The BWA is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information.
In May 2018 the BWA asked its members to “opt-in” for marketing communications. This brings us into line with the new General Data Protection Regulation (GDPR) rules which came into force in May 2018. We note your consent about how we can contact you. This means you’ll have the choice as to whether you want to receive our communications and be able to select how you want them (email, phone, SMS or post).
You can decide not to receive communications or change how we contact you at any time. If you wish to do so, please contact the secretary by emailing email@example.com, writing to BWA, 81 Browning Road, Ledbury HR8 2GA or telephoning 01531 671250.
We will never sell your personal data, or share it without your consent.
Any questions you have in relation to this policy or how we use your personal data should be sent to firstname.lastname@example.org or addressed to The Data Protection Officer, BWA, The Old Bakehouse, Ashperton, HR8 2SA.
2. ABOUT USYour personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by the British Waterfowl Association (charity no. 263156) in England.
3. WHAT INFORMATION WE COLLECT
Personal data you provide
We collect data you provide to us. This includes information you give when joining or registering, placing an order or communicating with us. For example:
- personal details (name, date of birth, email, address, telephone etc.) when you join as a member
- financial information (payment information such as credit/debit card or direct debit details, and whether donations are gift-aided. Please see section 9 for more information on payment security)
- details of your interests and preferences (such as campaigns, the ways you support us or types of waterfowl you enjoy).
If you purchase BWA membership as a gift for someone, join as a family or are the parent of one of our Junior members, your details will be recorded (as will the recipients) and your relationship to that person will be recorded.
Information created by your involvement with BWA
Your activities and involvement with BWA will result in personal data being created. This could include details of how you’ve helped us by volunteering or being involved with our campaigns and activities.
If you decide to donate to us then we will keep records of when and how much you give to a particular cause.
Information we generate
We may conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work, we may be able to build a profile which helps us decide which of our communications are likely to interest you. Section 7 (Research and profiling) contains more information about how we use information for profiling.
Information from third parties
We sometimes receive personal data about individuals from third parties. For example, if we are partnering with another organisation (e.g. you provide your information to another charity we’re collaborating with on a conservation project). Also, as explained in Section 12 (Cookies and links to other sites), we may use third parties to help us conduct research and analysis on personal data (and this can result in new personal data being created).
We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.
Occasionally, we may collect information about certain members (e.g. particularly well known or influential people) from public sources. This could include public databases (such as Companies House), news or other media. We don’t do this to everyone, and it is the exception not the rule.
Sensitive personal data
We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about members. However there are some situations where this will occur (e.g. if you volunteer with us or if you have an accident). If this does occur, we’ll take extra care to ensure your privacy rights are protected.
Accidents or incidents
If an accident or incident occurs at one of our events or involving one of our staff (including volunteers) then we’ll keep a record of this (which may include personal data and sensitive personal data).
If you are a volunteer (whether for specifically BWA, or if you are helping us for other reasons – for example you work for another organisation which is running an event with us) then we may collect extra information about you (e.g. references, criminal records checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal reasons, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
4. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to:
- enter into, or perform, a contract with you
- comply with a legal duty
- protect your vital interests
- for our own (or a third party’s) lawful interests, provided your rights don’t override these
In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes).
We use personal data to communicate with people, to promote the BWA and to help with fundraising. This includes keeping you up to date with our news, updates, campaigns and fundraising information. For further information on this please see Section 6 (Marketing).
We use personal data for administrative purposes (i.e. to carry on our charity and conservation work). This includes:
- receiving donations (e.g. direct debits or gift-aid instructions)
- maintaining databases of our volunteers and members
- performing our obligations under membership contracts
- fulfilling orders for goods or services (whether placed online, over the phone or in person)
- helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this)
Internal research and analysis
We may carry out research and analysis on our members, donors and volunteers, to determine the success of campaigns and appeals, better understand behaviour and responses and identify patterns and trends. This helps inform our approach towards campaigning and makes the BWA a stronger and more effective organisation. Understanding our members, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications).
Membership research and profiling
We may evaluate, categorise and profile personal data in order to tailor materials, services and communications (including targeted advertising) and prevent unwanted material from filling up your inbox. This also helps us understand our members, improve our organisation and carry out research. Further information on profiling can be found in Section 7 (Research and profiling).
5. DISCLOSING AND SHARING DATA
We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about third party products and services, but these communications will always come from the BWA and are usually incorporated into our own marketing materials (e.g. advertisements in magazines or newsletters).
We may share personal data with subcontractors or suppliers who provide us with services. For example, if you order something from the BWA Shop, your name and address may be shared with the delivery company. However, these activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure.
Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another charity). We’ll only share information when necessary and we’ll make sure to notify you first.
In May 2018, BWA asked its members to “opt-in” for most communications. This included all our marketing communications (the term marketing is broadly defined and, for instance, covers information about conservation and the BWA).
This means you’ll have the choice as to whether you want to receive these messages and be able to select how you want to receive them (post, phone, email, text).
You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact the Secretary by emailing email@example.com, writing to BWA, 81 Browning Road, Ledbury HR8 2GA or telephoning 01531 671250.
What does ‘marketing’ mean?
Marketing does not just mean offering things for sale, but also includes news and information about:
- our charity, campaigns and conservation work
- our role in educating the public in conservation of the natural environment
- BWA benefits and offers
- volunteering opportunities and how you can help
- appeals and fundraising (including donations and also competitions, raffles etc.)
- our events, activities and local groups
- products, services and offers (our own, and those of third parties which may interest you)
- leaving a legacy
- taking part in projects
When you receive a communication, we may collect information about how you respond to or interact with that communication, and this may affect how we communicate with you in future.
Newsletters and magazines
Membership magazines, including Waterfowl, are provided as a benefit to our members. We send these out to all our members (unless you specifically ask us not to) and you can choose to unsubscribe from general marketing communications without giving up your subscription to Waterfowl. However, please be aware that member magazines do include advertisements, competitions and fundraising information.
As a charity, we rely on donations and support from others to continue our work with conservation, education and preservation. From time to time, we will contact members with fundraising material and communications. This might be about an appeal, a competition we’re running, or to suggest ways you can raise funds (e.g. a sponsored event or activity, or even buying a product if the BWA will receive some of the proceeds).
As with other marketing communications, we’ll only contact you specifically about fundraising if you’ve opted into receiving marketing from us (and you can, of course, unsubscribe at any time).
Some of our fundraising (including face to face recruitment) is carried out by BWA County Reps and/or our mobile representatives. We may use third parties to carry out fundraising on our behalf. For example, we may use a representative to call members (who have agreed to be contacted by phone) about a campaign or appeal.
7. RESEARCH AND PROFILING
This section explains how and why we use personal data to build profiles which enable us to understand our members, improve our relationship with them, and provide a better membership experience.
Analysis and grouping
We may analyse our members to determine common characteristics and preferences. We do this by assessing various types of information including behaviour (e.g. previous responses) or demographic information (e.g. age or location).
By grouping people together on the basis of common characteristics, we can ensure that group is provided with communications, products, and information which is most important to them. This helps prevent your inbox from filling up, and also means we aren’t wasting resources on contacting people with information which isn’t relevant to them.
Profiling to help us understand our members
We may profile members in terms of financial and practical support. For example, we keep track of the amount, frequency and value of each person’s support. This information helps us to ensure communications are relevant and timely.
If, based on information that has been provided to us (such as geographical location, demographics, or previous donations), it appears an individual might be willing and able to provide more support in our various activities we may contact them to see if they wish to do so.
On occasion, we may also combine information about particular members with external information (such as directorships listed on Companies House, or news about an individual which has featured in the media) in order to create a more detailed profile about a particular individual.
We collect information on preferences and interests (e.g. whether you are a wildfowl, ornamental or domestic waterfowl enthusiast) so that we know what material you are most likely to be interested in.
We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new members, or to identify trends or patterns within our existing membership base. This information helps inform our actions and improve our campaigns, products/services and materials.
8. YOUNG PEOPLE
Photographs, pictures, stories and competitions in our magazines
We want young people to join in with BWA activities, and there are opportunities in our junior section in Waterfowl for readers to share their photos, stories and pictures. If we publish your child’s picture, photo or story, we’ll usually include their first name and age with it. If they write an article or story for us, we might also include their surname alongside it.
If your child enters a competition and is one of the lucky winners or runners-up, we’ll publish their name and winning entry alongside the other winners.
Parental permission: If your child is under 18 then we’ll need permission from you as their parent or guardian for them to enter one of our competitions or to share a picture, photo or story with us.
Information for parents
We take great care to protect and respect the rights of individuals in relation to their personal data, especially in the case of children.
If your child is under 18, we’ll only use his or her personal data with your consent. This means that, for example, if your child wants to have his or her name or picture featured in one of our magazines, we’ll need you to confirm you’re happy for us to do so.
Marketing and fundraising
We won’t send marketing emails, letters, calls or messages to under 18 year-olds and, in order to donate to BWA or order things from us online, you need to be an adult.
Our Junior Section in Waterfowl sometimes includes competitions or ideas about how to raise money (e.g. sponsored activities), but they are mostly just about waterfowl and conservation, the BWA, and ideas for things to do.
Junior membership and young people’s information
BWA adult membership is available to individuals aged 16 and over. Under 16s can have BWA Junior membership purchased for them by an adult.
We won’t use young people’s personal data for marketing purposes and we won’t profile it. If a Junior member turns 16 and wishes to join the BWA as an adult, some of the personal data we hold about that individual (e.g. junior membership history) will be carried over to their member profile.
9. HOW WE PROTECT DATAWe employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information. Electronic data and databases are stored on our protected computer systems and we control who has access to information (using both physical and electronic means). Our staff have received data protection training.
Payment securityIf you use a credit card to donate, purchase a membership, or purchase something on-line we will pass your credit card details securely to our payment provider (Worldpay). Other payment methods (e.g. PayPal and GoCardless) are handled in a similar manner. BWA 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.
Where we store information
The BWA’s operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do so if your data is adequately protected.
For example, some of our systems use Microsoft products. As a US company, it may be that using their products results in personal data being transferred to or accessible from the US. However, we’ll allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA’s Privacy Shield scheme).
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required. We never store payment card information.
11. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request)
- the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason)
- the right to have inaccurate data rectified
- the right to object to your data being used for marketing or profiling
- where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format
Please keep in mind that there are exceptions to the rights above, and though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
If you would like further information on your rights or wish to exercise them, please contact our Data Protection Officer at firstname.lastname@example.org, writing to BWA, 81 Browning Road, Ledbury, HR8 2SA or telephoning 01531 671250.
You can complain to the BWA directly by contacting our data protection officer using the details set out above. If wish to make a complaint (including a complaint about fundraising activity) which does not directly relate to your data protection and privacy rights, you can do so.
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at http://www.ico.org.uk.
12. COOKIES AND LINKS TO OTHER SITES
Our website uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality (such as being able to shop online). Further information can be found in our Cookies Policy at https://www.waterfowl.org.uk/wpnew/terms-and-conditions/
Links to other sites
Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working so we can fix it).
When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with the BWA.