Privacy Policy

1. Who we are

Markonia Foundation is a charitable organisation supporting access to education and training, including scholarship awards for students studying in Barbados. For the purposes of UK data protection law, Markonia Foundation is the data controller for the personal information described in this policy.

UK registration: Registered charity number 1206148.
Barbados registration: Charity SRN 16602.
Contact address: International House, The McLaren Building, 46 The Priory Queensway, Birmingham, B4 7LR
Email: hello@markoniafoundation.org

2. Scope of this policy

This policy applies when you visit markoniafoundation.org, contact us, make or enquire about a donation, subscribe to updates, apply for or receive a Markonia award, take part in our activities, or otherwise interact with the Foundation. It also applies where a parent, guardian, referee, educational institution or other person supplies information about you.

This policy reflects the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR), and relevant amendments made by the Data (Use and Access) Act 2025. Barbados data protection requirements may also apply to our activities in Barbados.

3. Information we may collect

• Identity and contact details, such as your name, postal address, email address, telephone number and date of birth.
• Donation and supporter details, including donation amount, date, Gift Aid status where applicable, correspondence and fundraising preferences. Payment card or bank details are normally collected directly by the payment provider and are not stored by us.
• Scholarship and applicant information, such as education and training history, qualifications, course details, personal statements, references, household or financial circumstances, eligibility information and evidence supporting an application.
• Information about award recipients, including progress reports, attendance, academic or training outcomes, payments made for their benefit and communications with their institution.
• Special category information where relevant and necessary, such as health, disability, racial or ethnic origin, or religious information contained in an application or voluntarily disclosed to us. We will only use it where an additional legal condition applies.
• Photographs, video, testimonials and stories where you have agreed to their use or where another lawful basis clearly applies.
• Enquiry, correspondence, complaint and safeguarding information.
• Technical and website information, such as IP address, browser and device information, pages visited, referring page, cookie identifiers, consent choices and security logs.
• Marketing preferences and records of when and how you gave, refused or withdrew consent.

Please avoid sending information we have not requested, particularly sensitive information about another person.

4. How we obtain information

We collect information directly from you through website forms, email, applications, donations, events and other communications. We may also receive information from parents or guardians, referees, educational or training institutions, payment providers, Gift Aid or regulatory bodies, publicly available sources, and people acting on your behalf. Where we receive your information from someone else, we will provide privacy information within the period required by law unless an exemption applies.

5. Why we use information and our lawful bases

We use personal information only when we have a lawful basis. Depending on the activity, we rely on one or more of the following:

• To respond to enquiries and administer relationships with applicants, award recipients, supporters and partners — legitimate interests, and contract or steps requested before entering a contract where relevant.
• To assess eligibility, select award recipients, administer awards, monitor progress and evaluate our charitable impact — legitimate interests in running the Foundation effectively; contract where an award agreement applies; and legal obligation where required.
• To process donations, maintain financial records, claim Gift Aid, prevent fraud and meet charity, tax, accounting and regulatory duties — contract, legal obligation and legitimate interests.
• To send fundraising news and charitable updates — consent where required by PECR, or the charity soft opt-in where it lawfully applies. Under the soft opt-in, we may contact a person who supports or expresses an interest in our charitable work, provided we offer a clear opportunity to object when details are collected and in every message.
• To publish photographs, testimonials or beneficiary stories — consent where appropriate, particularly for identifiable children or sensitive stories; otherwise legitimate interests following a careful assessment.
• To operate, secure, troubleshoot and improve our website and services — legitimate interests in providing a safe and effective service; consent for non-essential cookies or similar technologies.
• To handle concerns, safeguarding matters, complaints, legal claims and regulatory requests — legal obligation, recognised legitimate interests where applicable, legitimate interests, or the establishment, exercise or defence of legal claims.

Where we rely on legitimate interests, those interests include operating and improving the Foundation, administering charitable funds fairly, protecting our systems, preventing misuse, communicating with supporters and demonstrating charitable impact. We consider necessity, reasonable expectations and the effect on individuals before relying on this basis.

Where we use special category information, we also identify a condition under Article 9 UK GDPR and the Data Protection Act 2018, such as explicit consent, substantial public interest with an appropriate policy document, safeguarding, or legal claims. We do not use special category information merely because it is available.

6. Children and young people

Our scholarship work may involve children and young people. We take their needs, understanding and best interests into account when designing forms, notices and decisions. We collect only information that is necessary, use clear age-appropriate explanations where appropriate, restrict access, and normally involve a parent or guardian where required. We will not knowingly use a child's information for behavioural advertising.

7. Donations and payment providers

Online donations may be processed by PayPal or another payment provider shown at checkout. The provider processes payment and fraud-prevention information under its own privacy notice and may act as an independent controller for parts of that processing. We generally receive confirmation of the donation, the amount, your name and contact information, and relevant transaction details, but not your complete payment-card credentials. Please review the provider's privacy information before paying.

8. Cookies and website analytics

We may use strictly necessary cookies to operate and secure the website. We will not place analytics, advertising, social-media or other non-essential cookies on your device before obtaining valid consent, unless the law provides an exemption. The cookie control must make accepting and rejecting non-essential cookies equally straightforward. You can change or withdraw your choice at any time through the website's cookie settings. More detailed information, including cookie names, providers, purposes and lifetimes, should appear in our Cookie Notice or consent panel.

9. Who we share information with

We may share only the information necessary with:

• trustees, authorised volunteers and contractors who need it for their role;
• educational and training institutions involved in verifying an application, delivering a course, receiving award funds or monitoring progress;
• website hosting, cloud storage, email, database, analytics and IT-security providers;
• payment processors, banks, accountants, auditors and professional advisers;
• HM Revenue & Customs, the Charity Commission, Barbados regulators, law-enforcement bodies, courts or other authorities where required or permitted by law; and
• a successor organisation if the Foundation restructures, merges or transfers an activity, subject to appropriate safeguards.

We do not sell personal information. Service providers acting as processors may use information only on our documented instructions, must keep it secure and must not use it for their own unrelated purposes.

10. International transfers

Because the Foundation operates in the United Kingdom and Barbados, personal information may be accessed or transferred between those countries and may be processed by service providers in other countries. When UK personal information is transferred outside the United Kingdom, we use a lawful transfer mechanism where required, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another permitted safeguard. We also assess the protections in the destination country and apply supplementary security measures where appropriate. You may contact us for further information about the relevant safeguards.

11. How long we keep information

We keep information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, safeguarding and reporting requirements. Our usual guide is:

• Unsuccessful scholarship applications: normally 12 months after the decision, unless a complaint, safeguarding issue or legal reason requires longer.
• Successful applications and award administration records: normally 7 years after the award relationship ends, with selected impact records retained longer in anonymised or appropriately archived form.
• Donation, Gift Aid, accounting and tax records: normally 7 years after the end of the relevant financial year.
• Routine enquiries: normally up to 2 years after the matter is closed.
• Marketing records: until consent is withdrawn or an objection is received; we may retain a minimal suppression record so we continue to respect that choice.
• Cookie and consent records: for the lifetime stated in the cookie control and only as long as needed to demonstrate or respect the choice.
• Safeguarding, complaint and legal records: according to the seriousness of the matter, applicable guidance, limitation periods and legal requirements.

We may delete information earlier when it is no longer needed or retain it longer where law, safeguarding duties, an active dispute or a regulator requires this. At the end of the retention period, we securely delete or anonymise it.

12. Security

We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, alteration, disclosure or access. These include access controls, appropriate authentication, secure service providers, backups, staff and trustee awareness, and procedures for handling incidents. No internet service is completely secure, but we review risks and safeguards proportionately.

13. Your data protection rights

Depending on the circumstances, you may have the right to:

• be informed about how we use your information;
• ask for access to your personal information;
• ask us to correct inaccurate or incomplete information;
• ask us to erase information;
• ask us to restrict how information is used;
• receive certain information in a portable format;
• object to processing based on legitimate interests and object at any time to direct marketing;
• withdraw consent at any time, without affecting processing that was lawful before withdrawal; and
• ask for human intervention in relation to a solely automated decision that produces legal or similarly significant effects.

These rights are not absolute and exemptions may apply. We do not currently make scholarship decisions solely by automated means. To exercise a right, email hello@markoniafoundation.org. We may ask for reasonable information to confirm your identity and clarify your request. We will respond within the period required by law and normally do not charge a fee.

14. Data protection complaints

If you are concerned about our use of your information, please email hello@markoniafoundation.org with the subject line 'Data protection complaint', or write to the address in section 1. Please explain what happened, what information is involved and the outcome you seek. We will acknowledge the complaint within 30 days and respond without undue delay. We will provide information about our complaints process in an accessible electronic form.

You also have the right to complain to the UK Information Commissioner's Office (ICO). Visit ico.org.uk/make-a-complaint or telephone 0303 123 1113. If Barbados law applies, you may also contact the Barbados Data Protection Commission through its official channels. We would appreciate the opportunity to address your concern first, but this does not affect your right to contact a regulator.

15. Links and third-party services

Our website may link to third-party websites, social platforms or payment services. Those organisations control their own processing. We encourage you to read their privacy notices; this policy does not govern their websites or services.

16. Changes to this policy

We may update this policy when our services, technology or legal obligations change. The current version will be published on our website with a revised effective date. If a change materially affects how we use information, we will take reasonable steps to bring it to the attention of affected people and obtain new consent where required.

17. Contact us

For privacy questions, requests or complaints, contact:

Markonia Foundation
International House,
The McLaren Building,
46 The Priory Queensway,
Birmingham, B4 7LR

Email: hello@markoniafoundation.org