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.
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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.
Governance and Accountability: The Charities Officer is responsible for the day-to-day management of complaints, including maintaining the complaints register and coordinating investigations. Oversight of complaints handling and themes arising is provided by the Board of Trustees, who receive regular reports on complaint volumes, themes and learning. Final responses to complaints are approved by the Charities Officer or an appropriately delegated senior individual. Escalated complaints are reviewed and determined by the Trustees.
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 fair, evidence-based and clearly explained.
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.
Complaints relating to personal data
Individuals may raise concerns about how the Trust collects, stores, or uses personal data. This includes concerns about:
• marketing communications;
• accuracy of personal information;
• responses to subject access requests; or
• sharing of personal data.
These complaints will be handled in line with this policy.
Where a complaint relates to data protection, it will be identified as such in the complaints register and handled with appropriate priority and confidentiality.
This process does not affect an individual’s right to exercise their data protection rights or to lodge a complaint directly with the Information Commissioner’s Office (ICO).
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 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.
In order to enable us to fully investigate your complaint, please provide as much detail as you feel is appropriate. If your complaint relates to a matter that occurred some time ago, it may be more difficult for us to investigate fully.
If you are making a complaint on behalf of someone else, outline your relationship to the individual and provide a summary of why you are making contact and whether they have given their permission for you to contact the Trust on their behalf.
If you are making a complaint during the course of a visit, the visitor may record the information on your behalf and that the information was provided verbally. The visitor will also check that you are happy with the information they have recorded.
Any complaints submitted anonymously will be logged on the complaints register, reviewed and considered.
How we will process your complaint:
On receipt, complaints will be allocated a reference number and logged on to the complaints register. The complaints register is used to keep track of complaints received, along with resolution dates and outcomes. It will also record the date when all details should be destroyed.
We will aim to acknowledge receipt of your complaint within five working days. At this stage, we may also ask you for further details in order to help us fully investigate the matter.
We will also aim to respond to your complaint in full within 20 working days. If we are unable to investigate the matter fully within this timeframe, we will contact you to explain why we need further time to respond.
If you are happy with the response given, we will close the file and destroy all records after a maximum period of two years from the date of the complaint, this retention period is set in accordance with the Trust’s Data Protection Policy, which sets out wider data retention requirements. If however, you feel that the complaint has not been resolved to your satisfaction, you have the right to appeal the outcome of the complaint. We request that all appeals are lodged within 28 days of receipt of the report sent to you.
If you appeal against the outcome of your complaint, this will be elevated to our Board of Trustees who will then investigate the matter further. Individuals who were involved in dealing with the original complaint will not be involved in this stage. Trustees will aim to resolve the elevated complaint within a further 20 working days of receipt of your appeal. Any Trustee with a conflict of interest or prior involvement in the original complaint will not participate in the review of an appeal. Appeals will be considered in line with Trustee governance arrangements, ensuring appropriate independence and objectivity. If Trustees are not able to fully investigate the complaint within this timeframe, you will be contacted to advise you of the reasons why and an amended timescale for completion of the report.
At this stage if you do not feel your complaint has been dealt with to a satisfactory level, you can ask for advice from the Charity Commission or the Fundraising Regulator.
The Charity Commission, PO Box 1227, Liverpool L69 3UG. Telephone 0845 3000 218 http://www.charitycommission.gov.uk/how-to-complain/complain-about-a-charity/
The Fundraising Regulator has an online form on their website. Telephone 0300 999 3407 https://www.fundraisingregulator.org.uk/complaints/make-complaint
If you are not satisfied with the outcome of your complaint relating to personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint.
This policy will be reviewed as determined by the Trustees, with the complaints register being reviewed annually. The complaints register will be used to identify themes, trends, and areas for improvement. Learning arising from complaints will be recorded and used to inform service development and reported to Trustees as part of routine governance reporting.
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A definition of key terms is attached to this document. Your attention is also drawn to the Trust’s Privacy policy.
The Trust complies with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), as amended by the Data (Use and Access) Act 2025. Together, these form the UK’s data protection framework.
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 currently require the appointment of a Data Protection Officer under UK GDPR, based on the scale and nature of its processing activities. Responsibility is assigned 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. The Trust keeps this under regular review.
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. In relying on legitimate interests, the Trust considers the impact on individuals and ensures that such processing is necessary, proportionate, and does not override individuals’ rights and freedoms.
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.
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 we have a lawful basis to do so, such as consent, legal obligation, or legitimate interests. 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.
Special Category Data: The Trust may process special category data, including information relating to health, where this is necessary to assess eligibility for support. This processing is carried out in accordance with Article 9 of the UK GDPR, including where it is necessary for reasons of substantial public interest or the provision of social support.
Where required, the Trust will maintain an Appropriate Policy Document in line with the Data Protection Act 2018.
Data Subject Rights
Individuals have the following rights in relation to their personal data:
The right to be informed about how their data is used
The right of access to their personal data (Subject Access Request)
The right to rectification of inaccurate or incomplete data
The right to erasure (“right to be forgotten”), where applicable
The right to restrict processing
The right to data portability
The right to object to processing, including direct marketing
Rights in relation to automated decision-making and profiling
The right to lodge a complaint with the Information Commissioner’s Office (ICO) if they believe their personal data has been handled unlawfully.
Further details of these rights including how to exercise them and how to complain to the ICO, are set out in the Trust’s Privacy Policy.
Requests will be responded to within the timeframes outlined in our privacy policy and complaints policy, unless an extension is justified under data protection law.
Data protection complaints
The Trust provides a clear and accessible process for individuals to raise concerns about how their personal data is handled. Complaints relating to data protection will be handled in accordance with the Trust’s Complaints and Comments Policy, and will be:
• Acknowledged promptly
• Investigated proportionately
• Responded to within a reasonable timeframe
Individuals also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO).
A record of complaints will be maintained and reviewed to support continuous improvement.
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.
Legitimate interests and assessments (LIAs)
Where the Trust relies on legitimate interests as the lawful basis for processing personal data, it will carry out and document a Legitimate Interest Assessment (LIA). This will ensure that:
the processing is necessary for a clear and lawful purpose;
the benefits of the processing are balanced against the rights and freedoms of individuals; and
appropriate safeguards are in place.
The Trust may also rely on recognised legitimate interests where permitted by law (for example safeguarding or preventing harm) and will document decisions accordingly.
Where third parties process personal data on behalf of the Trust, such as, IT system providers, payment processors and professional advisers the Trust will ensure that appropriate Data Processing Agreements are in place in accordance with Article 28 UK GDPR. Where third parties process data on behalf of the Trust, appropriate contractual arrangements are in place to ensure the security and confidentiality of personal data.
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.
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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 from 1 August 2013 if not otherwise restricted 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.
- Students 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 or the Deputy Chairman of the Support and Grants Committee, 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.
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.
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Privacy 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 the Data Protection Act 2018 (DPA) 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. The lawful basis relied upon will depend on the nature of the activity. For example:
• Applications for financial support: necessary for the performance of a task carried out in the public interest and/or legitimate interests
• Donation processing and gift aid: compliance with legal obligations
• Communications and engagement: consent or legitimate interests
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 dependants (where relevant to the enquiry). This information helps to ensure your eligibility for support and to inform the Trust of any additional financial needs.
Special Category Data: The Trust may process special category data, including information relating to health, where this is necessary to assess eligibility for support. This processing is carried out in accordance with Article 9 of the UK GDPR, including where it is necessary for reasons of substantial public interest or the provision of social support.
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.
In certain cases, we may reuse personal data for purposes which are compatible with the original purpose for which it was collected, including internal analysis, service improvement, and supporter engagement. Where we do so, we will ensure that appropriate safeguards are in place and that such use is fair, transparent and lawful.
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 such as, IT system providers, payment processors and professional advisers. Where third parties process data on behalf of the Trust, appropriate contractual arrangements are in place to ensure the security and confidentiality of personal data..
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. Retention periods may vary depending on the nature of the relationship and legal or regulatory requirements. Further detail is set out in the Trust’s Data Protection Policy. 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.
Cookies
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We use cookies to identify you when you visit our website, keep track of your browsing patterns, and build a demographic profile of our site users. This helps us continue to improve our website. Where cookies are not strictly necessary for the operation of the website, they will only be used with your consent.
For more information about the cookies we use, please view our cookie policy.
How do I change my cookie settings?
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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. Where processing is based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing carried out before you withdraw consent.
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.
Right to complain
If you believe we have not handled your personal data in accordance with data protection law, you have the right to complain to us.
Complaints relating to data protection will be handled in accordance with the Trust’s Complaints and Comments Policy, and will be:
acknowledged promptly;
investigated proportionately; and
resolved within a reasonable timeframe.
Records of data protection complaints will be maintained and reviewed to support continuous improvement. We will aim to acknowledge receipt of your complaint within five working days. At this stage, we may also ask you for further details in order to help us fully investigate the matter.
We will also aim to respond to your complaint in full within 20 working days. If we are unable to investigate the matter fully within this timeframe, we will contact you to explain why we need further time to respond.
Raising a data protection complaint
You can raise a data protection complaint by:
• emailing us at csct@cgi.org.uk
• contacting us by phone 0207 612 7049
• or post to The Chartered Secretaries’ Charitable Trust, Saffron House, 6-10 Kirby Street, London, EC1N 8TS
Please provide as much information as possible about the nature of your complaint and the outcome you are seeking.
Contacting the Information Commissioner’s Office
You also have the right to complain to the Information Commissioner’s Office, which regulates data protection law in the UK. The ICO will usually expect you to have raised your concern with us first.
You can find more information on the ICO’s website at ico.org.uk/make-a-complaint.
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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.
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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.
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