Privacy notice for trustees

Who is responsible

PHA UK (Pulmonary Hypertension Association UK) is the data controller. The portal is operated by the company secretary, who is also PHA UK’s Chief Operating Officer. Any question about this notice, or any request about your own information, should go to him in the first instance.

What the portal holds about you

Four things, and nothing beyond them.

• Who you are. Your name, your email address, your role on the board, the date you were appointed and, when the time comes, the date your term ended.
• What you have done in the portal. When you signed in, which papers you opened, which you acknowledged, and when. If you are the Chair, your sign-off on a set of minutes.
• Your register of interests. The declaration you write yourself, and its history when you update it.
• Notices sent to you. The fact that papers were circulated to you, the address they went to, and confirmation that the mail provider accepted them.

Board papers, minutes, agendas and attendance lists also name people, including you. Those are the charity’s own records of its decisions rather than a separate profile of anyone.

What the portal does not hold

Worth stating plainly, because governance systems are often assumed to do all of it.

• No record of every page you look at. The portal records the things that matter for governance: signing in, opening a paper, acknowledging one, declaring an interest, signing minutes. Moving around the site is not tracked.
• No IP addresses and no record of your device or browser. Your IP address is used for a moment to limit repeated sign-in attempts and is never written down.
• No analytics, no advertising, and nothing loaded from another company. There are no cookies except the one that keeps you signed in.
• No password. You sign in with a link or a code sent to your email address, so there is no password stored to be stolen.

Why we hold it

Two reasons. Some of it the charity is required by law to keep: minutes of board meetings, the register of interests, and the record that notice of a meeting was given. Those duties come from company law and charity law, and they apply whether or not a portal exists.

The rest is held because it is necessary to run a board: knowing who is on it, giving you access, and being able to show that the papers reached you and were read. Being able to demonstrate that protects you as much as it protects the charity.

We do not rely on your consent for any of this, because consent you cannot withdraw and remain a trustee would not be a real choice.

Who else can see it

• Other trustees. The register of interests is visible to the whole board, which is the point of a register. Whether you have acknowledged a paper is also visible, as a count and by name, so the board can see its own coverage.
• The company secretary. He administers the portal and can see the full record, including the audit log.
• The charity’s external auditors. During an audit they are sent a link to specific signed minutes or adopted accounts. The link expires, it can be switched off, it reaches nothing else, and every use of it is recorded. This is the ordinary statutory audit disclosure.
• Regulators, where required. The Charity Commission or Companies House, if they ask for something the charity must provide.

The portal runs on services PHA UK uses under contract: a database and file host, an email provider for sign-in codes and meeting notices, and a web host. They process this information on the charity’s instructions and for no other purpose. Nothing here is sold, shared for marketing, or used to train anything.

How long it is kept

• Minutes, approvals and the Chair’s signature. Kept permanently. They are the charity’s record of what its board decided, and the law sets a minimum of ten years for the minutes themselves.
• Board papers and acknowledgements. Kept with the meeting they belong to. When a paper is corrected, the earlier version stays as well, because what the board actually read at the time is part of the record.
• Your register of interests. Kept for your time on the board and seven years afterwards.
• The audit log. Seven years.
• Email addresses in notice records. Removed after two years. The fact that you were sent the papers survives; the address does not.
• Your trustee record. Kept for your term and seven years after it ends, then deleted.

Your rights, and one honest limit

You can ask for a copy of what is held about you, ask for something wrong to be corrected, and object to how it is used. Ask the company secretary and he will deal with it.

The limit is erasure. Governance records the charity is legally required to keep cannot be deleted on request, and your name in the minutes of a meeting you attended is the charity’s record of its own decision rather than information held about you that can simply be removed. What can be deleted is your trustee record once its retention period has passed, and your email address from the notice records.

Corrections to minutes work the same way as they do on paper. A correction produces a new version that replaces the old one, and both stay on the file, so the record shows what changed and when.

How it is protected

You reach the portal with a one-time link or code sent to your address, so there is no password to guess. Every screen checks who you are at the database itself rather than in the page, which means a fault in the interface cannot show you, or anyone else, something they should not see. Papers are read in the portal rather than downloaded, and every file is checked against a fingerprint taken when it was uploaded, so an altered file will not open at all. The evidence records, which is to say acknowledgements, declarations, signatures and the audit log, can be added to but not edited or deleted. When someone leaves the board their access ends immediately, and any session they still have open stops working.

One thing the portal cannot do, and does not claim to: once a paper is on your screen, nothing prevents a screenshot. Reading in the portal removes the easy route to a copy and records who opened what. It is not a guarantee, and treating board papers as confidential still rests with each of us.

If you are not happy

Please raise it with the company secretary first, because most things are quicker to fix that way. You also have the right to complain to the Information Commissioner’s Office, the UK regulator, at ico.org.uk.