GDPR Privacy Policy 

GDPR PRIVACY NOTICE The Fifth Trust, Registered Charity 1136718

GDPR Privacy Notice Issue 01 (13/03/2018)


The Fifth Trust is a Kent-based charity that supports adults with learning difficulties. We provide daycare facilities on two sites in the Elham Valley near Canterbury for over 120 students, half of whom live locally in residential homes associated with the Trust. Our aim is to provide a safe and fulfilling way of life, helping each individual to achieve their full potential. On-site, we also have a vineyard, garden centre and café.


For any queries regarding the content of this Privacy Notice, or any requests to access data held, please contact Nikki Marley on 01227 832022 or e-mail The Fifth Trust is registered with the Information Commissioner’s Office.


Processing Activity Statements from the Legal Basis Matrix

Activity; purpose/justification – Legal Basis & Special Condition



• Absence Monitoring and Appraisals; to monitor performance, sickness and holiday absences – Legitimate Interests.

• HR Issues, Consultant; the occasional referral to QBH Solutions for the purposes of consultation on HR Documents such as Contracts of Employment, and for assistance with resolution on disciplinary and grievance issues – Legitimate Interests.

• Employment Records; retention of application form and contract, copies of identification and qualifications where applicable – Legal Obligation / Special Condition B Legal Compliance.

• DBS Checks; checks conducted and copies retained for all staff & volunteers working with vulnerable people and children – Legal Obligation / Special Condition B Legal Compliance.


General Contacts

CRM for B2B; Business contacts from networking for the promotion of the Trust – Legitimate Interests


CRM for Direct Marketing; Personal contact details for people subscribed to receive posts and emails from The Fifth Trust regarding events, news and fundraising opportunities – Consent


Connect Childcare

Software Photos; Digital pictures of staff and students for use on social media and for other marketing purposes – Consent

Student Information; Personal details, including a medical & health history for the purposes of assessing how best to meet the needs of the student and deliver a suitable training package – Contract

Medical Alerts; A process exists to inform all staff on-site of a medical emergency, this includes the immediate medical requirements of the Student involved – Vital Interests / Special Condition C Vital Interests

Medical Emergencies; An accident book is held, as well as reports on medical incidents – Legal Obligation / Special Condition B Legal Compliance



Accreditation; Evidence of the Trust’s activities and responsible persons are provided in the application for Registered Charity Status – Legitimate Interests


Donations; Retention of Gift Aid records – Legal Obligation


External Customers

Supply of Goods & Services; Records of customer details and their requirements are kept for the duration of any contract for garden maintenance and regular log deliveries – Contract