I also note from that website:
The commission can take trustees to court to recover funds lost to their charity as a result of a breach of trust.
You can also be liable to another person if your charity isn’t a charitable company or CIO. If you enter into contracts to provide services or employ staff, you could be personally liable for any debts your charity can’t pay from its money or assets.
This means your charity’s creditors can sue the trustees personally to recover money they’re owed, even if there hasn’t been a breach of trust. Trustees who have acted properly can be reimbursed from charity funds, providing the charity can afford to repay them.
Oh. If I'm reading that right...
The ICO could slap a massive fine on Mermaids... And the charity could potentially sue a trustee for their lack of governance to recover the money, if they could demonstrate they acted unlawfully or negligently.
Also trustees don't have to be called trustees specifically:
They may be called trustees, the board, the management committee, governors, directors or something else.
Oh.
Who is Mermaids data controller? Are they named?