Privacy Policy
ISLES OF SCILLY Wildlife Trust Privacy policy, Feb 2023
1. OUR COMMITMENT TO YOUR PRIVACY
We are committed to keeping the personal details of our members, friends 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.
Any references to Isles of Scilly Wildlife Trust, the Trust, or to ‘we’ or ‘us’ refer to:
• Isles of Scilly Wildlife Trust. We are a registered charity in England and Wales, and our registered charity number is 1097807.
• Isles of Scilly Wildlife Trust Limited, our charitable trading company, registered company number 04726698. The company is a wholly owned subsidiary of Isles of Scilly Wildlife Trust, which trades only to raise funds for our charitable organisation.
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).
i) ‘Data subject’: this is you, one of our valued members and supporters. As the data subject, we respect your right to control your data.
ii) ‘Data controller’: this is us, Isles of Scilly Wildlife Trust. With your permission, we determine why and how your personal data is used (as outlined in this policy).
iii) ‘Data processor’: this is a person, or organisation, who processes your data on our behalf, with your permission. For example, this might be the mailing house we use to co-ordinate our membership magazine mailings.
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 and never have done.
Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:
CEO, Julian Branscombe
Telephone: 01720 422153
Email: hello@ios-wildlifetrust.org.uk
Isles of Scilly Wildlife Trust, Trenoweth, St Mary's, Isles of Scilly, TR21 0NS
Our office hours are Monday – Friday, 9am – 5pm.
2. 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 ISLES OF SCILLY WILDLIFE TRUST MEMBERSHIP.
We collect your personal data to administer your membership, which may involve:
• Sending you a membership welcome pack when you first join us
• Processing your Direct Debit subscription payments, if you have set this donation process up with us
• 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, OR OUR RESERVES
We collect your personal data to:
• send you items you have purchased from our online shop
• send you 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 believe will be of interest to you.
This includes information about your membership, fundraising appeals, events, campaigning opportunities, membership, services, products, newsletter requests, feedback, competitions and other activities, as well as information about other carefully selected organisations that we work in partnership with. From time to time, we may also use your personal data to ask for your opinion about our work.
This information is in addition to that outlined in sections a) and b) and is defined as ‘direct marketing’ by the ICO.
i) Adult and Family membership
If you are an ‘Adult’ or a ‘Family’ member of our Wildlife Trust, including ‘Life’ members, 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 6 months after your membership has ended, or unless you 'unsubscribe'. This is just in case your support was cancelled accidentally, by 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 believe 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:
2) 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).
3) 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, WhatsApp message, 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 an Isles of Scilly 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
• dedicated volunteer thank-you events
Most importantly, we collect your personal data so that in an emergency, we are able to contact your next of kin.
We also record formal training you have completed, relevant to your volunteer role with Isles of Scilly Wildlife Trust (eg first aid, brushcutter, chainsaw)
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).
3. 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 (eg if a handwritten number is unclear on a form) we obtain information, such as your telephone number, postcode 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
i) We collect information about you, that you have told us, that helps us to get to know you better. This may include:
• information about your wildlife interests, which you tell us through our Membership Surveys
• records of donations you’ve made towards fundraising appeals
• your intention to remember Isles of Scilly Wildlife Trust in your Will
• 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. 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. Often, this is to ensure that we are speaking to a legal adult.
We may also collect demographic and consumption data about our membership as a whole, through geodemographic tools (such as CACI Acorn). This help us target our fundraising, communications and membership efforts and does not provide information on individuals.
ii) Other ways in which we collect personal data to get to know you better: 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.
c) SENSITIVE PERSONAL DATA
We do not normally collect or store sensitive personal data (such as information relating to health) about supporters and members. However, there are some situations where this will occur, for example where a member has told us they are a wheelchair user and to make adjustments on our events where possible.
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 bureau 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 will 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, we will capture your date of birth at the point of joining Isles of Scilly Wildlife Trust, as part of a family membership. This is so that we can send you information that we feel is suitable to your age.
If we have the permission of your parent or guardian, and you are one of our young ambassadors, we will capture your date of birth at the point of joining, together with your contact details. This is so that we can send you information about the activities you are involved in.
4. HOW DO WE STORE YOUR DATA?
a) SECURITY
All of the personal data we process is processed by our staff in the UK and all our IT systems are hosted and maintained within the European Economic Area (EEA). This is 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
Isles of Scilly 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.
All electronic Isles of Scilly Wildlife Trust forms that request financial data are made through secure payment gateways eg PayPal and Stripe. We do not process any financial information directly through our website. 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.
If you use a credit card to donate or purchase a membership or goods by telephone, post or in-person at one of our centres or events, we will process your credit card details securely through our payment provider **** and complete an annual PCI-DSS compliance through them.
c) CCTV
Some of our tenancy may have CCTV and you may be recorded if you visit them. CCTV is there to help provide security and protect vulnerable species. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review CCTV will be recorded over.
Isles of Scilly Wildlife Trust complies with the Information Commissioner’s Office CCTV Code of Practice, and we put up notices, so you know when CCTV is in use.
d) DATA RETENTION
We will only use and store information for as long as it required for the purposes it was collected for. We continually review the information we hold and delete what is no longer required.
5. 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. Email hello@ios-wildlifetrust.org.uk and 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.
For more information on your individual rights, please see the Information Commissioner’s Office.
6. MAKING A COMPLAINT
Isles of Scilly Wildlife Trust wants to exceed your expectations 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 grateful to hear from people who are willing to take the time to help us improve.
Should you wish to make a complaint, please contact our main office and our receptionists will direct you to the team manager who is most able to help you.
Telephone: 01720 422153
Email: hello@ios-wildlifetrust.org.uk
Isles of Scilly Wildlife Trust, Trenoweth, St Mary's, Isles of Scilly, TR21 0NS
Our office hours are Monday – Friday, 9am – 5pm.
a) 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.
For further information, please refer to our Complaints policy.
b) CONFIDENTIALITY All complaint information will be handled sensitively, in line with data protection requirements.
c) RESPONSIBILITY Overall responsibility for this policy and its implementation lies with Isles of Scilly Wildlife Trust’s Board of Trustees.
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
7. 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.
8. PLEASE GET IN TOUCH IF YOU HAVE ANY QUESTIONS
Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:
Office Manager
Telephone: 01720 422153
Email: hello@ios-wildlifetrust.org.uk
Isles of Scilly Wildlife Trust, Trenoweth, St Mary's, Isles of Scilly, TR21 0NS
Our office hours are Monday – Friday, 9am – 5pm.
9. REVIEW
Isles of Scilly Wildlife Trust is committed to reviewing its policy and good practice annually or whenever new legislation or practice make it necessary.
Approved by Board of Trustees: March 2023
Author: CEO (Julian Branscombe)
Accountable: Board of Trustees
ANNEX 1: COOKIES POLICY
a) 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.
b) 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 |
c)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.
Cookie provider: Facebook
Purpose: Used by Facebook for sharing content, conversion tracking, optimisation, creating audiences for Facebook Ads and marketing.
Cookies: _fbp, fr
Provider policy: Facebook
Cookie provider: Paypal
Purpose: Used to support payment services.
Cookies: AKDC, LANG, X-PP-SILOVER, akavpau_ppsd, enforce_policy, nsid, ts, ts_c, tsrce, x-csrf-jwt, x-pp-s
Provider policy: Paypal
Cookie provider: Vimeo
Purpose: Used to embed videos from Vimeo using cookies that we consider essential to the video player experience. Does not use third-party analytics or advertising cookies.
Cookies: player, vuid
Provider policy: Vimeo
Cookie provider: Eventbrite
Purpose: Used to deliver event booking services and content tailored to the user’s interests.
Cookies: _ga, _gat, _gid, AS, csrftoken, eblang, G, janus_re, mgref, SP, SS, ebGAClientId, lux_uid, SERVERID
Provider policy: Eventbrite
Cookie provider: Google
Purpose: Used to understand website usage including how users found and explored our site and how their experience can be enhanced. Google also provides campaign tracking, advertising and website functionality services.
Cookies: IDE, _ga, _gat, _gat_UA-xxxxxxx-xx, _gid
Provider policy: Google
Cookie provider: Stripe
Purpose: Used for making card transactions on the website. Provided by Stripe.com which allows online transactions without storing any credit card information.
Cookies: __stripe_mid, __stripe_sid
Provider policy: Stripe
Cookie provider: Hotjar
Purpose: Anonymously analyses how the website is being used to improve the user experience.
Cookies: _hjSessionUser_xxxxxx, _hjFirstSeen, _hjAbsoluteSessionInProgress, _hjIncludedInSessionSample, _hjSession_xxxxxxx, _hjIncludedInPageviewSample
Provider policy: Hotjar
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