Privacy Policy

We are required to provide you with this information under the General Data Protection Regulation (GDPR). This policy explains how we handle your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) and what you can do if you have any concerns.

For the purposes of data protection law, the ‘GWCT’ will be used to refer to the following jointly, as the Joint Data Controllers:

• Game & Wildlife Conservation Trust (charity no. 1112023 in England and SC038868 in Scotland. Company number 5579632. Our data controller number ZA220772).
• Game & Wildlife Conservation Trading Limited (registration number 01503620).
• Game Conservancy Events Limited (registration number 04662736).
• The Game Conservancy Trust (charity number 279968).
• Game Conservancy Scottish Research Trust (charity number SC015439).
• Allerton Research & Education Trust (charity number 1010814).
• Game & Wildlife Scottish Demonstration Farm (charity number SC045900).
• Game & Wildlife Scottish Demonstration Farm (limited company number SC492394).

• Write: GWCT, Burgate Manor, Fordingbridge, Hampshire SP6 1EF
• Call: 01425 652381
• Email: info@gwct.org.uk

When GDPR comes into force on 25 May 2018, the rules on processing personal data will switch from the Data Protection Act 1998 to the following provisions of the GDPR:

1. The processing is necessary for the performance of a contract. Examples of when this applies include: membership, when you purchase something from our online shop or purchase an event ticket we are required to process your personal data to send you these items.
2. It is in the legitimate interest of the data controller (the GWCT). You can tell us you would like to opt out at any time. We may need to process personal data for our legitimate interests (such as the management and administration of our charity and the improvement of our services) and that doing so will not interfere with your privacy rights. We use people’s data in ways they would reasonably expect and which have minimal privacy impact. Safeguards have been put in place to ensure we achieve the correct balance between our interests and yours. Examples of when this applies include: when you support us through donations and wildlife research surveys.
3. In line with the existing Privacy and Electronic Communications Regulations 2003 we will continue to seek your consent to electronic marketing. Examples of when this applies include: our weekly e-newsletter, the daily e-news round and our online surveys.

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, address, date of birth, email, telephone etc.) when you join as a member or supporter.
• Financial information (payment information such as credit/debit card or Direct Debit details, and your Gift Aid instruction).
• Details of your interests and preferences (such as campaigns or the ways you support us).

If you purchase GWCT membership as a gift for someone, join as a family, or are the parent of one of our youth supporters, your details will be recorded (as will the recipient’s) and your relationship to that person will be recorded.

• Your activities and involvement with the GWCT 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.
• 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 decide which of our communications are likely to interest you. Section 10 (How do we build profiles?) contains more information about how we use information for profiling.
• As explained in Section 16 (What about cookies and links or other websites?), 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 supporters (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.

Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and the GWCT.

We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and members. However, there are some situations where this may occur (e.g. if you have an accident at one of our events). If this does occur, we’ll take extra care to ensure your privacy rights are protected.

• If an accident or incident occurs on our property, 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 GWCT, 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.

1 Sensitive personal data (GDPR calls this Special Category Data) includes any of the following: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.

We use information:

• That you have given to us (e.g. your name, address, interests, event bookings, donations, shop purchases, complaints, bank account details, Gift Aid statement) on paper or electronic format).
• Provided via cookies on our website as explained in Section 16 (What about cookies and links to other websites?).
• We have collected from third parties as explained in Section 10 (How do we build profiles?).

In order to:

• Enter into, or perform, a contract with you (e.g. GWCT online shop sales and GWCT event tickets, GWCT advisory visit or course booking).
• Comply with a legal duty (e.g. financial information).
• Protect your vital interests.
• For our own (or a third party’s) lawful interests, provided your rights don’t override these.

We use personal data primarily to allow us to:

• Perform our contract with you.*
• To enable us to comply with legal obligations.**
• Pursue legitimate interests of our own or those of third parties***, provided your interests and fundamental rights do not override those interests.
• To provide you with information you have consented to.****

The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we will process your personal information, as well as indicating which categories of data are involved.

• Setting up new GWCT memberships.*
• Sending our membership renewals.*
• Sending you your members’ magazine three times a year by post.*
• Posting you a copy of our annual Review.*
• Sending you invitations to events by post.*
• Sending you invitations to events by email.****
• Collating names of people attending events.***
• Processing your entry forms for competition events (e.g. gun dog competitions and clay events).*
• Sending thank you letters by post.****
• Sending you weekly newsletters by email.****
• Sending you the daily news round.****
• Responding to queries emailed to our website.****
• Recording Gift Aid declarations.**
• Sending woodcock sponsorship details by post.*
• Recording your interests in volunteering at the GWCT.****
• Collating National Gamebag Census returns.****
• Collating Partridge Count Scheme returns.****
• Collating Big Farmland Bird Count returns.****
• Collating fox survey returns.****
• Collating mountain hare survey returns.****
• Recording Allerton Project training courses.*
• Confirmation of permission to access study sites.****
• Booking an advisory visit or attending a course.*
• Sending you appeal information by post.***
• Sending you appeal information by email.****
• Processing your donations.*
• Sending information about raffles by post.***
• Sending you information about raffles by email.****
• Processing your raffle ticket purchases.*
• Complying with health and safety obligations.**
• To conduct data analytics studies to review and better understand membership retention and attrition rates.***
• Sending you information about leaving a legacy by post.***
• Recording and processing donations (e.g. Direct Debits or Gift Aid instructions).***
• Performing our obligations under membership contracts.*
• Fulfilling orders for goods or services (whether placed online, over the phone or in person).*
• Recording your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this).****

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

We carry out research and analysis on our supporters, 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 and makes the GWCT a more effective organisation. Understanding our supporters, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications).

We 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 supporters, improve our organisation and carry out research. Further information on profiling can be found in Section 10 (How do we build profiles?).

We will never sell your personal data. We may contact you with information about our partners, or third-party products and services, but these communications will always come from the GWCT 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, your name and address will be shared with the delivery company in relation to:

• GWCT shop orders.
• GWCT Scottish Game Fair ticket purchases.
• GWCT members’ magazine mailing house.

However, these activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure.

Our marketing includes news and information. Examples include:

• Our charity, campaigns and conservation work.
• Our role in educating the public in conservation of the natural environment.
• GWCT benefits and offers.
• Volunteering opportunities.
• Appeals and fundraising (including donations and also competitions, raffles, etc.).
• Our events, activities and county groups.
• Products, services and offers (our own, and those of third parties which may interest you).
• Leaving a legacy.
• Taking part in projects (e.g. the Big Farmland Bird Count, National Gamebag Census, Partridge Count Scheme).

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.

The following are normally sent out by post but may also be provided electronically to those that have consented to receive electronic versions. Examples include:

• Members’ publications, including Gamewise, are sent to all our members (unless you specifically ask us not to) and you can choose to unsubscribe from general marketing communications. However, please be aware that member magazines do include advertisements, competitions and fundraising information.
• Project newsletters such as: National Gamebag Census, Partridge Count Scheme, Big Farmland Bird Count, fox surveys, woodcock surveys, curlew surveys, mountain hare surveys, etc.
• Updates about our events such as: the GWCT Scottish Game Fair, GWCT county group events and GWCT conferences and seminars.
• Fundraising activity such as: appeals, raffles and legacy mailings.
• GWCT shop offers and new products.
• Advisory Service: courses, events and services such as on-site visits and advice reports.

As a charity, we rely on donations and support from others to continue our conservation work. From time to time, we will contact members and supporters 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 GWCT will receive some of the proceeds).

You can decide not to receive communications or change how we contact you at any time. You can either exclude yourself from all marketing or specify removal from any combination of the following GWCT marketing activity:

• The weekly e-newsletter
• Big Farmland Bird Count
• Scottish Game Fair
• Appeals
• Events
• Raffles
• Shop
• Digital copies of the members’ magazine Gamewise
• Paper copies of the members’ magazine Gamewise
• Paper copies of the Annual Review
• The Woodcock Watch newsletter
• The morning e-briefing
• National Gamebag Census
• Partridge Count Scheme

If you wish to do so please contact us by:

• Email: info@gwct.org.uk
• Post: GWCT, Burgate Manor, Fordingbridge, Hampshire SP6 1EF
• Telephone: 01425 651024

This section explains how and why we use personal data to build profiles which enable us to understand our supporters, improve our relationship with them, and provide a better supporter experience.

• We analyse our supporters 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.
• We profile supporters in terms of financial, political 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 we may contact them to see if they wish to do so.

On occasion, we may also combine information about particular supporters 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 so that we know what material you are most likely to be interested in.
• We may also obtain information about you from other sources, much of which is available on public and private databases such as Mosaic and Acorn. We do this to enhance and fill in any gaps so that we can understand our supporters better, send you the most relevant communications, and target our resources effectively.

Examples of information we’ll obtain are details of other charities you may support, newspapers you read, shopping habits, financial products, leisure interests, and indicators of financial status such as house value. In some cases we will obtain likely indicators of interest or financial status based on your postcode rather than at an individual level. This information won’t be specific to you, but probable characteristics based on your postcode.

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 and supporters, or to identify trends or patterns within our existing supporter base. This information helps inform our actions and improve our campaigns, products/services and materials.

You may opt out of this profiling at any time by contacting the Data Compliance Manager at:

• GWCT, Burgate Manor, Fordingbridge, Hampshire SP6 1EF
• 01425 652381
• info@gwct.org.uk

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 13 we will require consent from a parent or guardian to process his or her personal data. This means that:

• If your child wants to have his or her name or picture featured in one of our publications, we’ll need you to confirm you’re happy for us to do so.
• 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.
• If we publish your child’s picture, photo or story, we’ll usually include their first name and age with it. We’ll need you to confirm you’re happy for us to do so.
• If they write an article or story for us, we might also include their surname alongside it. We’ll need you to confirm you’re happy for us to do so.

We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, use or disclosure of your personal information.

• 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.
• If you use a credit card to donate, purchase a membership or purchase something online we will pass your credit card details securely to our payment provider. Other payment methods (e.g. Apple Pay) are handled in a similar manner. The GWCT complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council.
• CCTV will only be viewed when necessary (e.g. to detect or prevent crime). The GWCT complies with the Information Commissioner’s Office CCTV Code of Practice, and we put up notices so you know where CCTV is in use.

The GWCT’s operations are based in the UK and we store our data within the European Union. Some organisations that 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. We check they are registered with Privacy Shield. Examples include:

• Our email distribution provider Mail Chimp
• Our members survey provider Survey Monkey
• Sometimes we store details on Google Drive
• Occasionally we transfer details by Dropbox
• Our Scottish Game Fair ticketing provider Red Box Tickets & Events
• Our online shop provider EKM Powershop

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. Examples include:

• Our members’ information is archived 3 years after they lapse.
• Major donor information is archived after 10 years of inactivity.
• Other supporter information is archived after 5 years of inactivity.
• Shop purchase information is archived 7 years after last purchase.
• Any personal data supplied as part of a wildlife survey may be stored in perpetuity to aid. long-term scientific analysis. However, findings will be aggregated when published to avoid any personal information being disclosed.

These are reviewed on a rolling annual basis by the Data Compliance Manager.

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 be informed about how we use your personal data.
• The right to access your personal data.
• The right 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 restrict the processing of your personal data.
• The right to object to your data being used for marketing and or profiling.
• Where technically feasible, you have the right to the data portability of the personal data you have provided to us which we processed.

To exercise these rights please contact the Data Compliance Manager:

• Write: GWCT, Burgate Manor, Fordingbridge, Hampshire SP6 1EF.
• Call: 01425 652381
• Email: info@gwct.org.uk

More information about your rights can be found on the Information Commissioner’s Office (ICO) website.

If you wish to make a complaint you can do so in accordance with the GWCT complaint policy.

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervising authority for data protection issues. Details of how to do this can be found at www.ico.org.uk.

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.

Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites. If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered by the GWCT Privacy Policy. 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 GWCT.

This policy will be reviewed by the GWCT Data Compliance Manager at intervals of no more than two years to ensure it remains up to date and compliant with the law.

This document was last reviewed on 8 May 2018.