JESUS FELLOWSHIP COMMUNITY TRUST
Privacy Notice for the JFCT Redress Scheme & Trust Closure
1. About this Privacy Notice
The Jesus Fellowship Community Trust Redress Scheme (the Redress Scheme) is administered by the redress team (the Redress Office) set up by Jesus Fellowship Community Trust (collectively referred to as JFCT, the Trust, we, us, or our in this Privacy Notice) to work in conjunction with Clyde & Co LLP (the Scheme Solicitors) to deal with applications for Redress on behalf of the Trust.
The Redress Scheme is being delivered as part of Phase 2 of the JFCT closure. Following Phase 2, in Phases 3 and 4, the Trust will consider requests for:
- Payment of historic ‘Relief of Need’ ;
- Under-21 contribution refunds; and
- Inclusion of former Trust members in the apportionment of any residual Trust funds.
You should read this Privacy Notice if you:
- interact with us in connection with the Redress Scheme or are considering doing so. This includes if you are considering applying for or have applied for redress under the Redress Scheme (in this Privacy Notice you are referred to as an applicant once you have applied for redress) or are a representative of, or interact with us on behalf of, an applicant;
- interact with us in registering your interest in Phases 3 and 4 of the Trust closure.
- interact with us in providing a reference for those registering their interest in Phases 3 and 4 of the Trust closure.
This Privacy Notice applies specifically to our handling of personal information in connection with the Redress Scheme and/or closure of the Trust. It explains your rights under the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) ((collectively, the Data Protection Legislation). It describes the type of information the Trust collects, why we collect it, how it may be used and who it might be shared with.
Personal data (or ‘data’) means any information that:
- might identify you; and/or
- be about you.
The Trust understands that your privacy is important to you and that you care about how your personal data is used. All your data will be treated sensitively and confidentially and in accordance with the Data Protection Legislation. With regard to the Redress Scheme, this applies if you are applying for yourself, or for someone else because you are their legally appointed representative.
We respect and value your privacy and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. Please read this Privacy Notice carefully and ensure that you understand it.
2. Why the Trust needs your data
The Redress Office is responsible for receiving and processing applications for the Redress Scheme and needs some data about you in order to process your application.
Whether you are (i) the applicant or (ii) applying on someone else’s behalf, the data you provide will be used in order to process your application.
We may also use data we collect to consider and undertake referrals to local authority children’s social care and police, if required, prevent fraud related to the Redress Scheme and closure of the Trust and manage complaints and feedback.
The Trust needs some data about you in order to receive and process your registration of interest in Redress and Phase 3 and Phase 4 in the closure of the Trust, including personal data relating to individuals who provide references for those registering interest in Phases 3 and 4 of the Trust Closure.
3. What is the legal basis for processing your data?
We can only use your data when we have a legal basis under the Data Protection Legislation to do so. We may rely on one or more of the following legal bases:
(a) where you have given consent to the processing of your personal data for one or more specific purposes. By making an application to the Redress Scheme, you provide an explicit consent for your personal data to be processed for the purpose of applying to and deciding the outcome of your application under the Redress Scheme.
(b) where we have another legitimate interest in doing so. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data. We do not use your personal data if the impact on you overrides our interests unless you have agreed or the law otherwise requires or permits it.
(c) where required by law. We may share your data with third parties when it is necessary for compliance with a legal obligation to which we are subject.
When we process special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health and genetic and biometric data), we may rely on one or more of the following legal bases:
(a) the explicit consent you have given to the processing of this personal data for the specific purposes outlined in this privacy policy; and/or
(b) where the processing is necessary for the establishment, exercise or defence of legal claims.
4. What data is requested?
4.1 The following data is required to enable the Redress Office to effectively process and determine your application for redress:
- personal information about you such as your name (including virtue names), applicant name changes since being in community (if applicable), current address (including postcode), correspondence address (if applicable), date of birth, national insurance number, preferred contact method (e.g. telephone number, email address), proof of identity (birth certificate, photographic identity, proof of name change), bank account details (to make a payment to you).
- personal information specific to your application for redress such as confirmation and dates of being in the Jesus Fellowship Community, whether you were a contributing member or a child of a contributing member of the Jesus Fellowship Community and/ or a member of the Jesus Fellowship church, name of community household lived in and dates of residence, dates, frequency of attendance to household and/or Jesus Fellowship Church meetings, details of capital payments to the Trust, name and contact details of referee, including email address and telephone number.
- personal information about your circumstances such as any legal power of attorney or advocacy agreement you may have in place, name, date of birth, proof of identity, contact number and email address of Litigation Friend (if you are under the age of 18 and applying for Individual Redress Payment Scheme).
- personal information about your legal representation such as name, email address and telephone number of your legal representative.
- personal information collected through our Redress Scheme website. When you visit our Redress Scheme website, the website server logs the following information: your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
4.2 The following data is required to enable the Trust to effectively process your registration of interest in Phases 3 and 4 of the closure of the Trust and any potential payments to be made:
- personal information about you such as your name, applicant name changes since being in community (if applicable), date of birth, email address, current address (including postcode), proof of identity (birth certificate, photographic identity, proof of name change), bank account details (should we need to make a payment to you).
- personal information specific to your registration of interest in Phases 3 and 4 of Trust closure such as confirmation and dates of being in the Jesus Fellowship Community, name of community household lived in, dates of residence and details relating to Trust membership, name of referee.
- personal information collected through our website. When you visit our website, the website server logs the following information: your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
5. Sensitive or special categories of personal data
As part of the application process for the Redress Scheme, we will ask you to tell us about your experience while resident in the Jesus Fellowship Community and this could include details of adverse experience, a description of the abuse and impact of the abuse on your life, information about your alleged abuser.
If you have submitted an Individual Redress Payment Scheme application, we need this information to verify that you are entitled to an individual redress payment and to assess the amount of that redress. If you have submitted a Community Adverse Experience Scheme application, we need this information to verify that you are entitled to a support grant and/or a capital refund and a letter of apology.
6. How your data will be used?
Your data will be used primarily:
- to process and determine your application to the Community Adverse Experience Scheme, the Individual Redress Payment Scheme and/or the Other Claims Scheme. We will also use your data to collate anonymised statistical and financial reports to inform the Redress Office and trustees of the Trust for budgeting and monitoring purposes;
- to register your interest in Phases 3 and 4 of the closure of the Trust. We will also use your data to collate anonymised statistical and financial reports to inform the trustees of the Trust for budgeting purposes.
- to collect and process references for registrants registering their interest in Phases 3 and 4 of the Trust closure.
7. Who will have access to your data?
Your data will be viewed by authorised people within the Redress Office and will be used for the purposes set out above. Your data will also be viewed by:
- the trustees of the Trust and by the Scheme Solicitors for the purpose of determining the value of any award of individual redress payment to be paid to you;
- the Trust for the purpose of determining your eligibility for Phases 3 and 4 of the closure of the Trust.
8. Who will we share your data with?
We may need to disclose your personal information to others. We may share your data with third parties where required by law or where we have another legitimate interest in doing so. Personal data is only shared when it is necessary for compliance with a legal obligation to which the controller is subject under Article 6(c) of the GDPR.
We may disclose your personal information (including sensitive information in relation to the Redress Scheme) to:
- our Solicitors;
- our insurers to facilitate an insurance claim;
- the Police Service and/or other relevant child protection authorities as permitted or required by law so that the appropriate authorities can assess any risk that a person may currently pose to children and/or to vulnerable adults. Please note, this may include the identity of any person you mention in the course of your Redress Scheme application as being responsible for abuse.
9. How will we keep your data secure?
The Trust is committed to protecting your privacy. Personal data held by the Trust will be managed effectively and stored in a secure location, and on secure IT systems and networks.
10. How long will You retain my Personal Data?
We will retain your personal information for as long as necessary to fulfil our legal obligations in relation to the Trust and the Redress Scheme. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have administered the Trust and the Redress Scheme correctly. After this period, we will securely destroy your personal information in accordance with our data retention policy.
11. What are your rights?
The GDPR provides you with a specific set of legal rights over your personal and sensitive data. You can:
- Request access to your personal data. This enables you to receive a copy of the personal data the we hold about you. You can do this by making a Data Subject Access Request;
- ask the Trust to correct your data if you think it is wrong or incomplete (Right to rectification). We will take reasonable steps to check and correct your information. We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
- ask for your personal information to be erased in some circumstances (Right to erasure). This enables you to ask the Trust to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- ask for your personal information to be given back to you or another third party you have chosen in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you (Right to data portability);
- ask the Trust to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it (Right to restrict processing);
- to object to your data being processed in certain circumstances (Right to object). where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms; and
- to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to process your application to the Redress Scheme. We will advise you if that is the case at the time you withdraw your consent.
You also have the Right to be Informed. This means that when we collect personal information from you, we will explain our purposes for processing your personal data, our retention periods for that personal data, and who it will be shared with (which we do in this Privacy Notice).
If you would like to exercise any of these rights, or you have any questions about the Privacy Notice, please contact privacy@jesus.org.uk.
If you believe that the Trust has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office, the UK regulator for data protection issues (www.ico.org.uk).
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the email address supplied.
12. Changes to the Privacy Notice
We keep our Privacy Notice under regular review. Any material changes to this Notice will be published on our website. This Privacy Notice was last updated in September 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the duration of the Redress Scheme and/or closure of the Trust.