Data Handling Policy

This policy is for internal governance and is published here for transparency. It should be read alongside our Privacy Policy, which explains your rights as a data subject.

This policy was last updated on 22 September 2026.

Who This Policy Applies To

This policy applies to all trustees, volunteers, and anyone acting on behalf of Your Simpal who has access to applicant, beneficiary, donor, or referrer data. Everyone covered by this policy is expected to have read and understood it before handling personal data.

Data Minimisation

We only ask for the information we need to assess eligibility and provide support. We do not collect data speculatively or retain it for possible future use.

How Application Data is Collected

Applications and referrals are submitted through forms on our website. Nothing is retained in the website’s database at any point. Each submission is then split at source: the information needed to assess the application, including any health or medical detail, is sent by email to a dedicated applications mailbox and goes nowhere else, while the remaining details, such as name, contact details, organisation and the type of support requested, are recorded in our application tracker so that we can manage and report on our work.

Database retention of form submissions must remain disabled at all times. This is a standing rule for the website, not a one-off configuration choice, and it must not be re-enabled for any reason. The same applies to any feature that saves a part-completed application, such as save and resume, because that would store applicant information, including health detail, in the website’s database.

Where Data is Stored

Assessment information is held only in a dedicated applications mailbox within our Google Workspace environment, which applies encryption at rest. It is never copied into the application tracker and is held nowhere else. The application tracker is a spreadsheet in the same Google Workspace environment, holding names, contact details, organisation, the type of support requested and the outcome. It never holds health or medical information. Access to both is limited to the individuals who need it, and the applications mailbox is reached by delegated access, so no additional password is created or shared.

We do not export, copy, or forward application data to personal devices, personal email accounts, or third-party tools outside our Google Workspace environment, except where necessary to arrange delivery of a SIM card or device to the applicant.

Who Can Access What

Access to applicant and beneficiary data is limited to the volunteers directly involved in processing that application. We do not give blanket access to all volunteers as a default.

Our Data Protection Officer, Mr Chris Lewis, has oversight of how data is handled across the charity and is the first point of contact for any data protection question or concern.

Special Category Data

Some of the information we handle, including health and medical information, and information relating to domestic abuse or human trafficking, is special category data under the UK GDPR. We take particular care with this data:

• It is only accessed by volunteers directly involved in assessing or fulfilling the application.
• It is never used or referenced for any purpose beyond assessing eligibility and providing the support requested.
• It is not discussed outside the context of processing the application, including with other volunteers who do not need to know it.

Referrals From Professionals

Where a referral is made on an applicant’s behalf by an NHS worker, social worker, hospice worker, or other professional, we handle the information they provide under the same principles set out in this policy. We do not share what a referrer has told us with the applicant or any third party without good reason.

Retention

• Assessment information, including any health or medical detail, is permanently deleted as soon as the application has been assessed. Recording a decision destroys the assessment email outright, and any application not assessed is deleted in any event within one calendar month of being received. Deletion is permanent and cannot be undone.
• Application records held in the tracker, which contain no health or medical information, are kept for a maximum of twelve months from the date of last contact, in line with our Privacy Policy.
• Donor records are kept for seven years from the date of the last donation, in line with financial record-keeping requirements.
• General correspondence is kept for three years unless it relates to a matter requiring a longer period.

When a retention period ends, the relevant emails and any associated records are permanently deleted, not simply archived or moved.

Account Security

All Google Workspace accounts used to receive application or beneficiary data must have two-factor authentication enabled. This is a precondition for any volunteer being given access to these accounts.

Volunteer Confidentiality

Every volunteer handling personal data is expected to keep it confidential, both during and after their time volunteering with us. This includes information learned informally in the course of processing an application, not only what is written down.

If Something Goes Wrong

If a volunteer becomes aware of a data breach, a misdirected email, unauthorised access, or any other incident involving personal data, they must report it to Chris Lewis immediately. We will assess whether the breach needs to be reported to the Information Commissioner’s Office and, where required, will do so within 72 hours of becoming aware of it.

Review

This policy is reviewed annually, or sooner if our systems, processes, or legal obligations change.