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Privacy

GENERAL PRIVACY POLICY
 

At the National Animal Welfare Trust (NAWT) we are committed to protecting your personal information. This Policy explains what happens to any personal data that you provide us with in order to help further our work in rescuing and rehoming domestic pets.

Who we are

  • The Charity, National Animal Welfare Trust (registered charity number 1090499)
  • Our trading company, AWT Trading Ltd (registered company number 2363778)

What the Law says

Data Protection is governed by the EU General Data Protection Regulation (the ‘GDPR’) and Data Protection Act 2018 which became enforceable in May 2018. GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the legal grounds must apply.

The four legal grounds that are most relevant to NAWT’s use of your personal information are:

  • Consent
  • Legitimate Interest
  • Contract
  • Legal Obligation

NAWT will only process (use) your personal information if we have:

  • asked you and have a record of your express and recent consent for us to do so;
  • a ‘Legitimate Interest’ to do so in order to support our charitable purposes. Our use will be fair and balanced and never unduly have an impact on your rights;
  • a contract with you that we can only fulfil by using your personal information, e.g. to send you an item that you have requested;
  • a legal obligation to use or disclose information about you, e.g. we are required by law to keep records of gifts that are given to us with Gift Aid for 4 years; and we are compelled to disclose information relating to incidents involving dangerous dogs for insurance purposes under the Dangerous Dogs Act.

In extreme situations, such as an accident or medical emergency, we may share your personal details with the emergency services if it is essential for the preservation of life (yours or another persons’) for us to do so. This is the ‘vital interest’ ground for using your personal information.

We will not unduly prioritise our interests as a charity over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.

Consent

NAWT will always ask for your consent before we communicate with you for certain purposes. For example, we will only email or phone you about our fundraising activities if we have an accurate record of your recent and freely given consent to do so.

You can withdraw your consent at any time by calling 0208 950 0177 or emailing supportercare@nawt.org.uk.

There are times when it is not practical to obtain and record consent. At those times, we will only process personal information if that processing would meet another legal ground e.g. Legitimate Interests, in which case we would only process in accordance with the law’s strict rules on legitimate interest processing.

What is Legitimate Interest?

This allows organisations to process your personal information if they have a genuine and legitimate interest for doing so and that use does not harm any of your rights and interests as an individual.

NAWT’s Legitimate Interest

We believe that the best way to look after the interests of our supporters is to consider their unique interests and expectations.  As a result we have established the following categories to help us to use your personal information in a way that matches your relationship with us, your interests and your expectations about your rights.

  • Pledged lifetime interest
  • Rehomed an animal from us
  • Provided financial donations
  • Demonstrated an interest in the charity by contacting us eg finding out more about one of our products, services or campaigns

What Legitimate Interest allows us to do?

We believe that NAWT supporters are connected to our mission and want to know how they can continue to help us to achieve our charitable aims. Unless you tell us not to, we will process (keep and use) your personal information for the following lengths of time.

  • Life Members

For supporters who are Life Members, Emergency Pet Care or Pet Care Card members; or have pledged to leave us a gift in their will – we will keep your personal information until there is no longer a need.

  • Rehomer

For supporters who have rehomed an animal we believe that you would wish to remain in contact with us throughout their lifetime.  We will therefore keep your personal information to allow for this up to a period of 20 years, or when you notify us that the animal has passed away, whichever is earlier.

  • Financial Supporters of NAWT

These are supporters who help or have helped us with financial gifts. A supporter’s pattern of giving can often change over time and the supporter may, for a period of time, stop providing financial support e.g. stop regular-giving through Animal Sponsorship.   This can be for a wide number of reasons, including because they choose to support us in different ways. Irrespective of their financial circumstances, these supporters still hold the same principles and values; and continue to be connected to NAWT. This is evidenced by the fact that many of this group of supporters restart regular-giving, and other financial support in future years. We believe that supporters of our charity never stop believing in the importance of the work that we do, and we will therefore keep your data until you tell us otherwise.

  • Shown an interest in NAWT via an enquiry

These are supporters of our mission, who have shown an interest in the work of the charity by contacting us for more information, e.g. to find out more about one of our products, services or campaigns. We feel that someone that has reached out to us would like us to provide a little more information; and even some support in fulfilling their initial query or request. To support this, we keep your personal information for a period of 2 years.

Supporters demonstrate their support in a number of ways and this could be in more than one, or even all, of the above categories.

It is always your choice. If you don’t think this is quite right for you, you can tell us to change your communication preferences and our use of your information at any time.

Legitimate Interest to send you direct mail

Unless you tell us not to, we will rely on our Legitimate Interest ground (explained above) for sending you direct mail. From time to time, we would like to post you exciting updates about our work, products, services and how you can support us, including fundraising activities. Unless you have requested that we do not send you some, or all of this, our direct mailings do include marketing and fundraising asks which further the aims and objectives of NAWT.

We are always mindful of trying to only send you what you are interested in and only as often as is appropriate. If we do not appear to be sending communications that are of interest, we will review this and will endeavour to reduce and then stop in a much shorter time than the above defined period of Legitimate Interest e.g. if you donated three years ago and do not seem to have been interested since then we are likely to reduce these communications, even though we have a legitimate interest to process for 10 years. The average length of time required for us to be able to properly assess and reflect on your pattern of response is about two years. But you’re always in control so please let us know if you no longer wish to receive this.

Legitimate Interest to process your information

We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.

When it is necessary we will contact you for administrative purposes, e.g. to contact you regarding a payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.

To help you to understand when and why NAWT would use Legitimate Interest to process your personal information we provide the following examples:

  • To send postal communications (as explained above)
  • To enhance, modify, personalise and improve our services and communications for the benefit of our supporters.
  • To improve security of our websites and systems.
  • To prevent fraud when transacting on our website.
  • To process your donations.
  • To fulfil online transactions; process and deliver your order(s). To take payment and arrange delivery, we need to collect personal information, including your payment details, your full name, delivery address and contact details.
  • To analyse your personal information to ensure that our communications are relevant to you.

The above list of examples are on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop.

What we collect and how we use it

NAWT collects information from the public in a number of different ways.  For example, we ask for contact and other information when members of the public wish to relinquish or rehome an animal, sign up to one of our campaigns or attend training classes. This may include information such as your name, address, email and telephone number. We use this information to help us provide and improve our services as a charity and to keep a record of our communications with you.

If you are a financial supporter of NAWT, by becoming a member, purchasing from our online shop, sponsoring an animal or donating to us we will ask for information that enables us to administer your donation.  This will normally include information such as your name, address, email or telephone number, your payment details and Gift Aid status.  

If you have given us your consent, we will contact you with information and updates on our work, products, services and how you can support us. This may be by post, email, telephone or text message, depending on your preferences. We will also continue to ask about your marketing preferences, to ensure that you are still happy to be contacted by us and by which means.

Information you may provide to the Charity

This list is not exhaustive but covers the main areas:

  1. How you use our website (cookies) which could include details of your visits such as pages viewed and the resources that you access. Such information includes IP address, traffic data, location data and other communication data;
  2. Recipients of our services eg rehoming, relinquishing of an animal, webinars, ally support;
  3. Donations, response to mailings, appeals, lottery, raffles and competitions;
  4. Volunteering for the charity, taking part in a sponsored event, attending an event or fundraising on our behalf;
  5. Job applications, working as an employee or consultant;
  6. Purchases from the charity or online shop;
  7. Sponsorship, Becoming a Friend, Membership and for the Emergency Pet Care or Pet Card Scheme, Gifts in Wills;
  8. Requests for a copy of our magazine, Animate or other promotional material;
  9. Enquiries or other correspondence (including social media & webinars) or you become involved with us in another way.

What we may collect and process

  1. Your name, address, email address, telephone number and other contact information
  2. Date of Birth but only to establish over 18 for raffles or lotteries
  3. Financial information, such as your bank or card details
  4. Information you enter onto our website
  5. Records of correspondence with us, if you have contacted us
  6. Details of your visit to our website, including your IP address

Payment processing

All of our payment processing is secure and is handled by one of the following organisations:

CAF

Donations from the NAWT website, Payroll Giving, CAF accounts and vouchers are processed through CAF.  If you agree to share your data with NAWT, we will receive the details you have given to CAF.  Please view CAF’s privacy and security https://www.cafonline.org/navigation/footer/privacy

Paypal

Payments and donations for the online shop are processed through PayPal.  Please view PayPal’s user agreement to find out how they deal with privacy and security https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.

Rapidata

Direct Debits are processed by Rapidata Services plc, a BACs Approved Bureau. All data is encrypted and protected to safeguard your data. Rapidata Services plc’s servers are hosted by Amazon Web services. For more details visit http://rapidataservices.com/service/edirectdebit/

Third Party Links

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites.  As these are not governed by this privacy statement you should exercise caution and look at the privacy statement applicable to the website in question.

Information we receive from other sources

JustGiving

Donations and sponsorship pages in support of NAWT are handled by JustGiving. Please view JustGiving’s terms and conditions and their privacy policy to find out how they deal with privacy and security https://www.justgiving.com/info/privacy-policy-versions/privacy-policy-v20.

If you agree to share your data with NAWT, we will receive the details you have given to JustGiving. We will store details of those who are, or have fundraised for the Charity, and those who have supported them if they have agreed via JustGiving to share this information. This information is for financial records. We will only contact the fundraiser (host of the JustGiving page) directly regarding their event for support and thanks (and if they wish to receive future communications) not those that have sponsored them.

JustGiving claim Gift Aid on our behalf, so NAWT will not have a Gift Aid declaration on file for you if you have only given Gift Aid permission through this channel (and not directly with us).

If you have not agreed to share your details with NAWT, we will only receive the amount and message left, but no contact details.

Unity

NAWT’s Lottery is managed by Unity who process payments.  Their privacy policy can be seen at  https://unity.charitypayments.co.uk/privacy-policy?charity=297

We may use publicly available sources to keep our records up to date eg using the Post Office’s National Change of Address database and postcode validation and checking against deceased records.

How and why we use your information

We will process your personal information in accordance with applicable data protection laws and regulations, for the following reasons:

  • To provide you with the services, products or information you have asked for;
  • To administer your purchase, donation, membership or support your fundraising, including processing Gift Aid;
  • To rehome dogs and cats in accordance with our charitable purposes, including contacting you for aftercare purposes to ensure successful rehoming in accordance with our policies;
  • To supply personal data for free insurance cover and microchip registration;
  • To comply with applicable laws and regulations and requests from statutory agencies;
  • For our own internal administrative purposes and to keep a record of your relationship with us;
  • For marketing purposes, to provide you with information about us, our fundraising campaigns, our events, our services, and any other information, products or services that we provide access to;
  • To manage your communication preferences with us generally;
  • To notify you about changes to our services and/or membership/donor benefits;
  • To ensure that content from our website is presented in the most effective manner for you and for your computer/mobile device.

We will keep your personal data for no longer than is necessary for the purposes for which it is processed, in accordance with this and our retention policy.

Where your personal data is stored

The information we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA).  It may also be processed by persons operating outside the EEA.  If we send your personal data outside the EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information.  By submitting your details you agree to this use of your data for processing and storing.

All information you provide to us is stored on secure servers in accordance with our internal security policies.  Any online payment transactions will be encrypted. 

Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission being at your own risk.  Once that information is received we will use strict procedures and security features to try to prevent any unauthorised access.

Who has access to your information and who do we share it with

Any information we collect may be used by both our charity and our wholly owned trading company, AWT Trading Limited.

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

  1. In the event that we merge with another charity.
  2. Where we are legally required by law to disclose your personal information eg HMRC for the purposes of administering Gift Aid.
  3. To further fraud protection and reduce the risk of fraud.

We may allow our staff, consultants and/or external providers acting on our behalf to access and use your information for the purposes for which you have provided it to us (eg deliver mailings, analyse data and process payments).  We only provide them with the information they need to deliver the relevant service and we make sure your information is treated with the same level of care as if we were handling it direct.

We will not share your data with any third parties for their marketing purposes. 

Access to Information

To obtain a copy of the personal data that the Trust holds about a Data Subject, they can do so by making a written data subject access request (DSAR) to Supporter Care at the address below. This allows the data subject to check that we are lawfully processing their personal data.

We may need to request specific information from Data Subjects in order to verify their identity and check their right to access the personal information or to exercise any of their other rights. This is a security measure to ensure that their personal information is not disclosed to any person who has no right to receive it.

Whilst we will normally provide a copy of the personal data in response to a DSAR free of charge, we reserve the right to charge a reasonable fee, based on our administrative costs of providing the personal data, when a DSAR is manifestly unfounded or excessive, particularly if it repeats a DSAR to which we have already responded. Alternatively, where a DSAR is manifestly unfounded or excessive, we reserve the right to refuse to respond altogether. Where we refuse to act on a request in this way, we will set out our written reasons why to the data subject within one month of receipt of their DSAR. We will also inform them of their right to complain to the Information Commissioner’s Office or to seek a judicial remedy in the courts.

Contacting Us

Please do not hesitate to contact us regarding any matter relating to this Privacy Policy and should you wish to change your communication preferences just give us a call on 0208 950 0177 (option 1) during office hours, email Supporter Care or write to Supporter Care, NAWT, Tylers Way, Watford by pass, Watford, WD25 8WT.

We are registered with the Information Commissioner’s Office (ICO) and Fundraising Regulator