FOR APPLICANTS 2021/22
LAST UPDATED NOVEMBER 2021

INTRODUCTION

Applicants to the Social Enterprise Support Fund: Restart and Recover are being processed by one of five independent organisations. If you have been informed that your application is being or has been processed by Community Land & Finance C.I.C (wholly owned by Resonance Limited), you should read the following carefully.

Community Land & Finance C.I.C has appointed its owner, Resonance Limited, to be the Data Processor of the Social Enterprise Support Fund. Data Processing is being completed in order to comply with Community Land & Finance C.I.C’s legal and moral requirements to properly handle, manage, process and monitor grant applications and to allow for the distribution of grants.

Resonance Limited and Community Land & Finance C.I.C are acting as Joint Data Controller with The National Lottery Community Fund in the delivery of the Social Enterprise Support Fund. All data will be handled in compliance with Resonance Limited’s legal, contractual and moral requirements to properly handle, manage, process and monitor grant applications and to allow for the distribution of grants.

Grant applicants are therefore referred to the Resonance Limited GDPR Policy for information on how their data will be treated.

This policy applies to applications made for the Social Enterprise Support Fund rounds running from 25th November 2021 to 24th March 2022 (inclusive). Applicants to other rounds should refer to the Data Protection Policy in place at the time of their application; copies available on request by email to sesf@resonance.ltd.uk.

 

DEFINITIONS

Subsidiary:  means Community Land & Finance C.I.C which is wholly owned by Resonance Limited.

Company:  means Resonance Limited.

GDPR:  means the General Data Protection Regulation.

Responsible Person:  means the person within the Company responsible for managing data protection compliance.

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

 

1. Data protection principles

The Company 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 it is processed;

d.  Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is 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 is 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 Company.

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

c.  This policy shall be reviewed at least annually.

d.  The Company 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 Company 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 Company shall be dealt with in a timely manner.

4. Equal Opportunities

a.  We process equal opportunities monitoring data including health, sexual orientation and race and ethnicity data (“Equal Opportunities Data”) in relation to the board members, senior leadership team and CEOs of VCSEs which apply for grants which we may fund through the Social Enterprise Support Fund (“SESF”).

b.  The Equal Opportunities Data allows the Fund to understand the diversity of applicants and inform any positive action it may take as permitted pursuant to the Equality Act 2010. We identify or keep under review the existence or absence of equality of opportunity or treatment between the applicant organisations, with a view to promoting and maintaining such equality.

5. Lawful purposes

a.  All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).

b.  We process Equal Opportunities Data for SESF for the purpose of equality of opportunity or treatment pursuant to Paragraph 8 Schedule 1 of the Data Protection Act 2018 (“DPA 2018”).

c.  The Company shall note the appropriate lawful basis in the Register of Systems.

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

e.  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 Company’s systems. 

6. Data minimisation

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

7. Accuracy

a.  The Company 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. Unsuccessful applicants will need to contact us directly to update any personal data submitted that falls within the timescales for which we will retain this information.

8. Archiving / removal

a.  To ensure that personal data is kept for no longer than necessary, the Company 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.

c.  For the Social Enterprise Support Fund, all personal and sensitive data about unsuccessful applicants shall be held until 30th June 2027 unless there is either an existing relationship with Resonance, an ongoing complaint, or the funders (The National Lottery Community Fund) require that the data is retained for longer for their monitoring purposes.

d.  For the Social Enterprise Support Fund, all personal and sensitive data about successful applicants shall be held no later than 30th June 2029 unless there is either an additional relationship with Resonance, an ongoing complaint, or the funders (The National Lottery Community Fund) require that the data is retained for longer for their monitoring purposes.

e.  For both successful and unsuccessful applicants to the Social Enterprise Support Fund,  basic data about the application shall be retained for up to 10 years from the closure of the Social Enterprise Support Fund for auditing and monitoring purposes.

9. Security

a.  The Company 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.

10. 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 Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

11. Data Sharing

Data collected for the purposes of the SESF from successful and unsuccessful applicants may be shared with third party evaluators (appointed by the partners to the SESF or The National Lottery Community Fund) to enable the independent monitoring of equality of opportunity. An appropriate data sharing agreement shall be in place before any data is shared with external evaluators.

END OF POLICY