Privacy Policy and T&C

1. Who are we?

The Cornwall Wildlife Trust is a registered charity established in 1962 to safeguard Cornwall’s habitats and associated wildlife in the long term. It fulfils a unique role in that it is concerned solely with Cornwall and deals with all aspects of conserving the Duchy’s wildlife and habitats. We have achieved a great deal over the years and have an ever-increasing adult membership. Our junior club, Wild Watch, is thriving - as are our special interest groups and local groups. With 47 similar organisations covering other geographical areas within the UK, the Cornwall Wildlife Trust is an independent member of The Wildlife Trusts. The Wildlife Trusts are a movement of more than 800,000 members, 40,000 volunteers, 2,000 staff and 600 trustees, from a wide range of backgrounds and all walks of life. In Cornwall we have around 1200 volunteers, 80 staff and 20 Trustees. We have over 17000 members who share our passion for Cornwall’s Wildlife and Wild places.

For more than half a century, we have been saving, protecting and standing up for wildlife and wild places, increasing people’s awareness and understanding of the natural world, and deepening people’s relationship with it.

The roots of our Trust are local. Impetus for the formation of an organisation to combat this devastation of the Cornish landscape and loss of wildlife came from the Camborne and Redruth Natural History Society, itself formed in 1956. An advertisement placed in the local press brought together almost 100 like-minded people at the County Museum in Truro on 23rd March 1962. The Cornwall Naturalists’ Trust was formed. This later changed its name to the Cornwall Trust for Nature Conservation and joined the Wildlife Trusts.

We work on land and sea, caring for our living landscapes and living seas. We look after more than 57 nature reserves, covering 2,345 hectares, representing some prime examples of Cornwall’s unique range of habitats. We also have a leading presence in marine conservation work

We work productively with many businesses, with other environmental organisations, community groups, local authorities, national governments, schools, universities, lotteries, charitable trusts and foundations, fishermen, divers, farmers, landowners, and politicians from across the political spectrum, and more. We believe we achieve more by talking and working with people. Most importantly, we engage people of all ages and local communities with their environment – inspiring people to cherish and care for our Wild Cornwall.
 

2. Our commitment to your privacy

We are committed to keeping the personal details of our members and supporters safe. This policy explains how and why we use your personal data, to ensure that you remain informed and in control of your information.

CWT 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 charitable Objects in our Memorandum and Articles of Association, 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.


3. Key Terms in this Document

Any references to Cornwall Wildlife Trust, the Trust, or to ‘we’ or ‘us’ refer to:
• Cornwall Wildlife Trust. We are a registered charity in England and Wales, and our registered charity number is 214929
• Cornwall Environmental Consultants Limited, our charitable trading company; (registered company number 02634834). The company is a wholly owned subsidiary of Cornwall Wildlife Trust, and all of its profits are donated to Cornwall Wildlife Trust.

We use three key definitions to describe people mentioned in this policy. 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 loyal members and supporters. As the data subject, we respect your right to control your data.
‘Data controller’: this is us, the Cornwall Wildlife Trust. With your permission, we determine why and how your personal data is used (as outlined in this policy).
‘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.

We will never sell your personal data.

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

Head of Finance and Administration
Telephone: 01872 273939
Email: dataprotectionteam@cornwallwildlifetrust.org.uk
Five Acres, Allet, Truro, TR4 9DJ

Our office hours are Monday – Friday, 8.30am – 4.30pm.


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 Cornwall 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
• Processing credit/debit card, cheques or standing orders if this is your preferred option of payment
• Sending you your membership renewal letter
• Getting in touch should there ever be any issues processing your subscription payment

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

b) To send you items purchased from our online shop, including event bookings

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

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

c) 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 welcome pack, membership magazine, fundraising appeals, events, campaigning opportunities, products, newsletter requests, feedback, competitions and other activities, as well as information about other carefully selected organisations that we work in partnership. Our magazine may carry a small number of paid advertisements that defray our costs. From time to time, we may also use your personal data to ask for your opinion about our work and our services.

This information is in addition to that outlined in sections a) and b) 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 3 months after your membership has ended. This is just in case your support was cancelled accidentally, 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.

d) To enable you to volunteer with us

If you are a Cornwall Wildlife Trust volunteer, we collect your personal data so that we can keep in touch with you about, for example:
• 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
• dedicated volunteer thank-you events

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).


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 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.

From time to time we may analyse your personal information to create a profile of your interests and preferences, so that we can contact you with information that is relevant to you and thank you in the most appropriate manner. We may make use of additional external information about you, including geo-demographic information and measures of affluence to help us do this effectively. This helps us understand the background of the people who support us and helps us to make appropriate requests for gifts from supporters. Examples of this additional information may include :

Places you enjoy visiting in Cornwall – we could let you know about events in those places
Wildlife you enjoy seeing in Cornwall – we could inform you of projects relating to those species where we may be looking for volunteer help or more significant contributions to that area of work
You favourite nature reserves in Cornwall – we could keep you up to date with work on that nature reserve or inform you of an area of need which you may be able to help with.
Your aspirations for wildlife in Cornwall – we can inform you of relevant consultations that you might wish to take part in, or invite you along to a meeting or an event to see how you could help make those aspirations come to fruition.
Events we hold that you attend and where you may have met us- we can inform you of similar forthcoming events which may be of interest to you and where you have the opportunity to catch up with us again.

 

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 see annex 1 below.


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.

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.

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.

We do not have individual Wildlife Watch membership if you join as part of a ‘family’ membership the form will be completed by an appropriate consenting adult and all communications will be addressed to the whole family. This can be updated at any time by contacting the membership team.

If we have the permission of your parent or guardian, and you are a Wildlife Watch member wishing to attend an event, we will capture your name, address and date of birth at the point of event registration. This is so that we can send you your award certificates, and tailor events which are age appropriate.

If we have collected personal data about young people under the age of 18 as part of registering for a project we are undertaking, we obtain consent of the parent or guardian. We use the data to offer events/activities and opportunities that are age appropriate.

 

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 anywhere within the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.

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 set of detailed data protection procedures which personnel are required to follow when handling personal data.

b) Payment security
All electronic Cornwall Wildlife Trust forms that request financial data will use the Secure Sockets Layer (SSL) 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 will pass your credit card details securely to our payment provider (Cardnet – a subsidiary of Lloyds bank). Other payment methods (e.g. Worldpay) are handled in a similar manner.

Cornwall 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) 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.

 

7. 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.

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.


8. Making a complaint

Cornwall Wildlife Trust wants to exceed your expectation 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, in order 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 develop our approach. 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.

Responsibility
Overall responsibility for this policy and its implementation lies with Carolyn Cadman, Chief Executive.

For further information on how to make a complaint, please contact:

Head of Finance and Administration
Telephone: 01872 273939
Email: dataprotectionteam@cornwallwildlifetrust.org.uk
Five Acres, Allet, Truro, TR4 9DJ

Our office hours are Monday – Friday, 8.30 am – 4.30pm.


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


9. 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.


10. 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:

Head of Finance and Administration
Telephone: 01872 273939
Email: dataprotectionteam@cornwallwildlifetrust.org.uk
Five Acres, Allet, Truro, TR4 9DJ

Our office hours are Monday – Friday, 8.30 am – 4.30pm.


Annex 1: Our use of cookies

Our website uses cookies, as almost all websites do, 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

We do NOT use cookies to:
• Collect any personally identifiable information (without your express permission)
• Collect any sensitive information (without your express permission)
• Pass personally identifiable data to third parties
• Pay sales commissions
• You can learn more about all the cookies we use below

There are two types of cookie you may encounter when using this site:
• First party cookies: these are our own cookies, controlled by us and used to provide information about usage of our site.
• Third party cookies: these are cookies found in other companies’ internet tools which we are using to enhance our site.

First party cookies

This site uses cookies in several places – we’ve listed each of them below with more details about why we use them and how long they will last.

Cookies set by this website

Name Purpose Typical content Expires
SESSxxxID Authentication session to prevent having to login multiple times in one browser session. This is only set if you authenticate via the site. This may happen if you purchase items from the shop or make use of our commenting  A unique id that ties the current session to a database settings table One week
cookieconsent_dismissed This cookie collects information about whether or not the user has agreed to cookies. Yes/No 70 years 6 months

Third party cookies

We use a number of suppliers who may also set cookies on their websites’ on its behalf. This site does not control the dissemination of these cookies. You should check the third party websites for more information about these.

Provider Name  Purpose More info
Google Analytics  _ga
_gid
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Google Privacy policy

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout


We update this policy periodically.
Last updated: 22 May 2018