Privacy Policy and T&Cs

Cornwall Wildlife Trust and Cornwall Environmental Consultants Limited Privacy Policy

Introduction and Important Information

Cornwall Wildlife Trust (CWT), Environmental Records Centre for Cornwall and the Isles of Scilly (ERCCIS) and Cornwall Environmental Consultants Limited (CEC) are committed to protecting and respecting your personal data and privacy.  When we use “We” or “us” in this policy we are referring to CWT and CEC unless otherwise specified.

This privacy policy relates to how we use and collect personal data from you when you use or purchase goods and services from us, attend an event, fundraise for us, make a donation, become a member of CWT, or access our websites. It also relates to our use of any personal information you provide to us by telephone (including SMS), in written correspondence (including letter and email) and in person.

Please note that:

• our services and our website are not intended for children under the age of 18 and we do not knowingly collect data relating to children; and
• our website and services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 1998 and 2018 (DPA) and The General Data Protection Regulation 2016 (GDPR) to the extent to which it is applied by UK GDPR as defined by the Data Protection Act 2018 together with other subsequent laws (“Data Protection Laws”).

This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page, so please check back regularly. Changes were recently made to section seven. 

Contents

1.  Who We Are and How to Contact Us

2.  How We Collect Data From You

3.  Special Category Data

4.  The Data We Collect About Website Users

5.  How We Use Information About Website Users and Individuals That We Interact With On Social Media

6.  The Data We Collect About Visitors and Those Who Attend Events With Us

7.  The Data We Collect About Donors, including Members

8.  The Data We Collect About Landowners

9.  Cornwall Environmental Consultants (CEC)

10.  ERCCIS

11.  Cornwall Good Seafood Guide

12.  Beach Rangers

13.  Partner Organisations and Tevi

14.  Third Parties and Sharing Information

15.  Where Your Data Is Held

16.  Applications to Work Or Volunteer For Us

17.  Data Retention

18.  Your Rights

19.  Cookie Policy

20.  Changes to this Privacy Policy

 

1. Who We Are And How To Contact Us

For the purpose of the Data Protection Laws, the data controller for this website and the websites operated by CWT as listed in section 4.1 below is Cornwall Wildlife Trust (CWT).  Where you provide personal data to Cornwall Environmental Consultants (CEC) the data controller for that data will be Cornwall Environmental Consultants Limited, which is a wholly owned trading subsidiary of Cornwall Wildlife Trust.

Cornwall Trust for Nature Conservation Ltd (otherwise known as Cornwall Wildlife Trust) is a registered charity (registered with the Charity Commission under registration number 214929) and is also a private company limited by guarantee registered in England and Wales under company number 00732511. Cornwall Environmental Consultants Limited is a wholly owned trading subsidiary of CWT which is registered in England and Wales with company number 02634834 and all of its profits are donated to CWT. The registered office address for both CWT and CEC is at Five Acres, Allet, Truro, Cornwall, TR4 9DJ. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below. 

FAO: Privacy Officer

Five Acres, Allet, Truro, Cornwall, TR4 9DJ

Email: dataprotection@cornwallwildlifetrust.org.uk

Telephone: 01872 273939 and ask to speak to the Privacy Officer. 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.     

 

2.0 How We Collect Data From You

 2.1       We use different methods to collect data from and about you including through:

2.1.1      Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. This includes personal data you provide when you:

(a)  contact us with an enquiry or provide feedback,

(b)  to become and act as a supporter,

(c)  become a customer with us by making a purchase via our online shop,

(d)  receive goods or services from us,

(e)  request marketing and other information to be sent to you,

(f)  attend an event we run or visit one of our nature reserves,

(g)  enter a promotion with us,

(h)  complete a survey

(i)  interact with us on one of our conservation projects,

(j)  notify us of a wildlife sighting,

(k)  register your business as a member;

(l) to act as a fundraiser; or

(m)  apply to work with us or volunteer for us.

2.1.2        Automated technologies or interactions. As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

2.1.3        Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

(a)  Technical Data from the following parties:

•  analytics providers;
• social media platforms
•  advertising networks; and
•  search information providers.

(b)  Contact, Financial and Transaction Data from providers of technical, or payment services, including Fundraising Platforms.

(c)  Identity and Contact Data from data brokers or aggregators, including marketing agencies, trade organisations or exhibition organisers.

(d)  Identity and Contact Data from publicly available sources such as Companies     House.

2.2            We have set out below under the relevant section, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been listed below.  Where we are relying on legitimate interests as the lawful basis for processing your personal data we make sure we consider and balance any potential impact on individuals (both positive and negative) and individuals rights before we process personal data for our legitimate interests. Where we rely on legitimate interest we will record our decision to do so. We rely on legitimate interest where processing of the data we hold does not, in our opinion, affect an individual’s rights or freedoms and is proportionate to our interests e.g., keeping you up to date with our latest services, obtaining your feedback on our work. 

2.3        Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of a service you have with us, but we will notify you if this is the case at the time.  

2.4            We never sell your data to third parties or allow third parties to contact you without your permission.

2.5        If we do wish to pass your data to a third party we will make this clear at the point of asking for this data, define the limits of this and not augment with any further data.

2.6            We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis. In order to ensure supporters have a better experience with us, we may process your personal data without your knowledge or consent where this is required or permitted by law.

2.7        We also collect, use, and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used solely in accordance with this policy.

 

3. Special Category Data

3.1         Special Category Data includes data, such as information relating to health, religious beliefs, race or political affiliations about you. We do not collect this data in the ordinary course of business but there are some circumstances where this may be collected.   We do not knowingly collect special category data about Website Users or Supporters 

3.2      When we do collect special category data about you we will be transparent as to why we are collecting such information and will only do so with your explicit consent. In these situations, we collect the data from you directly. For example, we may process special category data about you where it is needed to assess your volunteering capacity on health grounds and to provide appropriate workplace adjustments. We may collect information about your racial and ethnic origin and your sexual orientation but only where such data has been volunteered freely and only for the purpose of upholding our equal opportunities policies.

We may collect criminal record and offence data about you if we determine that it is appropriate to do so, for example volunteers working with children or vulnerable adults.

3.3      We may also collect special category data in the event that an accident occurs while you are visiting one of our nature reserves or attending an event with us. This information will be retained to comply with our legal obligations, for safeguarding purposes and to protect us in the event of an insurance or legal claim. If this does occur, we will take extra care to ensure your privacy rights are protected.

 

4. The Data We Collect About Website Users

4.1      This section of our privacy policy covers data we collect about users of our websites including when you make a purchase via our online shop (referred to collectively as “Website Users” in this privacy policy) and this includes users of the following websites owned or operated by CWT or CEC:

CWT Operated Websites:

• cornwall-wildlife-trust
• Welcome to ERCCIS | Online wildlife Recording for Kernow & Scilly
• The Environmental Records Centre for Cornwall and the Isles of Scilly
• Cornwall Good Seafood Guide
• Welcome to the Penwith Landscape Partnership website
• Cornwall Wildlife Trust | Cornwall Wildlife Trust

ERCCIS Operated Websites:

• Environmental Records Centre for Cornwall and the Isles of Scilly (ERCCIS)

CEC Operated Websites:

• Cornwall Environmental Consultants (CEC) | Cornwall | Southwest

4.2      We collect and process personal data about you when you use this website and any other websites operated by CWT/CEC. Typically, the personal data we collect and process will include identity, contact, transactional, financial, technical, profile, usage, marketing, communications such as:

4.2.1      Identity Data includes first name, last name, title, or other identifier (such as job title), marital status, date of birth, gender, and images.

4.2.2      Contact Data includes correspondence address, billing address, email addresses and telephone numbers.

4.2.3      Transaction Data includes details about goods and services you have purchased from us including products you have purchased from our online shop and events you have booked to attend via one of our websites.

4.2.4      Financial Data includes bank account and payment card details.

4.2.5      Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.

4.2.6      Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and responses to surveys about our services.

4.2.7      Usage Data includes information about how you use our websites, products, and services.

4.2.8      Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that we may collect and/or process other personal data about Website Users from time to time.

 

5. How We Use Information About Website Users And Individuals That We Interact With On Social Media

5.1      We use information held about Website Users to:

5.1.1      carry out our obligations arising from any contracts entered into between you and us via our websites for example to provide you with any goods or services you request,

5.1.2      carry out feedback and research on our work and our products/services, marketing, customer/supporter relationships and experiences,

5.1.3      to administer and protect our organisation and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); and

5.1.4        notify you about changes to our website services, privacy policy or terms and conditions.

5.1.5      where cookies have been accepted, we may use third party services to serve or retarget advertising.

5.1.6  Pixels. We use pixels to improve the relevance of our communications and track the effectiveness of our marketing efforts. Here’s how we use them:

• Email Pixels: These tiny images track when you open our emails, helping us measure engagement and improve content. If you'd prefer not to be tracked, you can adjust your email settings to prevent images from automatically loading.
• Website Pixels: Pixels on our website help us understand how you interact with our content. This data allows us to optimise our website and provide a better user experience.
• Meta (Facebook) Pixel: This pixel tracks actions on our website after you interact with our Facebook ads, helping us deliver relevant ads and measure campaign success. Facebook may link this data to your profile, in line with its own privacy policy. You can opt out of personalised ads through your Facebook Ad Settings or adjust your browser settings to block trackers.

5.2      Communication, engagement, and actions taken through external social media platforms that we are active on are subject to those platforms own terms and conditions and privacy policies. Depending on your personal privacy settings for social media such as Facebook or Twitter/X, you might give us permission to access information from those services, for example when you publicly tag us in an event photo or comment on our content, or to advertise to you. 

5.2.1   Social media platforms and tools. If you use social media, we may engage with you through platforms like:

• Facebook
• Google
• Twitter/X
• TikTok
• Instagram
• LinkedIn

We sometimes participate in Meta (Facebook and Instagram) Custom and Lookalike audience tools. This allows us to show you Cornwall Wildlife Trust ads that we believe you’ll find relevant. Similarly, we may prevent you from seeing ads that are not relevant to you, such as a membership ad if you are already an active member of Cornwall Wildlife Trust. To do this, we may share your email address with Meta to help them identify your social media profile. Your data is sent in an anonymised format and will be deleted by Meta if it doesn't correspond to a Meta account. We only share your data with these platforms if you’re already receiving marketing communications from us via email. The legal basis we apply to this activity is consent. Meta may also use your profile to find others with similar interests who may want to learn more about our work. These individuals may then see Cornwall Wildlife Trust ads.

If you’d like to stop seeing ads on these platforms based on this data, you can follow the instructions in their privacy policies:

• Facebook: https://www.facebook.com/help/568137493302217
• Instagram: https://help.instagram.com/155833707900388

If you’d like to opt out of having your data used in this way, please email us at supportercare@cornwallwildlifetrust.org.uk. However, this may not prevent you from seeing our ads entirely, as some ads are shown to broad audiences based on factors like age, location, or interests. It also won’t reduce the overall volume of ads in your social media feed.

5.3      We will only process personal data where we have identified a valid lawful basis to do so. For Website Users the lawful grounds of processing we are likely to rely on are as follows:

5.3.1      Processing is necessary for us to fulfill our contractual obligations under a contract entered into between you and us for example to provide you with goods or services you have ordered (including membership),

5.3.2      Processing is necessary to comply with a legal obligation,

5.3.3      Processing is necessary for our legitimate interests, for example to use data analytics to improve our website, products/services, marketing, relationships with customers/members/supporters and to administer and protect our business and our websites (including troubleshooting, system maintenance, data analysis) or via engagement on publicly available posts on social media,

5.3.4      Consent – We will seek to obtain your consent to process:

1. 1. 1. personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and
      2. any special category data.

5.4        Our websites use ‘cookies’, which are small files stored by your internet browser that help us provide you with a good experience while you are visiting our sites – further information can be found in the Cookie Policy for the relevant websites. Our cookie policy can be found below.

 

6. The Data We Collect About Visitors And Those Who Attend Events With Us

6.1      We collect and process personal data about you when you sign up to attend an event with us and attend the relevant event.  We will also collect personal data about you when you visit one of our nature reserves or book a wedding at Looe Island. Typically, the personal data we collect and process will include:

6.1.1     Identity Data includes first name, last name, title or other identifier, marital status, date of birth, gender and images, details of any children under the age of 18 who will be accompanying you on any visit.

6.1.2     Contact Data includes correspondence address, billing address, email addresses and telephone numbers.

6.1.3     Profile Data includes purchases made by you, your wildlife interests, nature reserve preferences, feedback, and responses to surveys about our services.

6.1.4     Transaction Data includes details about goods and services you have purchased from us including events you have booked to attend, details of your attendance and the details of any wedding package you may have booked.

6.1.5     Financial Data includes bank account and payment card details.

6.1.6     Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that we may collect and/or process other personal data about visitors from time to time.

6.2      In some circumstances we may also ask you for information related to your health (e.g., if you have any particular dietary requirements or mobility issues) but we will only process this information with your consent.

6.3      We will only process personal data for these purposes where we have identified a valid lawful basis to do so. These are as follows:

6.3.1      Processing is necessary for us to fulfil our contractual obligations under a contract entered into between you and us for example to provide you with access to one of our nature reserves or events or provide you with wedding services you have ordered,

6.3.2     Processing is necessary to comply with a legal obligation such as to comply with health and safety obligations and keep records of any incidents,

6.3.3      Processing is necessary for our legitimate interests, for example to enable us to effectively market our services to you and ensure optimum visitor experience,

6.3.4     Consent – We will seek to obtain your consent to process:

1. personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and any special category data.

 

7. The Data We Collect About Donors, including Members, And Related Parties

7.1       We collect and process personal data about you when you make a donation to us (regardless of method), including annual or regular donors subscribing as members. We may also collect personal data from solicitors, estate agents and others we may need to communicate with during the estate administration process who may provide us with personal data about you as well as providing us with their own contact details.

7.2       Typically, the personal data we collect about donors, including members, and related parties includes:

7.2.1    Identity Data includes first name, last name, title, or other identifier (such as a job title and date of birth) and signatures. We may capture other data, particularly for membership, including marital status, date of bird, gender, and any children included in a family membership.

7.2.2    Contact Data includes correspondence address, billing address, email addresses and telephone numbers.

7.2.3    Profile Data includes your preferences, interests, and responses to surveys about our work.

7.2.4    Financial Data includes bank account and payment card details.

7.2.5    Transaction Data includes details of the amounts donated, the nature of your donations, details of good and services you may have purchased from us, and events you have booked onto through our website.

7.2.6    Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

7.2.7    Usage data includes information about how you use our websites, products and services.

Please note that we may collect and/or process other personal data about donors, including members, and related parties from time to time.

7.3       We collect personal data to administer your donations and / or membership, which may involve:

7.3.1    Sending an acknowledgement of your donation and / or Gift Aid agreement.

7.3.2    Sending your membership welcome pack or renewal letter.

7.3.3    Processing donation and / or payment methods (Direct Debits, credit or debit car payments, CAF vouchers cheques, and / or standing orders) as applicable.

7.3.4    Getting in touch should there ever be any issues processing a regular payment (for example, for membership subscriptions).

7.3.5    Processing payments, fees and charges relating to any relevant events you may book to attend.

7.3.6    Making suggestions and recommendations about goods, services or content that may be of interest to you, and to inform you about fundraising campaigns we may be running.  

7.4       We will only process personal data for these purposes where we have identified a valid lawful basis to do so. These are as follows:

7.4.1    Processing is necessary for us to fulfil our contractual obligations, such as to administer membership or donations made via our websites, telephone, post, or other through another channel.

7.4.2    Processing is necessary to comply with a legal obligation such as to enable us to process Gift Aid claims.

7.4.3    Processing is necessary for our legitimate interests. For example, to send information about your membership and / or the work you’ve supported, to inform you of upcoming events and campaigns, to seek feedback, to provide information on other methods of support that may be of interest (such as gifts in Wills), or to provide information on other carefully selected organisations with whom we may work in partnership.

7.4.4    Consent – We will seek to obtain your consent to process:

• personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above).  For example, we will seek to obtain your consent to process your data in instances where we intend to process data that is not needed for the sole purpose of the legacy administration process, such as if we want to remain in contact with a donor’s relative to keep them updated on how the legacy donations are being used to benefit a particular area of CWT’s work.
• any special category data.

7.5       For ‘joint’ and ‘family’ memberships, we will address communications to all those listed on your membership. If you wish to update this at any point, please contact us at supportercare@cornwallwildlifetrust.org.uk.

7.6       For family memberships, children under 18 will be included and are members of CWT. We collect their names and dates of birth in order to allocate them into the correct membership bracket.

7.7       For membership purchased as a gift, we will use the address provided by the purchaser to send information about our work in the post.

7.8       When a membership expires or lapses, unless we receive instruction otherwise, we may continue to communicate with you by post, telephone and email (where legitimate interest and / or consent allows).

7.9       As a fundraising organisation, we may undertake in-house or outsourced research (using specialist agencies) or analysis about supporters and potential supporters (including donors and members). This includes, but is not limited to, using geo-segmentation tools, such as Acorn. This could be for several purposes, including:

• To understand supporters and potential supporters better, so we can: (a) identify individuals who may have the capacity to support our work at a significant level; and (b) can tailor communications to a person’s interests.
• To identify individuals who may have an affinity to our cause but with whom we are not already in touch.
• To conduct due diligence on donors in-line with our Gift Acceptance Policy, and to meet money laundering regulations.

Information will be sourced from publicly available sources, such as Companies House, the Electoral Register, company websites, ‘rich lists’, social networks (such as LinkedIn), political and property registers, and news archives.

Research to enable our work and provide the best possible experience to supporters may include:

• Database screening, to identify supporters and potential supporters who may have the capacity to support our work at a significant level.
• Using audience segmentation tools, such as Acorn. We call this ‘Profiling’ to better understand who our supporters are and increase the effectiveness of our communication and fundraising efforts.

We rely on Legitimate Interest as our lawful basis for conducting research, with the exception of Special Category Data (for example, this includes – but is not limited to - information on an individual’s health or religious believes), which will only ever be recorded with a supporter or potential supporters’ explicit consent.

Research helps us to understand more about our supporters and potential supporters so we can focus conversations and communications in the most effective way, and ensure that we provide a rewarding experience for those who make our work possible.

Supporters or potential supporters can opt out of having their data used in this way by emailing supportercare@cornwallwildlifetrust.org.uk.

 

8. The Data We Collect About Landowners

8.1     We collect personal data about landowners we work with on conservation projects or landowners we provide with grants. CWT is the data controller for this personal data.

8.2      The data we collect about landowners includes:

8.2.1      Identity Data includes first name, last name, title, or other identifier (such as job title).

8.2.2      Contact Data includes correspondence address, email addresses and telephone numbers.

8.2.3      Property Details includes details of land owned and any tenancy agreements.

8.2.4      Financial Data includes bank details and details of any grants provided.  

8.2.5      Profile Data includes your interests, preferences of activities you wish to get involved in, feedback, and responses to surveys about our work.

Please note that we may collect and/or process other personal data about landowners from time to time.

8.6      We will only process personal data where we have identified a valid lawful basis to do so. For landowners the lawful basis we are likely to rely on are as follows:

8.6.1      Processing is necessary for us to fulfil our contractual obligations, such as to process a grant we are providing you with;

8.6.2      Processing is necessary to comply with a legal obligation;

8.6.3      Processing is necessary for our legitimate interests for example to maintain relationships with landowners to fulfil our charitable purposes of preserving the landscape of Penwith;  

8.6.4      Consent – We will seek to obtain your consent to process:

1. personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and
2. any special category data.

 

9. Cornwall Environmental Consultants (CEC)

9.1    CEC is owned by Cornwall Wildlife Trust and offers ecology and wildlife surveys, as well as landscape architecture planning services.

9.2    CEC processes personal data when they are approached via their website or by email with work enquiries from clients such as architects, developers and individual land and property owners.

9.3    The data CEC collects includes:

9.3.1    Identity Data includes first name, last name, title or other identifier.

9.3.2    Contact Data includes correspondence and billing address, email addresses and telephone numbers.

9.3.3    Profile Data includes which service(s) you are interested in when you fill out a contact form on our website.

9.3.4    Financial Data includes bank account and payment card details.

9.3.5    Transaction Data includes details about services you have purchased from us.       

Please note that CEC may collect and/or process other personal data about you from time to time.

9.4    We will only process personal data where we have identified a valid lawful basis to do so. The lawful basis CEC are likely to rely on are as follows:

9.4.1    Processing is necessary for us to fulfil our contractual obligations, such as to provide you with our services,

9.4.2    Processing is necessary to comply with a legal obligation,

9.4.3    Processing is necessary for our legitimate interests for example to keep our records up to date or inform you about other services which may be of interest to you.

9.4.4    Consent: We will seek to obtain your consent to process

1. Personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and
2. Any special category data.

 

10. ERCCIS

10.1    ERCCIS is the official Local Environmental Records Centre for Cornwall and the Isles of Scilly and is a department of CWT.   ERCCIS processes spatial and temporal data on wildlife species and habitats. ERCCIS collects the following personal data when you make a wildlife sighting report or order services from us:

10.1.1    Identity Data includes first name, last name, title or other identifier.

10.1.2    Contact Data includes correspondence address, billing address, telephone numbers and email addresses.

10.1.3    Financial Data includes bank account and payment card details.

10.1.4    Transaction Data includes details about services you have purchased from us.      

10.1.5    Usage Data includes information about how you use our websites, products, and services.

10.2    If you report a wildlife sighting to ERCCIS we may contact national or local experts to ask for their opinion in the event of records that are rare or difficult to identify and following that ERCCIS/CWT staff and affiliated verifiers may need to contact you for further information regarding your sighting.

10.3    ERCCIS will only process personal data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:

10.3.1    Processing is necessary to fulfil a contract with you, such as where we are providing funded or charged environmental consultancy services;

10.3.2    Processing is necessary to comply with a legal obligation;

10.3.4    Processing is necessary for our legitimate interests, to keep our records updated and to analyse how customers use our services; and

10.3.4    Consent – We will seek to obtain your consent to process:

1. personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and
2. any special category data.

 

11. Cornwall Good Seafood Guide

11.1       Cornwall Good Seafood Guide is a project led by CWT in partnership with representatives from all sectors of Cornwall’s fishing industry. The website details, recipes and provides a guide which recommends places to eat or buy Cornish seafood.

11.2    The data Cornwall Good Seafood Guide collects includes:

11.2.1    Identity Data includes first name, last name, title or other identifier.

11.2.2    Contact Data includes correspondence address, billing address, email addresses and telephone numbers.

11.2.3    Financial Data includes bank account and payment card details.

11.2.4    Transaction Data includes details about goods you have purchased from our online shop, or services including the membership fee to display your business in the Cornwall Good Seafood Guide. 

11.2.5    Usage Data includes information about how you use our website, products, and services.

11.3    Cornwall Good Seafood Guide will only process personal data (which may include providing it to third parties) where we have identified a valid lawful basis to do so. These are as follows:

11.3.1    Processing is necessary to fulfil a contract with you, such as where you have made a purchase from our online shop or paid a subscription fee in order to feature in our online guide;

11.3.2      Processing is necessary for our legitimate interests of studying how users use our products/services to further develop the project and to advertise to them;

11.3.3    Processing is necessary to comply with a legal obligation; and

11.3.4    Consent – We will seek to obtain your consent to process:

1. personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and
2. any special category data.

 

13. Partner Organisations And Tevi

13.1    We process the names and contact details of those at partner organisations we work with on various projects to fulfil contracts with them and for our legitimate interests of ensuring the successful running of projects.

13.2    We are a partner of Tevi – an initiative which supports enterprises to become more efficient with their natural resource use and to minimise their waste in smart and innovative ways as part of a global transition towards a circular economy. This work is led by the University of Exeter, and is delivered in partnership with us, Cornwall Council and Cornwall Development Company.

13.3    Information on how data will be processed by Tevi can be found at: https://www.exeter.ac.uk/iib/about/privacy/

 

14. Third Parties And Sharing Information

14.1    We will keep personal data within our organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services.  We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

14.2       Please see below the list which sets out the categories of processors of personal data.

SERVICE PROVIDERS WHO MAY PROCESS YOUR PERSONAL DATA

Accountants

Banks

Cloud Providers

Cloud storage services (Dropbox, Google Drive, Microsoft Office)

Couriers and other mail providers who may send our magazines and any goods you order from our online shop to you

CRM Providers

Debt Recovery firms

Email Provider

Fundraising Platforms (e.g. JustGiving)

Online payment providers (such as Cardnet and Worldpay)

Eventbrite where you sign up to attend an event

HMRC

IT Support Services

Marketing Agencies

Market Research & Analytics companies

Providers of Accounting Software

Social Media platforms

Software Providers

Solicitors

 

14.3    In addition, third parties may provide us with personal data, and they should only do so where the law allows them to. 

14.4    Cornwall Wildlife Trust is an independent member of The Wildlife Trusts (The Royal Society of Wildlife Trusts (RSWT), registered address The Kiln, Mather Road, Waterside, Newark on Trent, Nottinghamshire, NG24 1WT. Registered company number RC000558 and charity number 207238). In some cases CWT will share your personal data with RSWT, for example where they provide us with services which they provide to us and other Wildlife Trusts (for example hosting our websites).

 

15. Where Your Data Is Held

15.1    Your data is stored by us and our processors in the UK or EEA. Where your personal data is transferred outside of the UK or the EAA, we have ensured that:

15.1.1    an adequacy decision has been made by the European Commission permitting the transfer of data to that country; or

15.1.2    standard contractual clauses (SCCs) are in place, and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case-by-case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.

 

16. Applications To Work Or Volunteer For Us

16.1      If you apply to work or volunteer for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

16.2    If you are a Cornwall Wildlife Trust volunteer, we collect your personal data so that we can keep in touch with you. For example, to notify you of changes to planned volunteer work programmes that you may be participating in. For further information, please refer to our volunteer privacy notice [link here].

16.3    We will only process personal data where we have identified a valid lawful basis to do so. For volunteers and applicants, the lawful basis are the following:

16.3.1    Processing is necessary to fulfil a contractual obligation, including those which arise from contracts of employment,

16.3.2    Processing is necessary to comply with a legal obligation, such as processing and retaining information about your health, including any medical condition in order to comply with our health and safety obligations and enable any reasonable adjustments to be made;

16.3.3    Processing is necessary for our legitimate interests for example to assess the suitability of candidates and volunteers for potential roles and monitor compliance with our internal standards and procedures; and

16.3.4    Consent – We will seek to obtain your consent to process:

1. personal data outside our contractual obligations (see above) unless we have identified a legal obligation or legitimate interest (see above); and
2. any special category data.

 

17. Data Retention

Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.

We will only use and store information for as long as is required for the purposes it was collected for. We continually review what information we hold and delete what is no longer required. If you ask us to stop sending you marketing materials, we will retain your contact details and relevant information to ensure we honour your request and do not contact you in the future.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

 

18. Your Rights

18.1    Under the Data Protection Laws your rights are:

18.1.1    To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available with the emphasis on transparency over how we process your data.

18.1.2    Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. 

18.1.3    Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.

18.1.4    Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case-by-case basis and should be submitted in writing to the contact details provided in this policy.

18.1.5    Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.

18.1.6    Portability – You have the right to obtain and reuse your personal data that you have provided to us.

18.1.7    Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.

18.1.8    Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.

18.2    Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.

18.3    If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

 

19. 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.

Cookie provider: The Wildlife Trusts
Purpose: Used by the website to remember cookie preferences.
Cookies: cookie-agreed, MCPopupClosed

Cookie provider: Google Analytics
Purpose: These cookies are installed by Google Analytics and calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. The _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. The _gat_UA-110481466-1 cookie is a variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.
Cookies: _ga_YD9BW1YSV9, _ga, _gat, _gid, _gat_UA-110481466-1
Provider policy: Google

Cookie provider: Bing
Purpose: Bing Ads sets this cookie to engage with a user that has previously visited the website. Bing sets this cookie to recognize unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations.
Cookies: _uetsid, _uetvid, MUID
Provider policy: Microsoft

Cookie provider: Facebook
Purpose: This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.
Cookies: _fbp
Provider policy: Facebook

Cookie provider: Stripe
Purpose: Stripe sets this cookie cookie to process payments.
Cookies: m, __stripe_mid ,__stripe_sid, 
Provider policy: Stripe

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

20.     Changes To This Privacy Policy

We keep our privacy policy under regular review, and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.

Date of last update:  29/10/2024