiliate members, graduates, students or employees of the Institute, who have maintained a minimum continued relationship with the Institute as described above, of a period as defined by current guidelines. Trustees are only empowered to utilise income and capital appreciation from 1 August 2013 to support these new classes. Should it prove necessary, priority will be given to:
• Graduates who have graduated within the last four years.
•  Affiliate members who have been affiliates for at least two years.
• tudents who have been students for a minimum of two years and a maximum of ten years, and who are or had been actively pursuing the Institute qualifying programme.
• Employees and former employees of the Institute in the UK, or their subsequent employer being a successor to the Institute in the UK arising as a result of any constitutional change, who were or had been continuously employed for at least four years and
• those who are dependants as determined by Trustees.

Grants to individuals are issued at the discretion of the Trustees and with due accordance to the constitution and to the Charities Act 2011. Grants are reviewed when circumstances determine and at least annually.

Trustees delegate the consideration of all applications for assistance to the Support and Grants Committee, which holds a minimum of three meetings a year. Between meetings, the Chairman of the Support and Grants Committee has the power in urgent cases to make grants to a maximum amount of £1,000 and interest free loans to a maximum amount of £5,000 in any one case, which are later noted by the committee. Where there is an emergency and the Chairman is unavailable, the Charities Officer seeks a decision from either of the Chairman of Trustees, the Deputy Chairman of the Support and Grants Committee and the Company Secretary, who have like power to make a decision.

In respect of the total level of grant aid, grants and loans will continue to be made up to the annual sums available as defined by the Trustees.

The Grant aid policy is reviewed every three years, or earlier at the discretion of the Chairman of Trustees and the Chairman of the Support and Grants Committee.

Download a printable version of the Grant aid policy for prizes

Education and Research grant aid policy

Our Education and Research grant aid policy outlines the eligibility criteria for grants to support the research and publication of results of such research, in the field of governance and business administration, or other activity, which in the opinion of the Trustees, will engage the public, and significantly progress and promote the practice of good governance and business administration.

Download a printable version of this policy

The Chartered Secretaries’ Charitable Trust (‘the Trust’) was incorporated on 9 July 2013. Registered charity no. 1152784. Company registration no. 8602517. The Trust:

• serves The Chartered Governance Institute UK & Ireland members, graduates, students, employees and their families to relieve and help prevent financial difficulties,
• facilitates research to increase good governance for the benefit of the public and
• encourages the expertise of those in the field of governance with bursaries and prizes.

This Privacy policy statement describes the ways in which the Trust use and disclose personal data. This includes information received from applicants for financial assistance, our volunteer visitors and supporters, our Trustees and Support and Grants Committee members and from third parties.

Personal data

Personal data includes any information that identifies you personally, such as your name, address, email address or telephone number. The Trust respects the privacy of your personal information and complies with General Data Protection Regulations and the Privacy and Electronic Communications Regulations. Our privacy notice that provides greater details for applicants for financial assistance, along with our Data protection policy is available on our website and on request.

How personal data is obtained

The Trust processes personal information supplied to us in writing, via email, via the telephone, in person or online. This may be combined with information obtained from CGIUKI, our volunteer visitors, other charitable organisations, suppliers of bespoke services, our bank and online donation platforms.

Purpose of using your data

The Trust processes personal information where you have given your consent, where there is a legitimate interest to do so to fulfil our charitable objectives or where it is necessary to comply with legal or contractual requirements. For example:

• Applicants to the Trust for financial assistance are requested to provide information on their relationship to CGIUKI along with financial details of their household and health conditions of themselves or any dependents (where relevant to the enquiry). This information helps to ensure your eligibility for support and to inform the Trust on any additional financial needs.

The Trust has a legitimate interest in retaining and using this personal data as appropriate, to ensure that assistance is only provided to those who have a relationship to CGIUKI and that they have a genuine financial hardship.

The Trust undertakes identity checks on all volunteer visitors and requires the successful completion of a Disclosure and Barring Service check prior to their commencement of visits to beneficiaries. For Trustee appointments, individuals are subject to additional checks with the Charity Commission, Companies House and the Individual Insolvency Register to ensure they are willing and eligible to take up the role.

For those individuals who kindly donate to our charity and are in a position to Gift Aid their donations we require them to provide their address, sign a Gift Aid declaration, the information on which will be shared with HMRC, and, if appropriate, provide their bank details to enable direct debit transactions to be set up.

Disclosure of information

All data is treated as strictly confidential, is only used for the purposes it was originally collected for and is only disclosed to those parties who have a need to access it to fulfil the charitable objectives or where required to do so by law. Where the Trust relies on the individual’s consent prior to sharing with the third party this consent can be withdrawn at any time.

• The Trust needs to disclose data to CGIUKI.

While the Trust controls the purposes, policies and processes of the data it obtains, records, uses and stores, the employees responsible for the day to day administration are employed by CGIUKI. CGIUKI also provide appropriate support through for example, their examinations, finance, IT and membership departments. CGIUKI is not permitted to use this information for any other purpose than to perform the processing service as instructed by the Trust.

• The Trust may disclose data to other third parties who provide services on behalf of the Trust.

The Trust may offer a beneficiary a bespoke service, for example an emergency alarm system to frail beneficiaries so that they can reach for assistance in case of a fall. In these circumstances, information will be shared on a need to know basis in order to fulfil the bespoke service.

How long information is held

The Trust will securely maintain records in line with our Data protection policy. As a general rule, data is held for a maximum of six years following the cessation of the Trust’s relationship with the individual. After this time, all paper and electronically held records are securely destroyed. Please see our full Data protection policy for details.

Storage and security of personal data

To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, the Trust has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information collected and processed on behalf of the Trust.

Your rights

You have the right to be informed about the processing of your personal data, request access to the information held about you, request rectification of any information that is inaccurate, request deletion of information or restrict processing at any point. You also have the right to move, copy or transfer your personal data, object to the processing and rights in relation to automated decision making including profiling. To find out more, refer to the Information Commissioner’s Office (ICO) website: https://ico.org.uk

If you have any questions regarding this statement or concerns, wish to exercise your rights, or have any concerns on the accuracy and use of your data, please contact the Charities Officer, (CSCT@cgi.org.uk), telephone: 020 7612 7049 who is responsible for the day-to-day administration of the Trust and for reporting any data breaches in respect of the Trust to the ICO and any serious incidents to the Charity Commission.

Duty of care

Trustees’ view is that their duty of care extends to all those individuals that interact with the objects and activities of the Trust. These include trustees, committee members, beneficiaries, volunteer visitors and donors. Procedures are in place to safeguard protection and are as follows:

Checks on individuals

While the Trust does not provide a regulated ongoing activity to its beneficiaries, all trustees, committee members and volunteer visitors are required to undertake a Disclosure and Barring Service check, regardless of whether they have any direct contact with beneficiaries. Until the Trust is satisfied of the outcome of the disclosure, the volunteer makes no visits and the potential trustee or committee member is not formally appointed. For Trustee appointments, individuals are subject to additional checks with the Charity Commission, Companies House and the Individual Insolvency Register to ensure they are willing and eligible to take up the role.

Volunteers visit beneficiaries to verify their circumstances and ensure that their needs could be appropriately expressed to the Trust. Trustees also recognise that needs cannot always be adequately expressed in an application form, letter or telephone conversation. In regard to our duty of care, face to face contact with the beneficiary can result in a specific need being identified, for example decorating or help with clothing, which the beneficiary had not thought to mention and ask for assistance.

Protection of sensitive information

The Trust holds sensitive information on beneficiaries, including health and financial details. The protection of this sensitive information is detailed in the Trust’s data protection and privacy policies.

Training

Safeguarding training is provided to volunteers on appointment and refreshed at least biennially or more frequently if there are significant changes in legislation, policy or process which warrant bringing this forward. The training includes both knowledge based and soft skills training to assist with visits. For example, in order to increase sensitivity and an understanding of beneficiaries’ individual circumstances, this includes training in respect of bereavement and mental health awareness. Visitors are also required to undertake data protection training.

Safety of individuals

When a visitor calls on a beneficiary for the first time, the beneficiary is advised by telephone and by letter how the visitor will arrange the meeting and how they will verify their identity. Beneficiaries are also advised that a family member or close friend can join them. Should the Trust or the visitor consider an element of risk in visiting the beneficiary in his or her own home, the visitor is advised to arrange the meeting in a public place, or to be accompanied when they visit. Visitors can also refuse to make a visit if they feel it is unsafe to do so. The Trust holds insurance in respect of potential accidents to visitors during the course of a visit.

Visitors are required to alert the Trust administration of any issues or difficulties they encounter as part of a visit along with any concerns about the beneficiaries they are visiting. For example, visitors have, in the past, reported broken essential white goods, which were then replaced or, have suggested the provision of an emergency alarm for an older or less agile beneficiary. In the event the visitor is concerned for the beneficiary’s wellbeing or safety, the visitor should contact Trust administration as soon as possible after the visit and follow the guidance laid out in the section below entitled “Raising and Reporting any Safeguarding Concerns”.

Should the visit cause any apparent distress to the beneficiary or to the visitor, the visitor is encouraged to politely remove themselves from the situation and contact the Trust administration immediately.

Donors

The Chartered Secretaries’ Charitable Trust is registered with the Fundraising Regulator and compliance with the Fundraising Code is acknowledged.

In particular, the Trust complies with Section 1.3 of the Code of Fundraising Practice ensuring all reasonable steps are taken to treat a donor fairly so they can make an informed decision about any donation. The Trust does not take donations from individuals if they know, or have good reason to believe, that a person lacks capacity to make a decision to donate, or is in vulnerable circumstances which mean they may not be able to make an informed decision. If a donor makes a donation while they do not have the capacity to make an informed decision, the Trust will return the money to them.

Raising and reporting any safeguarding concerns

Where there are concerns for the safety and/or wellbeing of beneficiaries following a visit, the visitor should make notes at the time, recording the date, time, raise the concern with the Trust administration as soon as possible after the event. The Trust administration will consider whether there is any immediate risk of harm and take appropriate action, referring to other agencies as appropriate.

Trustees have considered how to respond to appeals, complaints and serious incidents. All appeals and complaints received would be resolved in line with the appeals, complaints and comments policies and procedures. Any serious incidents would be dealt with in line with our serious incidents procedure.

Trustees will continue to monitor this policy and ensure that risks are identified in our risk register with appropriate controls in place to safeguard individuals who interact with the objects and activities of the Trust.

Statement of Investment Policy

Our Statement of Investment Policy outlines the Trust’s approach and objectives for investments in the Benevolence, Education and Research and Prize funds.

Download a printable version of this policy