This Data Sharing Agreement (“Agreement”) is made between:
- FT FLIC (hosting the donation page) Registered Charity No: 1194590 Address: Bracken House, 1 Friday Street, London EC4M 9BT
- Magic Breakfast (receiving shared data) Registered Charity No: 1102510 Address: Fora, 42-46 Princelet St, London, E1 5LP
1. Purpose of the Agreement
The purpose of this Agreement is to outline the terms under which FT FLIC will share specific donor data with Magic Breakfast as part of their joint Christmas fundraising appeal. FT FLIC will host the donation page for the appeal. The donation page is linked to the Stripe donation payment site. Stripe will be connected to Beacon which is an integrated tool that automatically adds the ones eligible for Gift Aid to a new claim, ready for one-click submission to HMRC.
When a donation payment is completed, donors will be redirected to a thank you page which asks them to check a consent box to confirm if they are willing to receive future communications from FT FLIC and Magic Breakfast. The email list of donors who consent to future communications with both charities will be shared by FT FLIC with Magic Breakfast for the purposes outlined below.
2. Data Processor Responsibilities
Stripe will act as the Data Controller for any personal data collected during the fundraising appeal and will be responsible for ensuring that the data is collected, processed, and shared in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
FT FLIC will act as the Data Controller for the donor email addresses for those who opt into receiving newsletters from FT FLIC and Magic Breakfast, after donating.
Magic Breakfast will act as the Data Controller for any personal data it receives from FT FLIC under this Agreement.
3. Data to be Shared
The data to be shared between the parties includes the following:
- Report of the donations collected through Stripe payments
- Donor details for those who opt into future communications
- Information for donors who selected a Gift Aid contribution
- Donor details for gifts over £5,000 for due diligence
4. Use of Shared Data
Magic Breakfast will use the shared data only for the following purposes:
- To acknowledge donations made as part of the fundraising appeal.
- To provide updates on future campaigns, where donors have given explicit consent.
- To process Gift Aid submissions to HMRC
The use of the shared data will be clearly and transparently explained to donors on the appeal donation page, hosted by FT FLIC, to ensure donors fully understand how their information will be used and the impact of their contributions.
5. Legal Basis for Sharing
Data will only be shared between the two parties where donors have given explicit consent for their data to be shared with Magic Breakfast by ticking a consent box on FT FLIC’s donation page. FT FLIC will ensure that the donation page clearly explains the purpose of the data sharing and provides an option for donors to opt in.
6. Security and Data Transfer
Both parties agree to implement appropriate technical and organizational measures to ensure the security of personal data during transfer and storage. This includes:
- Secure methods of data transfer, such as encrypted files or secure file-sharing platforms.
- Limiting access to the data to authorized personnel only.
- Prompt deletion of data once the agreed retention period has passed.
7. Data Retention
Magic Breakfast will retain the shared data only for as long as necessary to fulfil the purposes outlined in this Agreement, in compliance with their data retention policy and legal obligations. Magic Breakfast will securely delete any data once it is no longer needed for these purposes.
8. Rights of Data Subjects
Both parties will ensure that donors’ rights under the UK GDPR are upheld. This includes providing donors with access to their data upon request, as well as fulfilling any requests for rectification, erasure, opting out, or restrictions on processing.
9. Breach Notification
In the event of a data breach involving shared data, the party responsible for the breach must notify the other party immediately and take appropriate steps to mitigate the breach in line with regulatory requirements.
10. Termination
This Agreement will remain in force for the duration of the Seasonal fundraising appeal and will terminate once all data has been securely transferred and processed in compliance with the terms of this Agreement.
11. Governing Law
This Agreement shall be governed by and construed in accordance with the laws of England and Wales.
Signed by:
For FT FLIC:
Name: Raja Moussaoui
Position: Interim Executive Director
Date: 8 November 2024
For Magic Breakfast:
Name: Mariah Bush
Position: Head of Individual Giving and Engagement
Date: 20 November 2024