1. For the purposes of European data protection laws (primarily, the General Data Protection Regulation, or GDPR) we are the Controller in respect of your personal data which is provided by you, or collected by us, via this website or through direct correspondence with us. "Personal data" means information from which you can be identified, and "controller" means that we are the ones who decide how and why your personal data is collected. Our full name: Connected Conservation Foundation (a registered charity in England and Wales (number 1183328) and a company limited by guarantee in English (number 11632911)).

   Our contact details: 13 St Lukes Street, Chelsea, London, SW3 3RS

2. We are collecting your personal data in the following ways and for the following purposes – i) when you provide your contact details to us (either directly through the websites, or if you write to us or telephone us and provide those details) so that we can create a database of people who are interested in our activities, and keep those people updated with news about us, ii) through the use of "cookies", or similar technology, in order to understand how our website is being used by visitors, and to provide them with a service which is optimum to them and us.
3. The legal basis for processing your personal data is, for i) above, that you have given your consent for us to collect, hold and use your personal data for the purposes of communicating with you about our activities, and, for ii) above, because it is in our "legitimate interests" to operate our website so that it gives the best possible user experience, and provides us with information about how it used by visitors.
4. The recipients or categories of recipients of your personal data are [to be inserted]:
5. [If we intend to transfer your personal data outside of the European Economic Area, it is to [name country] which is subject to [a finding of adequacy by the European Commission] [us having binding corporate rules in place] [standard data protection clauses have been put in place] [other?].][We do not propose to transfer your personal data outside of the European Economic Area.] / [consider if Article 49 derogations apply.]
6. The personal data will be stored for [insert period or formula].
7. You have the right to request from us access to and rectification or erasure of personal data or to restriction of processing concerning you or to object to our processing of the data as well as the right to data portability.
8. If we are relying on your consent to process data, you may withdraw your consent at any time by notice to us.
9. You have the right to complain to a supervisory authority about the manner in which or otherwise in respect of the manner in which we process your personal data. A "supervisory authority" is the regulator responsible in each EU country for ensuring that data protection laws are complied with.
10. Your provision of personal data to us is not a contractual or legal requirement. However, if you do not supply your personal data to us, we will not be able to keep you updated with news and developments concerning Connected Conservation.
11. [We use automated decision-making processes[, including profiling,] as follows:

This policy applies to the charity trustees of Connected Conservation Foundation (the Charity).

The Charity is committed to ensuring full compliance with the data protection laws. The Charity is a 'controller' as defined in the General Data Protection Regulation (GDPR).

The Charity will ensure that both it, via its staff, consultants, and its suppliers (where appropriate) comply with the six data protection principles set out in the GDPR as follows:

1. Personal data should be:
   1.1 processed lawfully, fairly and in a transparent manner in relation to the data subject;
   1.2 collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
   1.3 adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
   1.4 accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that where personal data is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
   1.5 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; and
   1.6 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. To comply with these principles we must ensure that:
   2.1 we do not collect and hold more personal data than is necessary;
   2.2 we only hold personal data for as long as it may reasonably be required;
   2.3 we review personal data at appropriate intervals to ensure it is accurate and up to date;
   2.4 we do not disclose to the police or other public authority any personal data unless [senior data protection risk owner] has agreed to that disclosure; and
   2.5 we do not transfer personal data outside the Charity or the European Economic Area without the data subject's consent or without putting appropriate safeguards in place.
3. The Charity expects all staff and consultants to:
   3.1 abide by the six data protection principles;
   3.2 ensure so far as reasonably practicable when collecting personal data from data subjects that they have the authority to hold that data in the first place;
   3.3 understand what is meant by processing 'special categories of data' (also sometimes referred to as “sensitive personal data” i.e. data relating to a person's health, ethnicity, religious, political or philosophical views, sex life, sexuality or trade union membership) and any personal data relating to criminal convictions or investigations;
   3.4 anonymise documents and redact personal data where appropriate (e.g. when disclosing a document containing the personal data of a third party or sharing a document as internal know how);
   3.5 recognise a Subject Access Request (SAR), erasure request, rectification request, objection request or restriction request under GDPR and know whom to contact within The Charity
   3.6 recognise what a personal data breach is, and how to respond.
4. Data subject's rights
   4.1. The Charity upholds a data subject's right:
   4.1.1 to be informed (articles 13 and 14 of GDPR). We are fully committed to our obligations to handle personal data in a transparent way and will aim, where an exemption does not apply, to give privacy notices to data subjects appropriate to the processing being undertaken;
   4.1.2 of access (generally referred to as a Subject Access Request (SAR)). We will take care to establish the identity of the applicant. If there is any uncertainty about the identity of
   the applicant, we must ask for supporting documentation. We will also take into account other individual's rights to privacy;
   4.1.3 to rectification. We will, when requested by a data subject, rectify any inaccuracies in personal data of which we were previously unaware; and
   4.1.4 to erasure, to object to or to restrict processing. We will, unless there is a specific and justifiable reason not to, erase personal data on request, and respect requests to object
   to or restrict processing.
   4.2 If you are in any doubt about the effect of this policy, please contact info@connectedconservation.foundation 

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INTRODUCTION AND PURPOSE OF THIS POLICY

This policy applies to Connected Conservation Foundation (the Charity) and has been adopted to safeguard the assets of the Charity as far as possible and to provide clear procedures for controlling the finances of the Charity. They may not be exhaustive. Vigilanceis needed at all times from all concerned with finance, both paid staff and trustees and any matters of concern should be discussed with the Treasurer or Chair, as appropriate. In circumstances where a Treasurer has not been appointed, their function will be carried out by the Chair.

The Charity is governed by the charity trustees (the Charity Trustees). The Charity Trustees and paid staff of the Charity share responsibility for implementing this policy and the sound management of the Charity's assets as a whole.

The Treasurer is delegated the task of reporting to the Charity Trustees on the financial position of the Charity and issues relating to this policy. All Charity Trustees and paid staff are required to abide by these policies and procedures. Where specific responsibilities are allocated, these are stated within the policies and procedures.

The Charity Commission considers it essential for charity trustees to implement a financial controls policy. The Commission’s guidance for charity trustees on financial controls is available on its website at: https://www.gov.uk/government/publications/internal-financial-controls-for-charities-cc8.

This policy should be read in conjunction with the Charity's governing document, and relevant provisions in the governing document take precedence over this policy.

BANK ACCOUNTS

A current bank account will be administered in the Charity's name at a bank chosen by the Charity Trustees.

The bank mandates will always be approved and minuted by the Charity Trustees as will all changes to it.

The bank will be chosen according to quality of service (including value for money in terms of interest paid, bank charges, etc.). No borrowing will be undertaken by the Charity without a decision being taken at a meeting of the Charity Trustees.

The Charity will require the bank to provide current account statements every month. These will be reconciled with the cash book every month by the bookkeeper (as appropriate) and The treasurer will sign the monthly reconciliation.

A deposit account may also be administered in the Charity’s name in an appropriate Society or Company and surplus funds may be invested in appropriate Societies in accordance with the Trustees Investment Act (which allows part of the funds to be invested in equities as well as fixed interest stock). The Charity will not speculate with funds in investments which carry any significant risk.

FINANCIAL RECORDS

Financial records will be kept so that:

1. The Charity can meet its legal and other obligations, e.g., HM Revenue and Customs, Charities Acts, Companies Acts, Common Law.
2. The Charity Trustees can have control of the Charity's finances.
3. The Charity can meet contractual obligations and the requirements of funding bodies.

Careful records will be kept of all income and expenditure, using a system and books approved from time to time by the Treasurer.

All payments will be recorded and cross-referenced in a file containing supporting information (such as order form/letter, invoice or claims form), approved and initiated by a person authorised to do so.

Transactions will be reconciled against bank statements monthly by the Treasurer.

Transfer of funds between bank accounts will be initially authorised by two signatories. Once set up, regular transfers shall be authorised by the Treasurer.

Chief responsibility for the maintenance of records will rest with the Treasurer. All Charity financial records shall be treated confidentially. All Charity financial records will be kept for seven years in accordance with the Charity Act 2011.

ANNUAL BUDGET

The financial year for the Charity will end on 31 October or such other day as may be agreed by the Charity Trustees.

Before the start of each financial year, the charity trustees will approve a budgeted income and expenditure account for the following year.

A paper comparing actual income, and expenditure with the budget will be presented to the CharityTrustees every 3 months.

ACCOUNTS AND AUDIT

The relevant staff member/s, in conjunction with the Treasurer, will prepare regular reports to the Charity Trustees on the Charity’s financial situation and any issues requiring the Charity Trustees' approval or action. These will include quarterly reports setting out actual income and expenditure compared to the budget.

Accounts will be drawn up after each financial year within 4 months of the end of the year and presented to the next Annual General Meeting.

The accounts will be submitted by the Company Secretary (if one is appointed) to the Charity Commission and to Companies House.

The Charity Trustees will appoint an appropriately qualified auditor or an independent examiner, if necessary, to audit the accounts for presentation to the next AGM.

The Charity Trustees will review the appointment of the auditor/independent examiner at least every 3 years.

RECEIPTS (INCOME)

The Charity will ensure that all the income to which it is entitled is received and that this is evidenced.

A schedule of grant and contract income with the method of payment will be maintained and reviewed every 3 months.

All monies received will be recorded promptly in the cash analysis book and banked without delay (note this includes sundry receipts such as payments for telephone calls, photocopying, small donations from individuals etc.) The Charity will maintain files of documentation i.e. letters from funding bodies to back this up.

The Charity may agree specific procedures from the time to time in respect of any particular activities.

All payments must be made to the Charity by cheque or BACS. The Treasurer and book keeper (as appropriate) will review all debts on a monthly basis and agree follow up action. When an individual debt exceeds £2,000 for a period of more than 3 months then this will be brought to the attention of the Charity Trustees and relevant action agreed.

PAYMENTS (EXPENDITURE)

Authorisation to sign a contract, legal agreement or lease committing the Charity to over £10,000 expenditure must be taken at a meeting of the Charity Trustees.

Before committing the Charity to any expenditure, staff need to obtain authorisation from the Treasurer.

The Treasurer can authorise expenditure up to £10,000 if it is in the Charity budget and up to £5,000 if it is not in the budget but there are sufficient funds to meet the cost. Expenditure over these amounts will be referred to the Charity Trustees.

The Charity may administer a credit card account with delegated authority for expenditure as above.

Commitments to urgent expenditure between £10,000 and £20,000 can be made by the Treasurer, provided that permission is obtained from the Chair, or in their absence another Trustee, who will make a decision on behalf of the Charity Trustees.

All invoices will be stamped with full details of the account heading, payee and amount, signed by the relevant manager before approval for payment.

Both e-payments and cheque payments must be authorised/signed by 2 separate people. At least one of these people must be a Trustee, only one of these people may be the Treasurer. Direct debits and standing orders will be authorised by the Treasurer and a Trustee.

Blank cheques will never be signed. The relevant payee’s name will always be inscribed on the cheque before signature; the cheque stub will always be completed. Cheques must not be signed by the person to whom they are made payable.

No payment should be authorised until the signatory is satisfied, through sight of an order form, invoice, or similar written evidence, of the validity of the payment.

All invoices received for payment should be checked and signed, where possible, by the manager responsible for making the original order. Invoices must be authorised for payment by the Treasurer before payment is made.

PAYMENT PROCEDURES

Every payment from the Charity’s bank accounts will be supported by an original invoice (never against a supplier's statement or final demand). The original invoice will be filed and kept for seven years. The person who signs the cheque or authorises the online bank payment should ensure that the Charity's request for payment form (if any) is fully completed. This includes the following:

• Payment method
• Date of invoice /request
• Amount of payment
• Who authorised the payment

The only exceptions to payments not being supported by an original invoice would be for such items as advanced booking fees for a future expenditure, VAT, etc. Here a payment requisition form may be used.

Alternative supporting documentation such as the booking application form must be provided.

Contracts with suppliers can only be set up if authorised by the Treasurer in consultation with the Charity Trustees.

CASH

No cash transactions should be undertaken by the Charity except in exceptional circumstances approved by the Chair.

REIMBURSEMENT OF EXPENSES

The Charity will reimburse expenditure paid for personally by staff and Charity Trustees that is claimed using the agreed claim form (attached to this policy), providing:

• Expenses, such as fares, are evidenced by proof of purchase.
• Other expenditure is evidenced by original receipts.
• Car mileage is based on HMRC allowances.
• The expenditure has been authorised.
• The claim is submitted within 3 months of expenditure being incurred.

The Charity will reimburse the reasonable cost of necessary travel in connection with the Charity's activities. The most economic means of travel should be chosen if practicable/possible:

• Trains and planes – the Charity will reimburse for the cost of standard class travel unless expressly authorised in advance to travel in any other class. A receipt should be obtained for submission with a claim form.
• Taxis – the Charity will not usually reimburse the use of a taxi where there is public transport which would not greatly increase the journey time. When this is not the case or the number of staff/Trustees travelling together makes it cost-effective to do so, taxi fares will be reimbursed. A receipt should be obtained for submission with a claim form.

SALARIES AND PENSIONS

The Treasurer will ensure that all salaries, wages and other emoluments to all employees of the Charity are paid in accordance with statutory requirements and any policies adopted by the Charity.

Salaries due to be paid to staff will be confirmed by a Trustee (usually the Treasurer) before payment is processed.

INSURANCE

The Treasurer will effect insurance cover at a sufficient level to cover assets and possible liabilities as directed by the Charity Trustees.

FIXED ASSETS AND INVENTORIES

The Charity will set up and maintain a fixed assets register stating the date of purchase, cost, serial numbers and normal location of the asset(s). Should the Charity hold stocks of goods, e.g. books, etc., of significant value, it will maintain proper records.

The Charity will maintain an inventory of all capital items. The fixed assets register and inventory will be produced by the bookkeeper and reviewed by the trustees.

OTHER UNDERTAKINGS

The Charity does not accept liability for any financial commitment unless properly authorised. Any orders placed or undertakings given, with financial consequences must be approved by the Treasurer up to a value of £2,000.

Those valued at over £2,000 require the approval of one Charity Trustee.

Those valued at over £10,000 require the approval of two Charity Trustees.

RESERVES AND INVESTMENT POLICIES

The Charity Trustees will consider the level of reserves that is prudent for the Charity to have when agreeing the annual budget. Consideration will be given to future strategy, potential redundancy liabilities, and any other significant factors that should be taken into account were the Charity to close or move to new premises. The specific reserves policy including any designation of reserves for specific purposes may be agreed by the Charity Trustees on an annual basis.

A proportion of the Charity's reserves may be invested to generate investment income. If so, an investment policy will be agreed by trustees. All investments will be decided by the Charity Trustees and should be consistent with the investment policy.

CONFIDENTIALITY

The Charity Trustees, volunteers and employees will at all times act in the best interest of the Charity and if they experience a conflict of interest they will not divulge sensitive information about the Charity.

The Treasurer will ensure that the Charity complies with the Data Protection legislation, in according with such Data Protection policy as may be agreed by the Trustees from time to time.

MONITORING, ENFORCING AND REVIEWING THIS POLICY

Any Charity Trustee who becomes aware of a breach of this policy must report it to the Chair as soon as possible.

The Chair must:

• report all breaches of the policy of which they are aware to the Charity Trustees at the next Charity Trustee meeting; and
• ensure that all breaches are noted in the minutes of the relevant Charity Trustee meeting.

This policy must be reviewed annually, or sooner if required, by the Charity Trustees.