Wildfowl and Wetlands Trust (WWT) is committed to protecting its members’ and supporters’ personal information.
WWT Limited is a charity (1030884 in England and Wales, SCO39410 in Scotland) and a company limited by guarantee (2882729 England). VAT number 618368028.
The registered address is Wildfowl & Wetlands Trust, Slimbridge, Gloucestershire GL2 7BT
Why WWT holds and processes supporters’ personal data
- To administer membership and membership renewals
- To process donations
- To claim Gift Aid on donations
- To confirm receipt of donations, to thank donors and to provide details of how donations may be or have been used
- To enable WWT to maintain a record of supporters’ relationships with the organisation
- For analysis leading to the production of management information relating to income generation and supporter development
- In relation to correspondence entered into with WWT by any offline or online channel
- To manage visiting and other services at WWT centres
- To send WWT’s members and supporters information about the organisation’s work, fundraising activities and appeals where the organisation has obtained consent or is otherwise allowed to, e.g. by claiming legitimate interest based on existing relationships. Please see our Legitimate Interest Statement for more information. The lawful basis claimed for processing members’ personal data is the contract between WWT and its members which requires WWT to provide the benefits advertised for membership and the information that enables them to continue their membership, for example their renewal advice and membership card. Members who opt out of all communications will not receive this information.
- To keep WWT members’ and supporters’ data up to date
- To implement any instructions WWT receives with regard to withdrawing consent to send information
Individuals can update or withdraw their consent at any time, for individual channels of communication, or for all channels, by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing email@example.com
All WWT’s supporter e-mails contain an Unsubscribe link.
In the event that WWT needs to contact or enter into correspondence with individual supporters regarding administrative issues that do not fall into the GDPR definition of ‘direct marketing’, the use of an e-mail address or telephone number provided by the individual is permissible for the specific purpose of resolving the issue.
The personal information WWT captures and stores
WWT captures and stores personal information as follows:
|Members||Donors||Visitors||Event organisers||Event attendees (WWT ticket purchasers)||E-mail sign ups (via WWT website)|
|Title / full name / full postal address||Yes||Yes||If provided, only used for direct marketing, claiming legitimate interest for post||If provided, only used for direct marketing, claiming legitimate interest for post||If provided, only used for direct marketing,claiming legitimate interest for post||If provided, only used for direct marketing, claiming legitimate interest for post|
|Phone number (landline and/or mobile)||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact|
|E-mail address||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||If provided, only used for direct marketing with a clear opt-in for future contact||Yes|
|Centre services provided to the public e.g. catering for events, equipment hire||Services provided to WWT by the public e.g. media release forms, location usage permission|
|Notes||Only processed for the provision of the service by WWT and only stored for the length of time required to provide and administer the service||Only processed for the duration of WWT’s use of the permission and only stored for the length of time required for WWT to use the permission|
|Title/full name/full postal address||Yes – subject to the conditions noted above||Yes – subject to the conditions noted above|
|Phone number (landline and/or mobile)||Yes – subject to the conditions noted above||Yes – subject to the conditions noted above|
|E-mail address||Yes – subject to the conditions noted above||Yes – subject to the conditions noted above|
The rights of individuals
Individuals have the right to request at any time the information WWT holds about them, as subject access requests. Such requests should be submitted by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing firstname.lastname@example.org
Depending on the nature of the request, WWT may seek a form of identification to verify the identity of the person making it. The information will be supplied within 30 calendar days of the request or the verification, whichever is the later.
If individuals believe the information WWT holds about them is incorrect or incomplete, they have the right to ask the organisation to correct it. WWT must respond within one month of the request being received. Requests can be made by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing email@example.com
Individuals have the right to ask WWT to stop processing their personal data. In this situation, WWT can continue to store the data to ensure the request can be respected in the future, but all processing must cease, unless there is a legal purpose. Requests can be made by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing firstname.lastname@example.org
Where they have given consent to WWT processing their data, individuals have the right to ask WWT to provide their personal details to another organisation via commonly used open format such as a CSV file. Requests can be made by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing email@example.com
Individuals have a right to have personal data erased and to prevent processing by WWT in the following circumstances :
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
- When the individual withdraws consent
- When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing
- The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
- The personal data has to be erased in order to comply with a legal obligation
- The personal data is processed in relation to the offer of services to a child.
WWT can refuse to comply with a request for erasure where the personal data is processed for legal reasons or other scenarios that may be in the public interest as specified by the ICO.
Erasure requests can be made by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing firstname.lastname@example.org
If individuals believe they have suffered damage because WWT has behaved in breach of Data Protection law, they are entitled to claim compensation.
This right can only be enforced through the courts.
The law allows WWT to defend a claim for compensation on the basis that the organisation took all reasonable care in the circumstances to avoid the breach, that is, by complying with Data Protection legislation when processing data.
Querying automated decisions
Individuals can ask WWT not to make automated decisions based on their personal data; expect to be advised if the organisation may use automated processes to make such decisions; and challenge the results of automated decisions they believe them to be inaccurate.
Questions and requests regarding automated decisions can be submitted by contacting WWT’s Supporter Services team on 01453 891198 or e-mailing email@example.com
WWT ensures that there are appropriate controls in place to protect personal details provided to the organisation.
Online forms are encrypted and the organisation’s ThankQ database is held on secure servers.
WWT’s database is only accessible by approved staff, contractors and suppliers and paper-based information is stored securely as required by GDPR.
Cookies are small text files stored on computer by the websites individuals visit. They are standard across all websites and help website owners deliver a better experience to their users.
Further details about managing cookies on all types of devices can be found here: www.aboutcookies.org.
The cookies WWT uses on its website are as follows:
PHPSESSID cookie - this cookie has a number functional purposes, which include making the shopping basket work and allowing donation amounts to be selected.
utma, utmb, utmx, utmz cookies - these cookies enable the function of Google Analytics, software that we use to help analyse anonymous visitor information such as pages visited, time spent on site, browser usage etc. The data can only be viewed by relevant staff at WWT.
atuvc cookie - this cookie gives intergration with social media accounts, using AddThis (www.addthis.com), for those users that choose to share content on their social media networks
Sharing information with others
WWT sometimes uses external companies to process personal data on WWT’s behalf, for example to produce direct marketing materials.
In these circumstances, with reference to GDPR, WWT is the Data Controller and these suppliers are Data Processors.
The security practices of supplier companies are checked before WWT appoints them and then on a regular basis. WWT puts contracts in place that set out the organisation’s expectations and requirements, especially regarding how suppliers store and process the personal data provided by WWT.
Third party marketing
WWT will only use personal information within the organisation for the purposes for which it was obtained.
WWT will not, under any circumstances, share personal data with any third party organisations for their use or sell it to them for their own marketing purposes, and individuals will not receive marketing communications from any other companies, charities or other organisations as a result of providing their details.
WWT will comply with legal requests where disclosure is required or permitted by law and a written request is received, for example, to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime.
Processing within the EU
WWT does not process data outside the EU.
The length of time personal information will be retained
WWT will hold personal information on its systems for as long as it is necessary for it to carry out the relevant activity requested by the individual and as in line with the consent given.
The personal information of individuals who are no longer engaged with WWT will be held for no longer than 7 financial years. This period meets WWT’s statutory obligation to retain information for Gift Aid and other tax purposes.
If an individual asks WWT to cease contact, a record of the request will be kept along with the individual’s personal details to enable WWT to comply with the request over time, but this period will be no longer than the 7 financial years stated above.
Business to business marketing and corporate relationships
WWT is claiming legitimate interest to keep in touch, using their business addresses, with named individual business to 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.
For new relationships in these categories created with named individuals after 25 May 2018, consent for future contact will be sought and managed in compliance with the General Data Protection Regulation.
WWT’s full legitimate interest statement is available here, or a hard copy can be provided on request.
- Write to: Jenelle Murray-King, Supporter Service Manager, Wildfowl & Wetlands Trust, Slimbridge,Gloucestershire GL2 7BT
- Email: firstname.lastname@example.org
- Phone: 01453 891198
The UK's data protection authority is the Information Commissioner's Office (ICO).
The ICO’s website is www.ico.org.uk
The organisation can be contacted at: https://ico.org.uk/global/contact-us/