The Suffolk Owl Sanctuary Privacy Policy
1. INTRODUCTION
The Suffolk Owl Sanctuary Ltd. is committed to protecting your personal information. It’s your information, it’s personal, and we respect that. We also want to maintain the trust and confidence of everyone of our valued supporters, as well as each visitor who uses our website. Secure server software (SSL) encrypts all information you input before it is sent to us. Furthermore, as required by the UK Data Protection Act 1998, the EU General Data Protection Regulation (2016/679) and the UK Privacy and Electronic Communications (EC Directive) Regulations 2003 (Data Protection Legislation), we follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access. Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you. Under the terms of the Data Protection legislation, we are required to explain to you how we will treat any personal data which we collect from you.
Who we are
We are The Suffolk Owl Sanctuary Ltd., registered in the UK Company number 4183127 and registered as charity number 1086565. We operate a comprehensive facility for the care & rehabilitation of owls from the region, and the promotion of owl conservation throughout the UK and beyond. Our address is The Suffolk Owl Sanctuary, Unit 22, Stonham Barns, Pettaugh Road, Stonham Aspal, Suffolk IP14 6AT Tel: 03456 807 897. You can message us via our website www.owl-help.org.uk Our registered office is: Suite 4, Stanmore Towers, 8-14 Church Road, Stanmore, Middlesex HA7 4AW
Our website www.owl-help.org.uk is owned and operated by us. If you have questions regarding the information we hold or it’s use, please contact our Data Protection Officer with your name, address and postcode by emailing privacy@owl-help.org.uk or by phone on 03455 331 376
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
When you contact us directly
Generally, we collect your information when you decide to interact with us by responding to Suffolk Owl Sanctuary communications, by mail, email or via our web site at www.owl-help.org.uk, by corresponding with us by phone or by giving us your information when visiting us in person.
This could be collected for a variety of reasons, for example when you telephone, write, email or ask us in person to process an adoption, donation, bequest or legacy; when you purchase a season ticket; when you fill in a gift aid form; when you participate in events or enrol on falconry or photo day courses, or ask us to keep you in touch about events and developments. We may also gather your information when we respond to your written enquiry or when you send us your details via our social media pages.
When you use our website
When you visit our website www.owl-help.co.uk, our web server automatically records your public internet protocol ('IP') address and also generates a log file. The log file records the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version. This information is collected to help diagnose and manage the website, to audit the geographical make-up of users, and to establish how they have arrived at the website which altogether help us improve our site and the way you use it. Like most websites, we use “cookies” to gather this information - small text files that our website transfers to your internet-enabled device to make future interaction faster and easier. Please see our cookies page for more details on how we use them.
If you give us personal information about a third party - for example, when you are purchasing an owl adoption for a friend or relation - we will inform them about how we intend to use their personal information and give them the option of not receiving communications directly from us in the future.
If your data is provided to us by another person (for example a gift of an Adoption) you will be advised from whom with the gift you receive.
When you support us via a third party
Your information may be shared with us by independent organisation, for example fundraising sites like Just Giving or Charity Checkout. These independent third parties will only do so when you have indicated that you wish to support The Suffolk Owl Sanctuary and their use of your data will be controlled via their privacy settings that control their use of your data. Please check the Privacy Policy of such trusted organisation when you provide your information to understand fully how they will process your information.
Your information is also shared if you make a donation to the Suffolk Owl Sanctuary via Owl Barn Limited, whom support us by distribution of our literature with their catalogues and through whom donations or adoptions may be made.
When you have given permission to another organisation to share your information
You may have provided permission for another company or organisation to share your data with third parties, including charities like ourselves for example when you buy a product, receive a service, register for an online competition or sign up with a comparison site.
When you have given permission using social media
Depending on the settings or privacy policies of you social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those accounts or services.
Publicly available information
We may combine information you provide to us with information available from external sources such as Companies House or that which has been published in articles/ newspapers. This is in order to gain a better understanding of our supporters that may help us improve our fundraising methods, products and services. The information we get from other organisations (such as the Fundraising Preference Service) may depend on your privacy settings or the responses you give, so you should regularly check them.
Competitions
We may collect your information from any competitions that we may run - for example the annual “S.O.S. Photo Competition”
CCTV
The Suffolk Owl Sanctuary has in place a closed circuit television (CCTV) surveillance system. This is used to ensure to monitor the safety of birds, staff, visitors and members of the public. At no point are images recorded or retained for any particular use. Signs are displayed at the entrance and further signs are placed around the Sanctuary.
3. THE TYPES OF INFORMATION WE COLLECT
The information we collect will consist of but not be limited to the following: Title; Name; Address; Telephone number if offered to us (this will only be used for contacting you for matters in hand and not used for cold calling); email address if offered; delivery address if different from your main address; If you represent an organisation, the name and address and other details of that organisation; and your communication preferences - do/do not phone, email, text SMS or post.
We collect records of your donation history and correspondence with us, or other details relevant to the reasons you may have given us for supporting The Suffolk Owl Sanctuary. This also includes information as to whether you are a taxpayer and have given us permission to claim Gift Aid when you have Gift Aided your donation. Payments made by credit card are encrypted after data entry and are not stored on our systems once used.
We do not usually collect any Special Category Data such as race, religion, biometrics or health data. S.O.S. recognises that from time to time it may contact individuals who are vulnerable for its fundraising campaigns - for instance, wheelchair access requirements - and flag them as appropriate on the contact’s record.
It is our policy that your information is private and confidential. Accordingly, the personal information you provide to us is stored in a secure location and is accessible only by designated staff.
4. WHY WE COLLECT YOUR PERSONAL INFORMATION & HOW WE USE IT
We use the information held about you in the following ways:
For S.O.S. Supporters
• For administration purposes - for example we may contact you regarding an adoption and or donation you have made, to check the details that we hold about you are correct or the event you have registered for.
• To provide a service to you, such as adopting an Owl.
• To code transactions against your supporter record on our databases so that we can keep a record of the financial support you have given us, for example, dates and values of previous donations.
• To carry out our charity obligations and to provide a service or fulfil a contract with you.
Where we have justifiable reason (which includes legal obligations or legitimate interest) we may contact you to:
• To keep a note of your preferences on what and how you want to engage with The Suffolk Owl Sanctuary
• To analyse the personal information we have collected and combine it with other information to create a profile of your interests and preferences so that we can understand our supporters better. This allows us to make appropriate requests to our supporters who may be able and willing to give more than they already do.
• To analyse the likely and actual results of fundraising campaigns.
• To raise funds - we may send you information about how you can support The Suffolk Owl Sanctuary - for example, an invitation to take part in an event or challenge.
• To keep you up to date with how your support is helping the Sanctuary
• To invite you to events or to request your support for particular campaigns that we are running.
• To provide information you have requested about ways to support the Sanctuary, our services and our campaigns.
• To hold records that we are legally required to keep - for example, checking your Gift Aid status so that we meet HMRC and other regulators’ compliance requirements.
• To contact supporters who haven’t given in a while to ask them if they wish to donate once again.
• To record any contact we have with you.
• To prevent or detect fraud or abuses of our website and enable third parties to carry out technical, logistical or other functions on our behalf.
• To analyse and report on the number and nature of contacts with the organisation.
Payment Processors
All our card payment transactions are handled through our payment services providers Firstdata, Worldpay and Sage Pay. These transactions are processed are subject to the privacy policies and practices of each individual company. We only share information with our payment processors to the extent necessary for the purposes of processing your payments or when dealing with complaints and queries relating to them.
Third-party service providers
We rely on a third-party service provider to perform business operations on our behalf in order to fulfil our contract with you. In so doing, we may need to share your personal information with them in order to perform the services we request, and we require that they protect this information and not use it for any other purpose.
The third-party processor we use are Sunline Direct Mail Ltd. They process name, address and mailing preference details only to enable them to mail out our postal communications on our behalf through Royal Mail and any other recognised mail carrier.
For other people with whom we work
When you work for organisations with whom S.O.S. engages or wish to engage - for example, in staging special events - to provide you with information about our work or our activities when inviting you to work with us.
For all people with whom we engage
The following purposes are relevant to all with whom we engage:
• For internal record keeping, including the management of any feedback or complaints.
• To ask for your help in completing surveys about The Suffolk Owl Sanctuary, our work & and the promotion of owl conservation throughout the UK and beyond.
• To ensure that content from our site is presented in the most effective manner for you and for the electronic devices that you use.
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• As part of our efforts to keep our site safe and secure and to detect fraud and other abuses of our site.
We don't collect Special Category Data such religion, biometrics or health data about those we engage with unless there is a clear reason for doing so. This could be participation in a fundraising event where we need information to ensure we provide you with appropriate facilities or support to enable you to participate in an event or take up a volunteering position with the Suffolk Owl Sanctuary.
Applying for a job or volunteering position with The Suffolk Owl Sanctuary
We will collect data about you, both personal data (such as your name and contact details) and also sensitive personal data (such as information in your CV). The personal data and sensitive personal data will be stored, processed, used and disclosed by us in the following ways:
• To facilitate the recruitment process
• To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
• To answer your questions and enquiries
• To third parties where we have retained them to provide services that we or you have requested, including references, qualifications and criminal reference checking services, and verification of the details you have provided from third party source, psychometric evaluation or skill test
• To use your information on an anonymised basis to monitor compliance with our equal opportunities policy
The Suffolk Owl Sanctuary Limited is not responsible for the privacy notices and practices of other websites even if accessed using links from www.owl-help.org.uk and recommends that you check the policy of each website you visit and contact its owner or Data Protection Officer if you have any concerns or questions. Despite all our precautions, no data transmission over the internet is 100% secure. So, we cannot guarantee the security of any information, which you disclose to us and so wish to draw your attention to the fact that you do so at your own risk.
5. THE LEGAL BASES WHICH ALLOW US TO USE YOUR PERSONAL INFORMATION
The legal basis that we rely on for using your personal information will depend upon the circumstances in which we collect and use it, but will in most cases be because:
• It’s necessary to carry out for the performance of a contract with you; For example, processing an adoption of an owl at you request.
• It’s necessary in order for us to comply with a legal obligation; e.g. we are required by law to keep records of gifts that are given to us with Gift Aid for 4 years.
• It’s in our legitimate interests to do so.
This means the interest of our organisation in conducting and managing our affairs to enable us to give you the best support and services and the best and most secure experiences.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you by getting in touch with us by emailing our Data Protection Officer on privacy@owl-help.org.uk or phoning 03455 331 376 with your title, name and postcode.
The legitimate interest to send you direct mail
Unless you tell us not to, we will rely on our legitimate interest as reasons for sending you direct mail.
From time to time, we would like to post you updates about our work and how you can support us, including fundraising activities and research. As a charity operating a comprehensive facility for the conservation, care & rehabilitation of native wild owls and other birds of prey, we rely upon members of the public donating money to achieve these objectives. Most of our income is obtained through contacting people using personally addressed mail with informative and educational material that inspires them to give to our cause. Therefore, to be able to raise funds, we believe we have a legitimate interest to contact our supporters and potential supporters. Without those supporters and the money raised through Direct Mail fundraising, the charity would be unable to fulfil it’s objectives. You have the right to ask us to stop communicating with you at any time.
The legitimate interest to process your information
We hold the minimum of personal information about you to achieve
• Contacting you by postal mail for administrative purposes. For example, we may need to contact you to
• Sending you postal communications and updates
• Enhancing, modifying, personalising and improving our services and communications with our supporters.
• Improving security of our websites and systems.
• Preventing transaction fraud on our website.
• Processing your donations
• Fulfilling online transactions
• Delivering your requirements
• Reviewing your personal information to ensure that our communications are relevant to you.
• Answering any questions that you may have.
The above list of examples are on the basis that the processing will not harm your rights and interests as an individual. You can tell us that you’d like us to stop at any time by phoning 03455 331 376 or emailing privacy@owl-help.org.uk with your title, name and postcode.
Contacting you via email
Suffolk Owl Sanctuary will always ask for your consent before we communicate with you for certain purposes by email. For example, we will only email you about our fundraising activities if we have a record of your recent and freely given consent to do so.
6. CHILDREN
In some circumstances, with consent, we may collect and process the personal information of under 18s. We will only ever collect the information we need and for the purpose it was collected. We will always try to gain consent from whoever holds parental responsibility for the child. This information may be collected for:
Cobweb Club Membership
The parents or legal guardians are asked to register for family membership to the Cobweb Club, for which benefits include a free club badge, free copies of the regular Junior Newsletter along with two free Admission Passes for their un-named offspring.
Animal adoptions
Where a child has been given an animal adoption as a gift, we collect their name and address to enable us to fulfil the order. We don’t use the child’s details for any marketing communications, although a child with an animal adoption may receive their renewal invitation (under the contractual lawful basis).
Family and Child Annual Passes
Children under the age of 16 are included in a family annual pass, and child “Junior” annual passes are available to everyone between the ages of 4 to 16. We do not collect any details of the child. All correspondence is made with the Parent/Legal Guardian of the child.
Photo Competition
The Suffolk Owl Sanctuary holds an annual Photo Competition in which there is a junior category open to children aged 17 and under. These are invited to participate but the data collected will consist of the child’s name only together with the contact details of the parent/guardian.
7. HOW WE PROTECT YOUR DATA
The Suffolk Owl Sanctuary is committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected from unauthorised access and improper use e.g. our network is Firewall protected.
We ensure that there are appropriate technical controls in place to protect your personal details in accordance with current data protection legislation. We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.
As part of the services offered to you through the Suffolk Owl Sanctuary website, the personal information you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of the computer servers used to host the website are located in a country outside of the EEA. If The Suffolk Owl Sanctuary transfers your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this privacy notice.
The Suffolk Owl Sanctuary may transfer your information to organisations who host their data in the United State such as Facebook, Twitter or Google. Please note however that the USA has weaker data protection laws than those of the EEA and therefore we will ensure that only organisations who are part of the EU privacy shield initiative will handle your personal information. More details on this certification can be found at www.privacyshield.gov/welcome
Your debit and credit card information
If you use your credit or debit card to donate to us or pay for an adoption or donation online or over the phone, we will ensure that this is done securely. We do not store credit or debit card details following the completion of your transaction. All card details and validation codes are securely destroyed once the payment or donation has been processed. Only staff authorised and trained to process payments will be able to see your card details.
8. HOW LONG WE ARE LIKELY TO KEEP YOUR PERSONAL INFORMATION
We will hold your personal information for as long as is reasonably necessary for the purposes set out in this privacy notice and to fulfil our legal obligations or charity reason to do so. For those individuals working for other organisations we will retain your data for as long as we have a working relationship with you at that organisation or any other organisation which is engaged in work which is relevant to our activities.
We will not keep more information than we need: the retention period will vary according to the purpose. In all cases, our need to use your personal information will be re-assessed on a regular basis, and information which is no longer required for any purposes will be disposed of. Where your data is no longer required we will ensure that it is disposed of securely.
If you ask us to stop sending direct marketing communications or other information to you, we will keep a record of your contact details and appropriate information on a Suppression List to enable us to comply with your request not to be contacted by us in future.
Where you contribute material to us, e.g. in response to a particular campaign, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of collection.
For further information about how long we will keep your information, please contact the Data Protection Officer using the contact details outlined in this notice.
9. YOUR RIGHTS & CHOICES
We have tried to make it easy for you to access and amend the personal information that we hold on you, or to request that we stop contacting you. It’s your data and we want to make sure you feel in control of it.
Under the Data Protection Act 1998, or the General Data Protection Regulation 2018 you have the right to:
1. Ask us to restrict / stop using your personal information for marketing or other purposes at any time. In this event we will remove your details from our listing, although we will keep your name on our internal suppression list to ensure that you are not contacted again.
2. Ask us to remove the personal information we hold about you from our database.
3. Request full details of the personal information we hold about you and amend or correct it as appropriate.
4. Every promotional email we may send to you will include details on how to unsubscribe from future communications and refer you to our Privacy Policy.
You can contact Suffolk Owl Sanctuary about any of the above by contacting our Data Protection Officer as per the details given below. Please provide your title, surname and postcode together with a description of the information you wish to access, amend or delete.
By phone:
Data Protection Officer: 03455 331 376
By Post:
The Data Protection Officer,
Suffolk Owl Sanctuary,
Unit 22, Stonham Barns,
Stonham Aspal,
Stowmarket, Suffolk
IP14 6AT
By Email: privacy@owl-help.org.uk
You have the right to lodge a complaint with the supervisory authority of GDPR, The Information Commissioner’s Office at www.ico.org.uk
10. Updates or Changes to the Suffolk Owl Sanctuary Privacy Policy and Further Information
This notice was updated in May 2018. It may be updated on this page to take into account changes at The Suffolk Owl Sanctuary Limited or to reflect changes to regulation or legislation. Please check back from time to time.
For further information on data protection regulations and laws can be found at ico.org.uk/for-the-public and on fundraising regulations at www.fundraisingregulator.org.uk/code-of-fundraising-practice