Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- How to complain
Contact details
Post: Rokpa Trust, Eskdalemuir, Langholm, Dumfries DG13 0QL, Scotland
Email: companysecretary@samye.org
What information we collect, use, and why
We collect or use the following information to provide services and goods:
- Names and contact details
- Gender
- Addresses
- Date of birth
- Emergency contact details
- Next of kin details
- Photographs or video recordings
- Service use history
- Health information (including medical conditions, test results, allergies, medical requirements and medical history)
- Dietary information (including allergies and health conditions)
- Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
- Information about work, home and living conditions
- Information about support requirements
- Information about lifestyle, interests or personal history
- Criminal offence data
- Records of meetings and decisions
- Information about income and financial needs for funding or personal budget support
- Payment details (including card or bank information for transfers and direct debits)
- Information relating to compliments or complaints
We collect or use the following information to receive donations or funding and organise fundraising activities:
- Names and contact details
- Addresses
- Payment or banking details
- Donation history
- Taxpayer information (for Gift Aid purposes)
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
- Names and contact information
- Customer or client accounts and records
- Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
- Financial transaction information
- Witness statements and contact details
- Information relating to health and safety
We collect or use the following personal information for service updates or marketing purposes:
- Names and contact details
- Addresses
- Marketing preferences
- Recorded images, such as photos or videos
- Donation history
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Financial transaction information
- Health and safety information
- Criminal offence data
We also collect or use the following information to comply with legal requirements:
- Health information
We collect or use the following personal information for recruitment purposes:
- Contact details (e.g. name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (e.g. job application, employment references or secondary employment)
- Education history (e.g. qualifications)
- Right to work information
- Details of any criminal convictions (e.g. Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Purchase or service history
- Witness statements and contact details
- Relevant information from previous investigations
- Information relating to health and safety (including incident investigation details and reports and accident book records)
- Correspondence
We also collect or use the following information for dealing with queries, complaints or claims:
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
- Your right to erasure - You have the right to ask us to delete your personal information.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
- Your right to object to processing - You have the right to object to the processing of your personal data.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods, including delivery and third-party referrals are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, Rokpa Trust or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- To further one or more of Rokpa Trust’s charitable purposes, including offering or providing support to further one or more of those purposes.
- To keep supporters and beneficiaries informed about the same or similar teachings, activities and events that they have previously attended.
Our lawful bases for collecting or using personal information to receive donations or funding and organise fundraising activities are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, Rokpa Trust or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Processing complaints data will help Rokpa Trust to protect all who come into contact with the charity by identifying areas of required improvement and taking appropriate action, which will help to prevent future issues arising.
- Processing complaints data will help Rokpa Trust to protect all who come into contact with the charity by identifying areas of required improvement and taking appropriate action, which will help to prevent future issues arising.
Where we get personal information from
- Directly from you
- Regulatory authorities
- Family members or carers
- Other health and care providers
- Social services
- Charities or voluntary sector organisations
- Schools, colleges, universities or other education organisations
- Councils and other public sector organisations
- Previous employers.
How long we keep information
The Data Retention Schedule at Appendix 1 sets out the time periods that Rokpa Trust retains data.
Who we share information with
Others we share personal information with
- Insurance companies, brokers and other intermediaries
- Care providers
- Organisations we need to share information with for safeguarding reasons
- Emergency services
- Professional advisors
- Legal bodies or authorities
- Local authorities or councils
- Relevant regulatory authorities
- External auditors or inspectors
- Organisations we’re legally obliged to share personal information with
- Publicly on our website, social media or other marketing and information media
- Current employers
- Previous employers
- Suppliers and service providers
- Professional consultants
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow
Cheshire, SK9 5AF
Helpline number: 0303 123 1113
Last updated: 12 April 2025
APPENDIX 1: Rokpa Trust Data Retention Schedule
Financial Records
Record category |
Retention period |
Supplier contracts |
6 years from end of contract |
Donor records / personal details of living donors |
6 years from last donation |
Legal and Business Records
Record category |
Retention period |
Board meeting minutes |
PERMANENT |
Legal team meeting minutes |
PERMANENT |
Non-employment / volunteer contracts, agreements and other arrangements |
7 years from end of contract |
Registers: Breaches |
PERMANENT |
Registers: Complaints |
PERMANENT |
Documentation relating to complaints |
6 years after resolution the complaint |
Registers: Conflicts of interest |
PERMANENT |
RIDDOR |
6 years after last entry or end of investigation if later |
Other incidents management concerns and breaches |
3 years from the date of the incident |
Training records |
6 years from date of training |
Health & Safety procedures, good practice guidance, assessments, inspections and advice |
7 years from end of financial year in which issued |
Human Resource Records
Personal data record category |
Retention period |
HR operational activities including all records relating to employees from successful recruitment to exit[1] |
6 years from end of employment |
Disclosure and Barring Service (DBS) and Disclosure Scotland certificates |
6 months after recruitment decision or issuance of certificates thereafter |
Employee email accounts |
1 year from end of employment |
Unsuccessful employment candidates - all data e.g. application letters, CVs, references, certificates, interview notes etc |
6 months from application |
Resident and Volunteer Records
Personal data record category |
Retention period |
Residents’, volunteers’ agreements and identification documents |
2 years from end of residency / volunteering |
Unsuccessful residency / volunteer applicants - all data e.g. application letters, references, certificates, interview notes etc |
6 months from application |
Emails containing Personal Data or Sensitive or Special Categories of Personal Data attachments |
1 year after receipt of the email. If required to be kept, the email should be downloaded or printed and securely filed. The email can then be deleted. |
Deleted emails, desktop trash folder |
30 days from deletion |
Newsletter subscribers (e.g. name, email address) |
Kept until Data Subject unsubscribes / requests to be removed from system or updates their details. |
Call recordings / voice messages containing personal data |
30 days after receipt (unless required to be kept for legal / insurance reasons) |
Short (under 3 months’ duration) course registration, diary entries, related emails, messages and bookings and attendance lists |
30 days after course ends |
Retreat participants (over 3 months duration) |
1 year after retreat ends |
[1] Including e.g. evaluations, application forms, copies of academic and other training received, employment contracts and their amendments, correspondence concerning appointment, appraisals, promotions and demotions, agreements concerning activities in relation to the works council, references, and sick leave records