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Privacy Policy



Charity means If Chloe Can a registered charity.


GDPR means the General Data Protection Regulation.


Responsible Person means Esther McVey.


Register of Systems means a register of all systems or contexts in which personal data is processed by the Charity.



1. Data Protection Principles

The Charity is committed to processing data in accordance with its responsibilities under the GDPR

Article 5 of the GDPR requires that personal data shall be:

  • a. processed lawfully, fairly and in a transparent manner in relation to individuals;

  • b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

  • c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  • d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the
    purposes for which they are processed, are erased or rectified without delay;

  • e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  • f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”


2. General provisions

  • a. This policy applies to all personal data processed by the Charity.

  • b. The Responsible Person shall take responsibility for the Charity’s ongoing
    compliance with this policy.

  • c. This policy shall be reviewed at least annually.

  • d. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.


3. Lawful, fair and transparent processing

  • a. To ensure its processing of data is lawful, fair and transparent, the Charity shall
    maintain a Register of Systems.

  • b. The Register of Systems shall be reviewed at least annually.

  • c. Individuals have the right to access their personal data and any such requests made
    to the charity shall be dealt with in a timely manner.


4. Lawful purposes

  • a. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.

  • b. The Charity shall note the appropriate lawful basis in the Register of Systems.

  • c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

  • d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s


5. Data minimisation

  • a. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.


6. Accuracy

  • a. The Charity shall take reasonable steps to ensure personal data is accurate.
    b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.


7. Archiving / removal

  • a. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

  • b. The archiving policy shall consider what data should/must be retained, for how long, and why.


8. Security

  • a. The Charity shall ensure that personal data is stored securely using modern
    software that is kept-up-to-date.

  • b. Access to personal data shall be limited to personnel who need access and
    appropriate security should be in place to avoid unauthorised sharing of information.

  • c. When personal data is deleted this should be done safely such that the data is irrecoverable.

  • d. Appropriate back-up and disaster recovery solutions shall be in place.


9. Breach

  • In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO

Last updated 14 April 2021.

Safeguarding Policy

Children and Young People occupy a central place within the If Chloe Can.

Programme and the work it is engaged in. We strongly believe that all children have the right to be treated fairly, justly and have the right to freedom from abuse and harm.

Our policy ensures that all our staff and volunteers are carefully selected and vetted, have the relevant qualifications and experience, and accept responsibility for helping to prevent the abuse of children. All suspicions and allegations of poor practice will be taken seriously and responded to swiftly and appropriately.

We will offer help and support when a child or young person tells us that they are affected by these issues. We will work extensively with external agencies such as the local Safeguarding Children Board, and the police to ensure as far as possible that children and young people are protected.

The term child is used to refer to anyone under the age of 18.


We will not tolerate bullying. Incidents of bullying will be investigated and treated seriously. Action will be taken to stop the bullying.

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