This policy describes how and why 1851 Marine Trust uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information. We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it.
We are a charity with relationships with volunteers, supporters, companies, schools and researchers so we use personal information on a day to day basis in order to operate. Our use of personal information allows us to make better decisions, fundraise more efficiently and, ultimately, helps us to achieve our charitable aim to inspire and excite young people to better futures through sport and sustainability by providing them with the education and opportunities to become innovators of the future and stewards of the environment.
This policy is effective from 25th May 2018.
1. WHO WE ARE
1851 Marine Trust, a charitable incorporated organisation registered in England and Wales (Charity No 1158670), and our subsidiary STEM Crew Ltd, a company registered in England (Company no 10009114).
2. HOW TO CONTACT US
3. WHAT PERSONAL DATA DO WE COLLECT?
Your personal data (any information which identifies you, or which can be identified as relating to you personally for example, name, address, phone number, email address) may be collected and used by us. We’ll only collect the personal data that we need.
We collect personal data in connection with specific activities such as use of our STEM Crew website, interaction with our education and activity programmes (including Tech Deck visits, Roadshows and Go Sail) donations, volunteering, research, employment with us, etc.
You may provide us your personal data by completing forms on our website, by registering to use our website and STEM Crew website, participating in an event, subscribing to receive our newsletter or subscribing to other social media functions on our website or directly on a social media platform, donating to us, attending an event, entering a competition, promotion or survey or by corresponding with us (including by phone and email)).
The personal data you give us may include name, title, address, date of birth, age, gender, employment status, demographic information, email address, telephone numbers, personal description, photographs, CCTV images, attitudes, opinions, usernames and passwords.
Sensitive personal data
Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this type of sensitive data would be information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality or genetic/biometric information.
We only collect this type of information about participants in our activities or our supporters to the extent that there is a clear reason for us to do so, for example asking for health information if you are taking part in a sporting event organised by the 1851 Trust, or where we ask for information for the purpose of providing appropriate facilities or support.
Wherever it is practical for us to do so, we will make clear to you why we are collecting this type of information and what it will be used for.
Information you provide to us directly
You may give us your information directly. For example:
- Personal Details (name, date of birth, gender, email, address, telephone, social media identities)
- Financial information (payment information such as credit or debit card, or direct debit details, and whether donations are gift-aided)
- If you volunteer for us or apply for a job with us, information necessary for us to process these applications and assess your suitability (which may include things like employment status as well as any unspent criminal convictions or pending court cases that you may have).
- Information relating to your health and emergency contacts (for example if you are taking part in or attending an event, for health and safety purposes).
- Where you leave us a legacy, we will collect your next of kin information.
- Your opinions and attitudes about the 1851 Trust, personal activities and interest (e.g. marathon running, sailing, or STEM) and your experiences of the 1851 Trust.
- Links and relationships with our supporters, volunteers or members of staff including work colleagues and family members.
- Any other personal information that you provide to us.
Information you provide to us indirectly
Your information may be shared with us by third parties or created by your involvement with us, for example:
- independent event organisers, for example the London Marathon or fundraising sites like Virgin Money Giving;
- if you sign up as a volunteer for us through a Job Centre or external volunteering website;
- if you are a researcher and your information is shared with us by the principal investigator or institution.
- professional fundraising agencies;
- we 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 decided which of our communications are likely to interest you. The section below ‘Research and Profiling’ gives more details about how we use information for profiling and targeted advertising, including giving you more relevant digital content.
We also use information from the following sources:
In accordance with common website practice, we will receive information about the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, your IP address, time zone setting, browser plug-in types and versions, unique phone identifier (if you access our website via your mobile device), the terms you used to search our website, page response times, download errors, length of visits to certain pages, methods used to browse away from a page and why errors or a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us. We use Google Analytics to support our analysis of website visitors.
Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those services, for example when you publicly tag us in an event photo.
Information available publicly
We supplement information on our supporters with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of 1851 Marine Trust. For more information, please see our section on “‘Research and Profiling’ below.
4. CHILDREN’S PERSONAL DATA
When a child attends one of our events or school sessions we collect data including their gender, year group and school on a feedback form. Once this feedback form has been analysed, the personal data is deleted. No names or identifying characteristics are collected during this process.
Where a school provides disability and accessibility information for a group of children, this is recorded against their school booking however no identifying information is collected (i.e. name of the child requiring additional support) as this responsibility sits with the school teachers.
When a group of children or a child is taking part in our sailing programmes, they are required to complete an additional medical and parental consent form which is supplied by our third party watersports supplier. These forms are passed to the third party supplier via the 1851 Trust and held securely in accordance with the supplier’s privacy notice. The 1851 Trust does not hold any copy of this information. For information on the suppliers we use, please contact email@example.com
At our events and activities we may collect quotes and photographs of children for whom we have received consent to do so. This consent will have been provided by the parent or guardian to the school or organisation they visit us with. The quotes and photographs may be used by us to promote our programmes and for marketing and fundraising purposes. If any parent or child wishes to withdraw their consent for images to be used in our future materials after their activity, they may do so by emailing firstname.lastname@example.org
We are committed to safeguarding young people in accordance with our Safeguarding Policy and maintain current DBS clearances and safeguarding training for all 1851 Trust staff.
5. HOW WE USE YOUR PERSONAL DATA
As permitted by law
We will only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (from 25 May 2018)/UK Data Protection Act and Privacy of Electronic Communication Regulation.
Personal data provided to us will be used for the purpose or purposes outlined in any fair processing notice in a transparent manner at the time of collection or registration where appropriate, in accordance with any preferences you express. If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.
Your personal data may be collected and used to help us deliver our charitable activities, help us raise funds, or complete your order or request. Below are the main uses of your data which depend on the nature of our relationship with you and how you interact with our various services, websites and activities.
- provide you with the services, products or information you asked for;
- administer your donation or support your fundraising, including processing Gift Aid;
- keep a record of your relationship with us;
- respond to or fulfil any requests, complaints or queries you make to us;
- understand how we can improve our services, products or information by conducting analysis and market research;
- manage our events;
- check for updated contact details against third party sources so that we can stay in touch if you move (see “Keeping your information up to date” below);
- further our charitable objectives;
- register, administer and personalise online accounts when you sign up to products we have developed;
- send you correspondence and communicate with you;
- process applications for funding and for administration of our role in the projects we fund;
- administer our websites and to troubleshoot, perform data analysis, research, generate statistics and surveys related to our technical systems;
- testing our technical systems to make sure they are working as expected;
- contact you if enter your details onto one of our online forms, and you don’t ‘send’ or ‘submit’ the form, to see if we can help with any problems you may be experiencing with the form or our websites;
- display content to you in a way appropriate to the device you are using (for example if you are viewing content on a mobile device or a computer);
- generate reports on our work, services and events;
- safeguard our staff and volunteers;
- conduct due diligence and ethical screening;
- monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
- process your application for a job or volunteering position;
- conduct training and quality control;
- audit and administer our accounts;
- meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
- carry out fraud prevention and money laundering checks;
- undertake credit risk reduction activities; and/or
- establish, defend or enforce legal claims.
To tell you about our work and ask for your support
Your privacy is important to us, so we will always keep your details secure. We would like to use your details to keep in touch about things that may matter to you.
Our marketing communications include information about our latest projects and programmes, campaigns, work with schools and requests for donations or other support. Occasionally, we may include information from partner organisations or organisations who support us in these communications but we will never share your information with companies outside the 1851 Trust for inclusion in their marketing. (We may however share cookie data with third parties to help with our own advertising targeting). If you agree to receive marketing information from us you can change your mind at a later date.
We operate an ‘opt-in only’ communication policy. This means that, except as set out below, we will only send marketing communications to those that have explicitly stated that they are happy for us to do so.
However, if you tell us you do not want to receive marketing communications, then you may not hear about events or other work we do that may be of interest to you.
We may use information you have given us directly, as well as the type of activity you have been involved with, to tailor our communications with you about future activities.
We may sometimes use third parties to capture some of your data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and in line with the requirements set out in the GDPR.
We will always act upon your choice of how you want to receive communications (for example, by email, post or phone). However, there are some communications that we need to send. These are essential to fulfil our promises to you as a school key contact, volunteer, donor or buyer of goods or services from the Trust.
Marketing to young people and fundraising
We will not send marketing emails, letters or make calls to people under the age of 13. We will not send any marketing communications requesting donations to young people aged between 13 and 17 and will not profile anyone under the age of 18.
Events and fundraising
When you have asked for details of an 1851 Trust event, we will send you information including, where relevant, ideas for fundraising and reminders on key information about the activity.
Where you have signed up for an event with a third party (for example the London Marathon) and told the event organiser that you wish to fundraise for us, we may contact you with information and support for your fundraising for that event.
Where we have your permission, we may invite you to support our work by making a donation, buying a raffle ticket, getting involved in fundraising activities or leaving a gift in your will.
Occasionally, we may invite supporters to attend special events to find out more about the ways in which donations and gifts in wills can make a difference to specific projects and to our cause. We will also send you updates on the impact that you make by supporting us in this way, unless you tell us not to.
If you make a donation, we will use any personal information you give us to record the nature and amount of your gift, claim gift aid where you’ve told us you’re eligible and thank you for your gift. If you interact or have a conversation with us, we’ll note anything relevant and store this securely on our systems.
If you tell us you want to fundraise to support our cause, we’ll use the personal information you give us to record your plans and contact you to support your fundraising efforts.
If you’ve told us that you’re planning to, or thinking about, leaving us a gift in your will, we’ll use the information you give us to keep a record of this – including the purpose of your gift, if you let us know this.
If we have a conversation or interaction with you (or with someone who contacts us in relation to your will, for example your solicitor), we’ll note these interactions throughout your relationship with us, as this helps to ensure your gift is directed as you wanted.
Charity Commission rules require us to be assured of the provenance of funds and any conditions attached to them. We follow a due diligence process which involves researching the financial soundness, credibility, reputation and ethical principles of donors who’ve made, or are likely to make, a significant donation to the 1851 Trust.
As part of this process we’ll carry out research using publicly available information and professional resources. If this applies to you, we will remind you about the process when you make your donation.
If you’re a current or prospective major donor, we’ll give you a bespoke privacy notice with further details of how we look after your data. You can also find out more in the Research and Profiling section below.
We need to use your personal data to manage your volunteering, from the moment you enquire to the time you decide to stop volunteering with us. This could include: contacting you about a role you’ve applied for or we think you might be interested in, expense claims you’ve made, shifts you’ve booked and to recognise your contribution.
It could also include information about things happening where you volunteer and about your volunteering, including asking for your opinions on your volunteering experience.
We may also share this with funders to help them monitor how their funding is making a difference.
We may carry out research with our supporters, beneficiaries, staff and volunteers to get feedback on their experience with us. We use this feedback to improve the experiences that we offer and ensure we know what is relevant and interesting to you.
If you choose to take part in research, we will tell you when you start what data we will collect, why and how we will use it. All the research we conduct is optional and you can choose not to take part. For some of our research we may ask you to provide sensitive personal data (e.g. ethnicity). You do not have to provide this data and we also provide a ‘prefer not to say’ option. We only use it at an aggregate level for reporting (e.g. equal opportunities monitoring).
We may give some of your personal data (e.g. contact information) to a research agency who will carry out research on our behalf.
We know it is important to our supporters that we use our resources in a responsible and cost-effective way. So we may use automated profiling and targeting to help us understand our supporters and make sure that our communications and services are relevant, personalised and interesting to you, our activities and programmes meet the needs of our supporters, and we only ask for further support and help from you if it t’nd tes and programmesfrom locand photographs may be used by us to promote our programmes and or gurdian is appropriate.
To do this we may analyse how you interact with us and use both geographic and demographic information to let you know what’s happening in your local area and understand your interests.
We use specific tools to profile how you interact with us online, for example, Google Analytics. We use Google Analytics to collect information on the use of the 1851 Trust and STEM Crew website. Much of the information we collect is aggregated, however we may also collect some personal data for the use of personalising your experience, optimising our marketing campaigns, and to ensure the site is functioning as intended.
The personal information that is collect includes transactional information for Schools bookings, donations, STEM Crew website use, and event registrations. We also collect data on individual user activity when they create or log into their My National Trust account. This information take the form of an encrypted string.
What information do we collect?
After taking a supporter’s communications preferences into account, we use information we hold on them to research their potential to be a significant donor to 1851 Trust and collect additional details relating to their employment and any philanthropic activity. We may also estimate their gift capacity, based on their visible assets, history of charitable giving and how connected they are to 1851 Trust.
Which information do we use?
We use existing data from our own database and combine this with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of 1851 Trust. We only use reputable sources, where someone would expect their information may be read by the public. We avoid any data that we believe has not been lawfully or ethically obtained, and we do not use information sources which have not been broadcast or made public.
We’re committed to putting you in control of your data and you’re free at any time to opt out from this activity. To find out more, please contact 01489 587852 or email@example.com
6. RECRUITMENT AND EMPLOYMENT
In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including sensitive personal data, from job applicants and employees.
Such data can include, but isn’t limited to, information relating to health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it’s processed is given below.
Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.
Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.
Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, training and development, absence, disciplinary matters, e-mail address and telephone number.
Disclosure of personal data to other organisations
In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with one or more third party supplier.
To meet the employment contract, we are required to transfer an employee’s personal data to third parties, for example, to pension providers and HM Revenue & Customs.
In order to fulfil our statutory responsibilities, we’re required to give some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.
7. LEGAL BASIS FOR PROCESSING
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation and have been summarised below:
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via post, phone, text or e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner or Gambling Commission, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying something from us (for instance some branded merchandise or, in some cases, an event place), applying to work/volunteer with us, or being funded to undertake research.
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities 1851 Trust carries out with personal information. Some examples not mentioned under the other bases above where we are relying on legitimate interests are:
- analysis and profiling of our supporters using personal information we already hold;
- use of personal information when we are monitoring use of our website or apps for technical purposes;
- use of personal information to administer, review and keep an internal record of the people we work with, including supporters, volunteers and researchers;
- where you have signed up with us on a charity place for a third party event (for example a sponsored run not organised by 1851 Trust), sharing personal information with the third party event organiser so they can administer the event.
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way. We will conduct a Data Protection Impact Assessment before processing your data, each time we do so.
When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
8. HOW WE KEEP YOUR INFORMATION SAFE
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details. For example, our online forms are always encrypted and our network is protected and routinely monitored.
9. HOW LONG WE KEEP YOUR INFORMATION FOR:
1851 Trust has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations. For instance, we are required to keep some personal information for tax or health and safety purposes. If you’d like more information regarding how long we retain your data for, please contact the Data Protection Officer, firstname.lastname@example.org.
10. SHARING YOUR INFORMATION WITH OTHER ORGANISATIONS
As set out in the “Marketing Communications” section above, we will never sell or rent your information to third parties for marketing purposes. However, we may disclose your information to third parties in connection with the other purposes set out in this policy. These third parties may include:
- if you are a researcher, volunteer advisory panels, any joint funders of research, host institutions and external members of our committees;
- if you are a legacy giver, we may share information with co-beneficiaries;
- advertisers and advertising networks
- analytics and search engine providers;
- IT service providers.
Some of our suppliers run their operations outside the European Economic Area (EEA) – this may include a country which may not be subject to the same data protection laws as companies based in the UK. In these circumstances, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.
Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider this necessary, to protect the rights, property or safety of 1851 Marine Trust, its personnel, visitors, users or others.
We reserve the right to disclose your personal information to third parties if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets; and/or if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets.
11. KEEPING YOUR INFORMATION UP TO DATE
We want you to remain in control of your personal data. If, at any time, you want to update or amend your personal data, delete your STEM Crew platform account or marketing preferences please contact us email@example.com
12. YOUR RIGHTS
Under UK data protection law, you have rights over personal information that we hold about you. We’ve summarised these below:
Right to access your personal information
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, send a description of the information you want to see by post to 1851 Trust, The Camber, East Street, Portsmouth, PO1 2JJ or by email to firstname.lastname@example.org
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and, where applicable, correct any inaccuracies.
Right to restrict use of your personal information
You have a right to ask us to restrict the processing of some or all of your personal information in the following situations: if some information we hold on you isn’t right; we’re not lawfully allowed to use it; you need us to retain your information in order for you to establish, exercise or defend a legal claim; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.
Right to erasure of your personal information
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object to the use of your personal information
If we are processing your personal information based on our legitimate interests or for scientific/historical research or statistics, you have a right to object to our use of your information.
If we are processing your personal information for direct marketing purposes, and you wish to object, we will stop processing your information for these purposes as soon as reasonably possible.
If you want to exercise any of the above rights, please contact us on 1851 Trust, The Camber, East Street, Portsmouth, PO1 2JJ or by email to email@example.com
We may be required to ask for further information and/or evidence of identity. We will endeavor to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.
If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve. In the first instance please contact our CEO via firstname.lastname@example.org.
You also have the right to lodge a complaint about any use of your information with the Information Commissioners Office, the UK data protection regulator.
14. CHANGES TO THIS POLICY