As from 25 May 2018, under the General Data Protection Regulation, WWT (Wildfowl and Wetlands Trust) will rely on legitimate interest as per GDPR Article 6(1)(f) for some of its processing of personal data.
This permits the organisation to contact its members and supporters by post. Individuals are free to opt out of postal contact at any time.
Clear information about how individuals can opt out of contact or change their contact preferences is prominent on WWT’s website and printed materials with a data capture element.
An up to date privacy statement is available on WWT’s website www.wwt.org.uk.
WWT is a high-profile conservation organisation with a widely known membership product. We believe that the individuals whose information we hold on our database are fully aware of the nature of their relationship with us and the mutually beneficial reasons for remaining in contact.
Our detailed rationale for claiming legitimate interest is as follows:
The purposes for which we will use individuals’ personal information
- Sending membership communications, particularly Waterlife, the membership magazine, and renewal letters
- Sending fundraising appeals and updates to WWT donors who wish to support our conservation work
- Providing occasional information to visitors to our centres if they have provided their personal information e.g. as a result of buying a ticket for a paid-for event
Without these contact opportunities, WWT’s income generation potential is put at risk, endangering the long term survival of the organisation:
- Membership benefits are heavily weighted towards post: Membership renewals containing membership cards have to be sent by post; Waterlife magazine is posted 4 times a year
- The income generation opportunity is greatly increased among the current donor base if fundraising appeals are sent by post – direct mail appeals generate higher response rates
- The visitor experience is enhanced, and paid for visiting is promoted, if previous visitors who are happy to be contacted can be told about events and new attractions at WWT’s centres by both post and e-mail.
Articles 47 and 48 of the GDPR say that direct marketing activity is a legitimate interest; in particular, in the context of a relevant and appropriate relationship between the organisation (WWT) and the individual (the recipient), there would be a reasonable expectation that postal details are used for these purposes.
The legitimate interests of third parties
In order to deliver the direct marketing described above, WWT may provide individuals’ personal contact details to mailing and fulfilment houses, supplied from our own secure database.
We may also occasionally brief suppliers to carry out analysis, sometimes using personal data and at other times anonymised data, to help determine market trends and opportunities around membership and visiting. This insight enables us to provide the best possible experience for our visitors, members and supporters.
We make every effort to ensure the data we send to suppliers is secure at every point of transfer and during all the stages of data processing. Our reputable suppliers are required to provide their security protocols on demand. Personal data will always be held on servers within the EU and is securely deleted by our suppliers as soon as each mailing activity has been completed.
Necessity for the data processing of personal information
WWT’s membership programme is highly dependent on mail for delivering information about WWT’s work, its centres and – most importantly - membership cards to new and renewing members. Membership cards are required if members are to benefit from unlimited entry to WWT’s centres as they must be shown at the admission desk on arrival.
Waterlife magazine, another membership-only benefit, is currently posted to the membership base.
Without post-based welcome and renewal packs for members, WWT’s ability to continue to generate most of its income from membership to fund its conservation work would be compromised.
If members’ ability to visit the centres were to be hindered, the opportunity to earn incremental income from visiting would in turn be reduced.
Direct postal mail based fundraising appeals sent by post to existing supporters are also crucial to the charity’s income generation activities .
Rights and freedoms of the individual
WWT will do the following with the personal information it holds. None of these activities infringe the rights or freedoms of individuals under the terms of the GDPR:
- Securely transfer data to third party suppliers for the purposes of producing personalised direct mail materials (see above)
- Send both generic and personalised content by post - and, where the individual has given explicit permission, by e-mail
- Retain the individuals’ data for as long as the active relationship lasts with WWT, for marketing, business analysis and administration purposes
- Retain the individuals’ data for a period after the relationship has ceased, for the same purposes (i.e., membership has lapsed; no donations have been received). This will be for a maximum of 7 years after the last recorded activity by the individual. These timings are consistent with WWT’s statutory responsibilities to retain data for Gift Aid and other tax purposes.
- We will only record and store personal data with the knowledge of the individual
We will not send promotional or marketing information to children
- Junior members (aged 4-16) join with the permission of an adult who usually pays for their membership
- They receive the membership benefits attached to the Junior category, but
- We may use external data sources to enhance the personal data we store as permitted by Article 22 of the GDPR
- We will not use marketing data obtained from a third party without proof of third party consent for mailing having been obtained by the data owner
Nature of personal information held by WWT and processed in reliance on legitimate interests
- Title, full name, address, postcode
For Family memberships and some Adoption products only:
- Adults’ and children’s dates of birth
- Transactional data relating to the dates and amounts paid for memberships and donations
Bank details are held securely on our Finance systems only for processing Direct Debits, for example for payments relating to ongoing memberships, regular gifts and animal adoption products. These payments are protected by the Direct Debit Guarantee.
- Card details are not retained for one-off purchases e.g. memberships, events tickets and donations.
The individuals whose details WWT holds fall into these primary categories. They may be active or lapsed. WWT claims legitimate interest as outlined above for the purposes of communications, via post, to reactivate lapsed members or supporters for income generation purposes.
Former employees’ and former volunteers’ data will be dealt with according to the requirements of GDPR:
- Non-transactional supporters
Business to business and corporate partnership relationships
WWT is claiming legitimate interest to keep in touch, using their business addresses, with named individual business and corporate partnership contacts with whom the organisation already had a relationship prior to the introduction of the General Data Protection Regulation on 25 May 2018.
This legitimate interest does not extend to contacting these individuals using their personal contact details unless, as private individuals, they fall into one of the categories listed above in ‘Primary relationships’, in which case WWT claims legitimate interest for contact by post and will only make e-mail or telephone contact if the appropriate consents are in place.
For new relationships in these categories created with named individuals after 25 May 2018, consent for future contact will be sought and managed in full compliance with the General Data Protection Regulation.
Please direct any queries regarding this statement to Jenelle Murray-King, Supporter Service Manager.
Phone: 01453 891198