Privacy Policy

1. Who are we?

Devon Wildlife Trust (DWT) is a volunteer- and Member-led organisation that has been established for over fifty years. We are the only organisation solely dedicated to protecting all of Devon’s wildlife – at sea and on land – for the future. We strive to ensure that our natural environment is rich in wildlife, for everyone, and valued by all, and provide opportunities for Members and non-Members alike to discover, enjoy and protect Devon’s amazing natural environment and share their love and passion for wildlife with others.

DWT – our staff, volunteers, Members, supporters and partners – are a welcoming community of people who share a love of Devon’s wildlife and who work together to protect it.

As an organisation, we seek to build lifelong relationships with our volunteers, Members, supporters and other stakeholders. This means nurturing loyalty through our shared values and beliefs, strong and sustained communications and excellent levels of customer care grounded in the principles of responsiveness, accountability, transparency and mutual respect.

2. Our Commitment to your Privacy

DWT and its trading subsidiaries holds and processes data – including personal data and sensitive data – so that we can deliver our charitable mission as defined by our charitable Objects and our Manifesto, adhere to our values and beliefs, and so that we can grow and sustain our valuable community and vital networks.

We collect, hold and process personal data to build and maintain relationships; to secure the resources we need to deliver our mission; to provide a strong evidence base for our work; to keep our staff, volunteers, supporter and service users safe and to meet our legal and contractual obligations.

We are committed to gathering and processing personal data with full regard for the General Data Protection Regulations (GDPR), the Privacy and Electronic Communications Regulations (PECR) and to the principles of personal choice and control, transparency, fairness and security. We always collect and process data on lawful grounds to meet the genuine needs of our organisation, but we do so with the highest regard for an individual’s rights and freedoms.

We only share information when it is absolutely necessary to meet our organisational needs and legal obligations and only with strict controls and data sharing and processing agreements in place. We will never sell personal data to third parties.

We are committed to keeping the personal details of our members and supporters safe. This Notice explains how and why we use your personal data, to ensure that you remain informed and in control of your information.
For more information about your rights with regards to personal data, please see the Information Commissioner’s Office.

If you have any questions about this document, would like to find out more about the data we hold on you and/or would like to see our full Data Protection and Privacy Policies, please do get in touch:


Director Resources and Marketing
Telephone: 01392 279244
Email: contactus@devonwildlifetrust.org
Address: Devon Wildlife Trust
Cricklepit Mill
Commercial Road
Exeter
Devon
EX2 4AB

Our office hours are Monday – Friday, 9am – 5pm.

3. Key terms in this document

Any references to Devon Wildlife Trust, DWT, the Trust, or to ‘we’ or ‘us’ in this and Related Policies refer to DWT the charity - a registered charity in England and Wales (registered charity number 213224) – and to our wholly owned trading subsidiaries: Devon Wildlife Enterprises (Environmental Consultancy – company No. 2533451); Devon Wildlife Services (Seaton Jurassic – company No. 9466941); Warren Crocus Limited (Dawlish Warren – company No. 719357).

We use the following key definitions to describe people mentioned in this document. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk)

• ‘Data subject’: this is you, one of our valued members and supporters. As the data subject, we respect your right to control your data.
• ‘Data controller’: this is us, the Devon Wildlife Trust. With your permission, we determine why and how your personal data is used (as outlined in this document).
• ‘Data processor’: this is a person, or organisation, who processes your data on our behalf, with your permission. For example, this might be a mailing house who sends your membership magazine to you on our behalf (due to the size of our organisation, it’s more cost-effective to outsource ad-hoc and large-scale tasks like this).

When we work with other organisations or individuals in this way, we always set up a written contract with them to protect your data. The third parties we work with at no point ‘own’ your data, so you will never hear from them independently and they will always delete your data from their systems when they have completed the task in hand. We always send your data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.

4. Why do we collect your personal data?

We use your personal data to keep in touch with you.

We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The ICO refers to this as a ‘lawful basis’. Further information about why we collect your personal data is outlined below.

a) To administer your Devon Wildlife Trust membership

We collect your personal data to administer your membership, which may involve:
• Sending you your membership welcome pack when you first join us
• Processing your Direct Debit subscription payments, if you have set this donation process up with us
• Sending you your membership renewal letter
• Getting in touch should there ever be any issues processing your subscription payment
• Keeping your personal details up to date

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.

b) To send you items purchased from us

We collect your personal data to send you:
• items you have purchased
• information about events you have booked onto

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.

c) To administer and acknowledge gifts and donations you have made to us

We collect your personal data to:
• process any donation payments
• acknowledge receipt of any donations

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’

d) To deliver services that you have asked for
We collect personal data to:
• provide funded or charged services – such as landowner advice, environmental consultancy services, educational activity etc.
• process any payments related to these services
• process any monitoring information related to these services
• report to funders as required by funding contracts

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’. Where it is a contractual requirement to share your personal data with third parties – such as our funders or any regulatory bodies – we will always make this clear when we first collect information from you.


e) To send you information about our work and ask for your opinion

We also collect your personal data so that we can send you information about our work that we feel will be of interest to you. This includes your membership magazine, fundraising appeals, events, campaigning opportunities, volunteering opportunities, job and trainee opportunities at the Trust, membership, our projects, activities going on in your area, services, products, newsletter requests, feedback, competitions and other activities, as well as information about other carefully selected organisations that we work in partnership with (such as Vine House Farm who supply high quality bird seed). From time to time, we may also use your personal data to ask for your opinion about our work.

This information is in addition to that outlined in sections a), b), c) and d) and is defined as ‘direct marketing’ by the ICO.

i) Joint and family membership

If you are a ‘joint’ or a ‘family’ member of our Wildlife Trust, we will address communications to all those listed on your membership. If you wish to update this at any point, please let us know.

ii) Gift membership

If your Wildlife Trust membership was purchased as a gift, we will use the address provided by the purchaser to send you information about our work in the post. This will include a ‘renewal letter’, which we will send you when your membership is due to expire, to see if you would like to continue supporting our charity.

iii) When your membership has ended

Unless we hear from you directly, we will continue to send you information about our work for up to 12 months after your membership has ended. This is just in case your support was cancelled accidentally, by for example changing your bank account details, and you wish to update your details with us.

Your personal data also helps us to get to know you better and to develop a ‘profile’ of you on our secure supporter database. This ‘profile’ enables us to send you the information listed above in a timely and relevant way, to suit you. For example, keeping track of the donations you make to our organisation helps us to send you information about fundraising appeals that we feel you would like to hear about. Likewise, keeping a record of your wildlife interests that you may tell us about in one of our Membership Surveys, helps us to send you relevant project updates.

As defined by the ICO, we use two different lawful bases for processing your data for ‘direct marketing’ purposes:

i) Legitimate interest
This is where we have identified a genuine and legitimate reason for contacting you, which crucially does not override your rights or interests.

We use legitimate interest to send you the information listed above by post or telephone (if you are not registered with the Telephone Preference Service, and you have given us your telephone number).

ii) Opt-in consent
This is where you have given us express permission to contact you by particular communication channels.

We use opt-in consent to send you the information listed above by email, text message (SMS) or telephone (if you are registered with the Telephone Preference Service)

We respect your right to update the way we get in touch with you about our work at any time.

f) To enable you to volunteer with us

If you are a Devon Wildlife Trust volunteer, we collect your personal data so that we can keep in touch with you about, for example:
• the current work of DWT
• changes to planned volunteer work programmes that you may be taking part in
• the positive impact you have on our work, by sending you our volunteer newsletter or similar
• events useful for volunteers e.g. training opportunities, ‘thank you’ events, informative events.
• new volunteer opportunities
• thank you letters and information relating to our volunteer awards
• Christmas cards, get well cards, etc
• feedback about your volunteering for example volunteer satisfaction surveys and exit reviews
• your feedback about the work of DWT.

As defined by the ICO, the lawful basis for processing your data for these purposes is ‘contractual’ (where administering your volunteer record) and ‘legitimate interest’ (when sending you information about our work).

If you are participating in a volunteering programme or activity that is supported by an external funder, we sometimes need to share your data with them so that they can check that their funds are being spent properly. The lawful basis for processing your data in this case would be ‘contractual’ and we will always make this clear when we first collect information from you.


5. What kind of personal data do we collect? How do we collect it?

a) Basic information
We will usually collect basic information about you, including your name, postal address, telephone number, email address and your bank details if you are supporting us financially.

Most of the time, we collect this data from you directly. Sometimes this is in person; other times, it is over the telephone, in writing or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (only where you have given permission for such information to be shared).

b) Getting to know you better
We also collect information about you that helps us to get to know you better. This may include:
• information about your wildlife interests, which you tell us through our Membership or similar Surveys
• records of donations you’ve made towards fundraising appeals
• your preferences of how you would like us to contact you
• ways you’ve helped us through volunteering your time
• records of events you’ve attended, or campaigns or activities that you’ve been involved in.

Sometimes we will collect other information about you such as your date of birth and gender. When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission.

Once again, most of the time we collect this data from you directly. Occasionally we also obtain data from external sources. For example, we may check against Royal Mail’s National Change of Address database to ensure that the address we have listed for you is up to date. We know moving to a new house can be a busy time and appreciate that you don’t always have the chance to send us your new address. By undertaking this exercise, we can update your record without you needing to get in touch.

We may also collect demographic and consumption data generated through geo-demographic tools (such as CACI Acorn), as well as information related to your wealth. This may include information from public registers and other publicly available sources such as Companies House, newspapers and magazines.

If you do not wish your data to be collected in any of these ways, or have questions about them, please contact us.

Other ways in which we collect personal data to get to know you better include:

i) Our website
Our website uses ‘cookies’ to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:
• Make our website work as you'd expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you

For more information on our Cookies Policy, please click here.


c) Sensitive personal data
We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and members. However, there are some situations where this will occur. For example, if we are delivering a funded project that is specifically aimed at benefitting people’s health or which targets particular groups of individuals (such as people from diverse backgrounds or with specific ethnicities).

When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission. In these situations, we collect the data from you directly. Generally, we anonymise sensitive personal data wherever possible.

If you are a volunteer then we may collect extra information about you, for example:
• references
• criminal records checks
• details of emergency contacts
• medical conditions

We may also collect sensitive personal data if you have an accident on one of our reserves. This information will be retained for legal reasons, for safeguarding purposes and to protect us (including in the event of an insurance or legal claim). If this does occur, we’ll take extra care to ensure your privacy rights are protected.

d) Children and young people
In line with data protection law, we will not collect, store or process your personal details if you are under 13 years of age; unless we have the express permission from your parent or guardian to do so.

If we have the permission of your parent or guardian, and you are a family member or member of one of our Wildlife Watch groups, we will capture your date of birth at the point of joining. This is so that we can send you information that we feel is suitable to your age.


6. How do we store your data?

a) Security
All of the personal data we process is processed by our staff in the UK. However, for the purposes of IT hosting and maintenance your information may be situated outside of the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.

We use Campaign Monitor for e-mail marketing. A copy of their policy regarding data security in terms of operational security, physical security and application security can be found here.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a clear Data Protection Policy and associated guidance which personnel are required to follow when handling personal data.

b) Payment security
All electronic Devon Wildlife Trust forms that request financial data will use the Secure Sockets Layer (TLS1.2) protocol to encrypt the data between your browser and our servers.

If you use a credit card to donate, purchase a membership or purchase something online we use Worldpay. Please refer to sections 17, 18, and 19 in the following link for their data processing terms and conditions: https://www.worldpay.com/sites/default/files/171120-SME-Terms-2017.pdf

Devon Wildlife Trust complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council and will never store card details.

Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.

c) CCTV
Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and Devon Wildlife Trust. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review CCTV will be recorded over.

Devon Wildlife Trust complies with the Information Commissioner’s Office CCTV Code of Practice, and we put up notices, so you know when CCTV is in use.

d) Data retention policy
We will only use and store information for as long as it required for the purposes it was collected for. We continually review what information we hold and delete what is no longer required.

For further information, please see our Data Retention Information. (PDF file at the foot of this page.)

7. Data sharing

We sometimes need to share the personal information we process. Where this is necessary we, and any third parties we share with, are required to comply with all aspects of the General Data Protection Regulations (GDPR). Sharing is always subject to a lawful basis for processing. We will never sell personal details to third parties.

Organisations that we share data with include:

• Organisations who process data on our behalf – for example, membership recruitment providers, mail and print services, providers of other goods and services on our behalf (such as merchandise), consultants who help us to analyse and improve our performance;
• Our partners on partnership projects – for example, for the purposes of project monitoring and delivery;
• Our trading subsidiaries – to ensure that we are adhering to legal obligations and high levels of customer care throughout the charitable ‘group’ and to promote the work of the charity through subsidiary networks and vice versa;
• Our funders – to demonstrate compliance to funding and service provision contracts;
• Legal/compliance bodies where required – insurers, auditors, pension provider, HMRC, Fundraising Regulator, ICO;
• Statutory bodies or agencies – for example, to respond to legal issues and risks;
• Healthcare, social and welfare organisations – to manage and safeguard the wellbeing of our staff, volunteers and beneficiaries;
• Educators and examining bodies – for example, where we are supporting trainees;
• Current, past and prospective employers – for example, to provide references;
• Family, associates or representatives of the person whose personal data we are processing – for example, where we are administering a legacy;
• Survey or research organisations – for example, to verify species records.

When we work with other organisations or individuals in this way, we must always set up a written contract with them to protect personal data – Data Processing and/or Data Sharing Agreements. The third parties we work with at no point ‘own’ an individual’s data, must never contact the individual outside of their agreement with us and must always delete this data from their systems when they have completed the task in hand. We must always send data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.
  

8. Your rights

We respect your right to control your data. Your rights include:

a) The right to be informed
This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this policy, please contact us.

b) The right of access
If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request, we will respond within one month. To make a Subject Access Request, please contact our Director of Resources and Marketing.

c) The right to rectification
If we have captured information about you that is inaccurate or incomplete, we will update it.

d) The right to erase
You can ask us to remove or randomise your personal details from our records.

e) The right to restrict processing
You can ask us to stop using your personal data.

f) The right to data portability
You can ask to obtain your personal data from us for your own purposes.

g) The right to object
You can ask to be excluded from marketing activity.

h) Rights in relation to automated decision making and profiling
We respect your right not to be subject to a decision that is based on automated processing.

For more information on your individual rights, please see the Information Commissioner’s Office.


9. Making a complaint

The Devon Wildlife Trust want to exceed your expectations in everything we do. However, we know that there may be times when we do not meet our own high standards. When this happens, we want to hear about it, to deal with the situation as quickly as possible and put measures in place to stop it happening again.

We take complaints very seriously and we treat them as an opportunity to improve and strengthen our relationship with our supporters and volunteers. This is why we are always very grateful to hear from people who are willing to take the time to help us improve.

Our policy is:
• To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.
• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
• To make sure everyone in our organisation knows what to do if a complaint is received.
• To make sure all complaints are investigated fairly and in a timely way.
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
• To learn from complaints and feedback to help us to improve what we do.

Confidentiality
All complaint information will be handled sensitively, in line with relevant data protection requirements.

You can find our Complaints Policy – ‘How to Make a Complaint’ - here.


Responsibility
Overall responsibility for this notice and the implementation of our Data Protection Policy lies with the Director of Resources and Marketing.


Information Commissioner’s Office
For further assistance with complaints regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Telephone: 0303 123 1113
Email: casework@ico.org.uk


10. Leaving our website

We are not responsible for the privacy practices or the content of any other websites linked to our website. If you have followed a link from this website to another website you may be supplying information to a third party.


11. Get in touch

Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:

Director of Resources and Marketing
Telephone: 01392 279244
Email: contactus@devonwildlifetrust.org

Address: Devon Wildlife Trust, Cricklepit Mill, Commercial Road, Exeter, Devon, EX2 4AB


Our office hours are Monday – Friday, 9am – 5pm.
 

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