Privacy Policy

Founded in 1962, Wiltshire Wildlife Trust (WWT) is today the leading charity in Wiltshire and Swindon working to achieve nature’s recovery and connect people with nature. 

The Trust is supported by a growing community of more than 12,000 members, almost 3,000 volunteers, and employs over 150 people. Partnership is our watchword, and our Strategy commits us to collaborating with farmers and strategic partners in order to achieve nature’s recovery in the wider landscape beyond our own reserves. 

Wiltshire Wildlife Trust Limited is a registered charity (registered with the Charity Commission under registration number 266202). We are also registered as a company in England and Wales under registration number 00730536. 

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.  

WWT holds and processes data – including personal and sensitive data – so that we can deliver our charitable mission 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 in accordance with the Data Protection Act 2018 (DPA18), 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 only share information when it is necessary to meet our organisational needs and legal obligations and then only with strict controls and data sharing and processing agreements in place. We will never sell personal data to third parties. 

We use three key definitions to describe the 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. 

• ‘Data subject’: this is you. As the data subject, we respect your right to control your own data.
• ‘Data controller’: this is us, Wiltshire Wildlife Trust (WWT). 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 an organisation, who processes data on our behalf.  

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 anyone. 

For more information about your rights with regards to personal data, please see the Information Commissioner’s Office (www.ico.org.uk). If you have any questions about this document, would like to find out more about the data we hold on you or would like more information, please do get in touch – see 12 Contact Details. 

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 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 Wiltshire 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
• Sending you your membership renewal letter
• Getting in touch should there be any issues processing your subscription payment
• Keeping your personal details up to date 

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

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

We collect your personal data to: 

• process any donation payments
• acknowledge receipt of any donations 

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

c) To deliver services that you have asked for 

We collect personal data to: 

• provide funded or charged services – such as landowner advice, environmental services, educational activity etc.
• process any payments related to these services
• process any monitoring information related to these services
• report to funders as required by funding contracts 

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

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

We also collect your personal data so that we can send you information about our work that we feel will be of interest to you. This includes your membership magazine, fundraising appeals, events, campaigning and volunteering opportunities, job and trainee opportunities, membership, our projects, local activities, services, products, newsletter requests, feedback, competitions and other activities, as well as information about other carefully selected organisations with whom we work in partnership. From time to time, we may also use your personal data to ask for your opinion about our work. 

Your personal data also helps us to get to know you better and to develop a ‘profile’ of you on our secure support database. This ‘profile’ enables us to send you the information listed above in a timely and relevant way, to suit you. Keeping track of the donations, you make to our organisation, for example, 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: 

1. 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). 

2. 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 contact you about our work at any time. If you wish to update your communication preferences at any time in the future, please contact the membership team at membership@wiltshirewildlife.org or 01380 725670.   

 e) To enable you to volunteer with us 

If you are a Wiltshire Wildlife Trust volunteer, we collect your personal data to: 

• Notify you of volunteer opportunities and any changes to planned work programmes that you may be taking part in
• Let you know about events useful for volunteers e.g. training opportunities, ‘thank you’ events, and informative events.
• Send you volunteering information or news 

We may collect extra information about you, for example, references, criminal records checks, details of emergency contacts, and medical conditions. 

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

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

f) To meet our legal obligations  

We collect personal data in order to comply with legal obligations such as providing information to bodies such as HMRC, Charity Commission, Companies House, and HSE.  

The ICO define the lawful basis for processing personal data for these purposes as ‘legal obligation’. 

g) To enable effective functioning of our organisation 

We collect personal data to enable the Trust to operate effectively in a variety of ways such as:  

• responding to complaints,
• complying with regulators e.g. Fundraising Preference Service, Fundraising Regulator
• safeguarding, health and safety, security
• maintaining records to comply with donor requirements
• maintaining historical records of reserve management and biological field records
• liaising with landowners and tenants about conservation activities
• running engagement activities such as events and competitions
• evaluating events, campaigns and website activity
• research and statistical analysis 

The ICO define the lawful basis for processing personal data for these purposes as ‘legitimate interest’. 

a) Basic information 

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

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

b) Getting to know you better 

We also collect information about you that helps us to get to know you better. This may include: 

• information about your wildlife interests, which you tell us through our Membership or similar Surveys
• records of donations you’ve made towards fundraising appeals
• your preferences of how you would like us to contact you
• ways you’ve helped us through volunteering
• 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. We may check against Royal Mail’s National Change of Address database, for example, 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. 

In order that we use our resources as effectively as possible to help us engage with our supporters appropriately, we may collect demographic and consumption data generated through geo-demographic tools, as well as information related to your wealth. We may use profiling techniques or use third party wealth screening companies to provide us with general information about you. This may include information from publicly available sources, for example, Companies House, the Electoral Register, company websites, social networks , political and property registers and news archives. Wealth screening enables us to better target our conversations about fundraising and therefore generate funds cost effectively. We use legitimate interest as the legal means for processing this data. 

We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This may include people connected to our current major supporters, trustees or volunteers. We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Acceptance Policy and to meet money laundering regulations. We conduct this research on the basis of Legitimate Interest. 

If you would prefer us not to use your data in this way, please email us at info@wiltshirewildlife.org or call us on 01380 725670.   

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

1. 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. These help us to: 

• 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, please see our cookies policy here. 

2. YouTube API (Application Programming Interface) services 

 We use YouTube API services to display video across our website.  By using our website, you agree to be bound by the YouTube Terms of Service. Find out more information on Google Privacy policy 
 
We may provide your email address to digital advertising or social media companies who work on our behalf, such as Facebook and Instagram. This is so we can reach you and others like you with information about how you can support our cause. This data is always provided in an encrypted format and is deleted immediately after use. If you don’t want to see targeted advertising from us on social media, please refer to the instructions provided by the social media site, for example on Facebook, Instagram, and Google.  

Below are some examples of the types of organisations with which we may share your data:  

• Advertising partners – to enable us to ensure our advertising is relevant to the recipients.
• Analytics partners – to enable us to track the effectiveness of our website or mobile apps.
• Social media partners – so that we can effectively communicate with our supporters on social media platforms. 

Website and app partners – to help us develop websites and apps that give our customers the best possible online experience. 
 
Upon 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 one then you may be supplying information to a third party. 

c) Sensitive personal data 

We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and members. However, there are some situations where this will occur. For example, if we are delivering a funded project that is specifically aimed at benefitting people’s health or which targets particular groups of individuals (such as people from diverse backgrounds or with specific ethnicities). When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission. In these situations, we collect the data from you directly. Generally, we anonymise sensitive personal data wherever possible. 

If you are a volunteer then we may collect extra information about you, for example: 

• references
• criminal records checks
• details of emergency contacts
• medical conditions 

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

d) Children and young people 

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

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

For further information, please see our Safeguarding policies and procedures.  

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

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 Wiltshire 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 (Stripe; PayPal). Other payment methods (e.g. Apple Pay) are handled in a similar manner. 

Wiltshire 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 is required for the purposes it was collected for. We continually review what information we hold, and delete what is no longer required. 

We will never sell your personal data to third parties. If you have opted-in to communications, we may contact you with information about our partners, or third party products and services, but these communications will always come from the Trust and are usually incorporated into our own communications (e.g. leaflets, articles in magazines or email newsletters).  

We sometimes need to share personal data with subcontractors or suppliers who provide us with services. Where this is necessary we, and any third parties we share with, are required to comply with all aspects of the General Data Protection Regulations (GDPR). Sharing is always subject to a lawful basis for processing. Organisations that we share data with include:  

• Our trading subsidiaries – to ensure that we are adhering to legal obligations and high levels of customer care throughout the Trust group;
• Organisations who process data on our behalf – for example, membership recruitment providers, mail and print services, consultants / sub-contractors who help us to analyse and improve our performance, and consultants / sub-contractors who help us by supporting our social media and online advertising and marketing campaigns;
• Our partners on partnership projects – for example, for the purposes of project monitoring and delivery, or if you register to attend a jointly-run event;
• Our funders – to demonstrate compliance to funding and contracts;
• Legal/compliance bodies where required – including insurers, auditors, pension providers, HMRC, Fundraising Regulator, ICO;
• Statutory bodies or agencies – for example, to respond to legal issues and risks;
• Healthcare, social and welfare organisations – to manage and safeguard the wellbeing of our staff, volunteers and supporters;
• Educators and examining bodies – for example, where we are supporting children through our education programmes and care farms, or our trainees;
• Current, past and prospective employers – for example, to provide references;
• Family, associates or representatives of the person whose personal data we are processing – for example, where we are administering a legacy;
• Survey or research organisations – for example, to verify species records.
• The Wildlife Trust Federation - To support our collaboration as a federation. Data sharing across The Wildlife Trusts federation is governed by a comprehensive collective Data Sharing, Processing and Joint Controllership Agreement. 

We’ll only share information when necessary and for the purposes that you have provided the data to us. We will always endeavour to send data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.   

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

• The right to be informed:  This Privacy Notice outlines how we capture, store and use your data. If you have any questions about this, please contact us using the details at the end of this notice.
• 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 the statutory timeframes, based on ICO guidelines.
• The right to rectification:  If we have captured information about you that is inaccurate or incomplete, we will update it.    
• The right to erasure (‘right to be forgotten’):  You can ask us to remove your personal details from our records.
• The right to restriction:  You can ask us to stop using your personal data.
• The right to data portability:  You can ask to obtain your personal data from us for your own purposes.
• The right to object: You can ask to be excluded from marketing activity.
• Rights in relation to automated decision making and profiling: We respect your right not to be subject to a decision that is based solely on automated processing, including profiling.  

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

Please note that there are statutory exemptions and restrictions that can, in some circumstances, be applied to exempt or qualify the right of individuals to exercise these rights. 

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

For more information see our complaints policy here.

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

Name: Becki Mckinlay, Director of Fundraising and Engagement 

Address: Wiltshire Wildlife Trust, Elm Tree Court, Long Street, Devizes, SN10 1NJ 

Phone: 01380 725670  

Email: info@wiltshirewildlife.org

We regularly review our privacy policy to ensure that we remain compliant with legislation and our current information practices. This means that from time to time our privacy policy will be updated without prior notice. We want you to remain informed and to always be in control of your information and significant changes will be notified via our website on the updates page here.