PERSONAL DATA AND PRIVACY POLICY

INTRODUCTION TO THE CHARITY

The Sayagyi U Ba Khin Memorial Trust (the Charity) is a charitable trust registered with the Charity Commission (registered no. 280134). It owns and administers the International Meditation Centre in Wiltshire (IMC-UK).

The Charity’s website is www.internationalmeditationcentre.org.

10-day residential courses in Theravada Buddhist meditation in the tradition of Sayagyi U Ba Khin and Mother Sayamagyi are held monthly at IMC-UK, taught by a qualified teacher. These courses are open to applicants from all walks of life who are willing to give the meditation a fair trial and who are physically and mentally able to practise the meditation.

PERSONAL DATA AND PRIVACY

In order for the Charity to run the meditation courses referred to above, while fulfilling its responsibilities, it processes (i.e. records, copies and refers to) personal data relating to the students who apply for courses at IMC-UK, as originally submitted in their application forms (and amended subsequently where applicable). Students complete an application form when applying to attend a course at IMC-UK for the first time. They are not required to complete a form for any course they attend subsequently, so long as their details remain on the Charity’s database.

WHAT PERSONAL DATA DO WE COLLECT?

Personal Data Recorded on a Database

The Charity records the following data (if given) on its database relating to those who have applied to attend a course at IMC-UK:

  • Name, date of birth, nationality, gender, address, email address, telephone numbers

  • Source of introduction

  • Any food allergy notified by application form or other means

  • Whether or not he/she wishes to receive a copy of the twice-yearly IMC-UK Newsletter (with information about future course dates) and, if so, whether by post or email

  • Whether or not a Gift Aid declaration has been made (see below)

Personal Data Recorded Elsewhere

  • Course application forms (these are retained only for the duration of the applicant’s first course)

  • Gift Aid declarations made by those who have given and/or propose to give (a) donation(s) to the Charity and any donations on which Gift Aid has been claimed

  • Email correspondence relevant to students’ enquiries

WHAT DO WE DO WITH YOUR PERSONAL DATA?

We use the information about students’ health, medication and past meditation practices collected on the course form to arrange food, accommodation and teaching according to students’ needs and take appropriate measures for the safety and wellbeing of the students, staff and visitors.

We retain hard copy course application forms for a maximum period of two weeks after the relevant course and then they are shredded.

We may provide students’ names to taxi or share-ride companies to facilitate pick-ups requested by students and a list of students’ names and the times of their taxis ordered are put up at the end of the course.

The teacher and managers use your information:

  • To make sure you will be able to benefit from a course and that we are able to provide for any support needs you may have

  • If you are a child or a vulnerable adult, we will need to check that you have the necessary parental consents and, where necessary, are chaperoned

  • To answer your correspondence

  • Where you have asked us to do so, to send you a bi-annual newsletter with forthcoming course information and occasional news of any other special events at IMC-UK

  • Where you have made a valid Gift Aid declaration, to make Gift Aid claims to HMRC (if eligible)

  • The charity’s website https://www.internationalmeditationcentre.org solicits and stores email addresses on Smart Hosting, URL: https://krystal.uk a third party server.

  • The Charity’s website https://www.ubakhin-vipassana-meditation.org/ solicits and stores email addresses on Square Space, URL: https://www.squarespace.com a third party server.

  • The websites use Google Analytics to analyse traffic and to help us understand how visitors use the site.

  • The websites use cookies, as described in the cookie policy at https://internationalmeditationcentre.org/policy/cookie

We do not share your personal details with anyone outside the organisation.

WHAT IS THE LEGAL BASIS FOR THE CHARITY’S DATA PROCESSING?

By law, the Charity may only process personal data where there is a legal justification for doing so.

In accordance with that law, the Charity processes personal data as described above because it is necessary for the purposes of the legitimate interests pursued by the Charity, namely:

  • to protect the interests of the students attending (or applying to attend) courses at IMC-UK, whether before, during and/or after attending meditation courses at IMC-UK and to manage its relationship with its students generally; and

  • to comply with its legal obligations in relation to the students, including those relating to health and safety (including food safety) and safeguarding;

  • to send the bi-annual Newsletter to students (unless they have indicated they do not wish to receive it) and to notify them of any special events at IMC-UK

Where we use your personal data for the Charity’s legitimate interests, we use appropriate safeguards and make sure that we take into account any potential impact that such use may have on you. If we believe that your interests or fundamental rights and freedoms override our legitimate interests then we will not use your personal details on this basis and may seek your specific consent.

Individuals can withdraw their consent to our processing of personal data at any time by notifying the teacher or manager in person or by contacting the meditation centre by email or phone.

YOUR RIGHTS IN RELATION TO PERSONAL DATA

You have the following rights in relation to your personal data.

  1. The right to information and access

    You have the right to request access to the information we hold about you.

    On request the Charity will provide you with copies of your personal data in a convenient format.

  2. Rectification, erasure and restriction

    You have the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances. In responding to such requests, we will let you know the impact of such restrictions or deletions. For example, if your details were deleted, we would no longer be able to send you a Newsletter and, if you subsequently wished to attend a course at IMC-UK, you would be required to complete a new application form.

    The Charity takes reasonable steps to ensure that the personal details it holds about you are accurate and up to date, as long as we are provided with the necessary information to make necessary changes. We will comply with any request to rectify inaccurate data we may hold about you. However, the Charity relies on the accuracy of the information you supply to us. If you are aware of any changes to the information you have supplied to us previously, please let us know so we can amend our records.

  3. Right to object

    You have the right to object to the Charity using your information on the basis of its legitimate interests. You may action your rights by contacting us as set out below and we will comply with your request unless we have a lawful reason not to do so.

    The Charity will endeavour to handle any such requests within a reasonable period and in any event within one month of the original request.

  4. Contact

    Requests for access or to rectify, erase or restrict the use of your personal data or any objection should be sent by email to: show">show, or by post to: The Secretary, IMC-UK, Splatts House, Heddington, Calne SN11 0PE.

DATA SECURITY

The Charity takes appropriate technical and organisational measures to protect the personal data we transmit, store or otherwise process against accidental or unlawful destruction, loss, alteration or unauthorised disclosure or access.

The contents of all application forms are input manually into a database which is password protected and not connected to the Internet. Any paper copies are shredded after the applicant's first course. Students’ personal data is backed up to onsite and offsite locations on a regular basis.

HOW LONG DOES THE CHARITY RETAIN PERSONAL DATA?

The Charity will only retain personal data for as long as it is necessary for the purposes of its legitimate interests or other legal requirement. Please contact us if you require further information about our retention policies.

DATA BREACHES

In the event of any breach of the Charity’s systems impacting on the security of a student’s personal data the Charity will inform the individual(s) concerned as soon as practically possible, describing the nature of the breach, the possible consequences and the remedial measures being taken.

COMPLAINTS

If you are unhappy about the way the Charity processes your personal data, please contact us using the contact details below.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their contact details are:

Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 700 or via their website: https://ico.org.uk/global/contact-us

CONTACT US

If you have any comments or queries relating to this policy, please write to:

The Secretary
IMC-UK, Splatts House, Heddington
Calne SN11 0PE
or send an email to: show">show.

UPDATING THIS POLICY

We may change our data processing policies and activities from time to time. We will notify you of any changes to this policy as required by law and post an updated version on our website.

26th April 2019