Privacy Policy

Privacy Policy

This privacy policy sets out how the Wild Trout Trust (WTT) uses and protects any information that you provide to us.

The WTT is committed to ensuring that your right to privacy and confidentiality is protected. Any personal identifiable information (PII) by which you can be identified is regulated by the Data Protection Act (and from 25 May 2018, by the General Data Protection Regulation). You can be assured that the WTT will only use your information in compliance with these laws and accordance with this privacy policy.

The WTT may change the privacy policy from time to time and will always endeavour to let you know that changes have been made. But you should check the WTT’s website www.wildtrout.org from time to time to review this policy to ensure that you are still happy with how the WTT manages and protects your information. This privacy policy is effective from March 2018.

Key details

The Wild Trout Trust is an independent registered charity in England and Wales (1162478) and Scotland (SCO46354) as well as a registered charitable company (03345901) in England and Wales.

The WTT is committed to the advancement of public education and the conservation of wild trout and their habitats, ecosystems, environment, river and water conservation and the management and creation of wild trout habitats for the public benefit.

The Data Protection Act requires every organisation that processes personal information to register with the Information Commissioner’s Office (ICO). The WTT is registered with the ICO as a Data Controller (ZA164604) as the WTT determines the purpose and manner in which your personal data is processed.

Any personal information provided or obtained by the WTT is used and processed only for the legitimate purposes of the WTT.

If you have any questions or concerns relating to how the WTT may use your personal information please contact:
Christina Bryant (Trust & Data Manager) at the WTT Office:
Email: Office@wildtrout.org Telephone: 023 9257 0985
By post to: Freepost WILD TROUT TRUST (this is a complete address and does not require a stamp).
(Registered address, 13 – 17 Paradise Square, Sheffield S1 2DE).

Personal information collected about you

We will collect the following information about you that will be held securely on a central database:

Name
Contact information including email address and telephone number
Demographic information such as postcode, communications & preferences
Donation types, amount, frequency, and supporter information
Membership information, subscription fees and gift aid
Banking details relating to regular donations or membership subscriptions
Project and conservation work
Donated items for auction/raffle/competition prizes, event attendance, products bought on our website

The information we collect is necessary for us to be able to provide you with the service you require, for the effective management of WTT and to fulfil our conservation work. Refer to the section below ‘What we do with your information’ for further details.

Where we collect your information from

The following are the different sources we may collect personal data about you from:

Directly from you. This is information you provide to us when you become a member, make a donation, sign up for one of our events, purchase products from our online shop, register to take part in our Annual Spring Auction which is hosted via a sub-domain of www.wildtrout.org — www.auction.wildtrout.org.
Indirectly from you. You may give us your information indirectly when you contribute to WTT via fundraising sites like Just Giving or Virgin Money Giving. These independent third parties will pass your data to WTT where you have indicated that you wish to support WTT and have given your consent or it is a necessary part of completing a contract with you.
From an agent/third party acting on your behalf. We may obtain information about you from a third party in relation to conservation projects and other interest of WTT.
When you access WTT’s social media. We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.

https://www.facebook.com/policy.php
https://twitter.com/en/privacy
https://www.whatsapp.com/legal/#privacy-policy
https://www.linkedin.com/legal/privacy-policy

Through publicly available sources. We may use the following public sources:
- Newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies House.

By Reference or word of mouth. For example, you may be recommended to us by a friend or a family member may purchase a product or donate to WTT on your behalf.

What we do with your information

Project and Conservation work: We collect information about individuals who request our support with project or conservation work relating to the habitats and ecosystems of wild trout. This is collected for the purposes of understanding your needs and requirements better, so that we can communicate with you and others involved with the project and where we are able to, to provide the service and support that you require.

Supporters of the Wild Trout Trust: As a charitable organisation we rely on a range of financial and non-financial support to help further our conservation work. This support can come in many forms from individuals making personal donations of money, goods and time through to organisations donating goods or services that we can use to further our conservation efforts. The information we collect on our supporters helps the WTT to further its objectives through raising awareness of our charitable nature, conservation work and fundraising initiatives.

Members of the Wild Trout Trust: Individuals are invited to become a member of the Wild Trout Trust in support of our work. Membership is through annual, monthly or one-off life subscription that brings with it many benefits, from the annual magazine, Salmo Trutta, regular newsletters and invitations to WTT events. Information is collected on our members for the purposes of managing membership subscriptions.

What we do with the information we gather:

Internal record keeping, accurate accounting and financial reporting and compliance purposes
Processing of donations, payments, membership fees
Reporting on conservation projects and support provided
To contact you in response to a specific enquiry, compliment or complaint
Promotional awareness and fundraising
We may use the information to improve our products and services that we provide
We will use your information, where you have consented for WTT to do so, to send SMS Text alerts to you to remind you that our annual Spring Auction in live.
We may periodically send promotional and fundraising emails about new products, special offers or other information which we think you may find interesting. However you will need to have given consent to the WTT for this purpose.
We may use your email address to contact you for non-fundraising purposes that relates to your membership, to respond to your questions or queries or to discuss conservation projects with you.
We respect your right not to receive fundraising postal communications. If you do not wish to receive these please contact Christina Bryant at office@wildtrout.org or 023 9257 0985.
We may use your information for statistical reporting purposes, archiving for historical purposes.
We are obliged to process our information in compliance with any lawful request made by order or the court or under police warrant.

Our legal basis for processing your information

For anyone using our service, support, advice or guidance (e.g. our publications, events and support with project or conservation work), our processing is necessary for our legitimate interests in that we need the information in order to provide these services to you (e.g. to administer your membership benefits).

WTT will only contact you for marketing purposes — for example keep you up to date on our work, or let you know of ways in which you can support that work — where we have your consent or we are otherwise allowed to do so. Refer to the section below ‘Fundraising Communications’.

If you notify us of any health or disability requirements then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.

Consequences of not providing your information

If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, it will be very difficult for the WTT to provide you with the service, support, advice or guidance or to work collaboratively with you for the conservation of wild trout and their habitats.

For our members and those who donate to further our work it is very important to us that we have access to their information so that we can thank them accordingly, show our appreciation of their valuable support and keep them up to date with how their support is helping the WTT’s conservation efforts.

The WTT must also have access to some of your information in order to operate and to comply with legal obligations.

How long we keep your information for

How long we keep your information will depend on the purpose or purposes for which we use it. While you are a member of WTT, a donor, or support through online auctions and other activity, a visitor to our website or engaged with WTT for conservation and project work, we will only retain your information for as long as is necessary for those purposes and to comply with statutory or regulatory retention periods. For example, we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules.

If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

Fundraising communications

It is in the Wild Trout Trust’s legitimate interest to, from time to time, send postal communications to supporters, members and others on the database with information about our conservation efforts for wild trout and their habitats and to raise awareness of our charitable nature (unless those individuals tell us not to).

These communications we hope will be of interest to you and may include details of our fundraising events, information about how to become a member of the WTT or to ask for donations and support for particular projects or appeals.

To comply with additional regulations that govern electronic fundraising communications we will need your consent to send you certain communications by email. We may request these from you to enable more cost effective and quicker communications to occur. All emails of a fundraising nature will carry an unsubscribe link or a way that you can use to stop emails.

We respect that some individuals may prefer not to receive communications of a fundraising nature. Therefore anyone who informs the WTT that they would prefer not to receive communications of a fundraising nature, or who do not consent to fundraising communications by email will be removed from our mailing list. You can start or stop these communications at any time by emailing the WTT Trust & Data Manager, Christina Bryant, at office@wildtrout.org or by calling 023 9257 0985.

It is important to note that rules and regulations, as described above, only relate to fundraising communications. This means that that we may still communicate with you by post, telephone or email for non-fundraising requirements where there is a need to contact you with regard to a specific issue and to respond to you appropriately. For example to manage your membership details, to provide you with information that you have requested or to communicate with you about a project that you are involved with or have an interest in.

The WTT works closely with a print and mailing house for the purposes of cost effective communications. They support the work of the WTT and provide their services under contract and pursuant to a non-disclosure agreement that protects your privacy and information security.

What we will not do with your information

The WTT respects your rights under data protection laws and takes our obligations seriously. Any information provided to the WTT is used and protected by the WTT for the WTT’s own legitimate purposes. Your rights to privacy, confidentiality and information security are highly important to us and upheld by us. Your support is extremely important to the WTT so we do not and will not share, swap, or sell your personal information with any other organisation for their own purposes.

We will not use your information for a different and non-compatible purpose to those described above or those that you would not reasonably expect. We will always let you know at the time of capturing your information if our intended purpose is different to those described above.

We do not carry out automated decision making or automated profiling.

Information sharing

The WTT will share your information for its own purposes and only where necessary, with:

Conservation Officers for project and conservation work
Print and mailing houses for cost-effective communications
Organisations that support our conservation activity like the Environment Agency
Service providers and associated organisations
Trust agents and employees

Any sharing will be carried out under formal non-disclosure agreements and only after due diligence processes have been followed to ensure that those we work with support our aims and objectives.

Non-disclosure agreements are designed to protect information security, your confidentiality and set strict obligations as to the control and use of your information. Any information that is shared is secured through security protocols such as encryption and secure file transfer portals.

We never have and never will share, swap or sell your personal details to any organisation for their own marketing purposes. Your privacy and confidentiality is paramount to us and we will only use the information that you provide for the WTT’s own purposes.

Information security and how we store your information

We are committed to ensuring that your information is secure and that your right to privacy and confidentiality are protected. We take information governance and security seriously and have technical and organisational measures in place that include ensuring all antivirus, antispam and software packages are up-to-date, correctly configured firewalls, encryption, secure file transfer protocols, Trust policies, processes and staff training to manage and protect your personal information in order to prevent unauthorised access, unlawful processing, accidental loss, damage, destruction or disclosure.

All information you provide to us is stored securely by WTT and governed by IT Security Policy and Procedures. Your information remains under the control of WTT at all times. You have the right to access your information at any time. Refer to section below ‘Your legal rights’.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us online; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

Where possible, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed. You can obtain a copy of these safeguards by contacting us.

Website cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive, smart phone, tablet or other device and are used to improve your online experience by almost every website including ours. This is why it is important to understand how cookies work, what they are for and when they are being used.

Once you agree, the cookie file is added to your computer and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

At the WTT we use cookies for a variety of reasons, such as to monitor how many people have visited our website and tracking items in the WTT shopping system. More information about cookies can be found at www.allaboutcookies.org

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. The cookies we use in no way give us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

You can manage your cookie preferences for our website or any other websites by using your browser settings. Your browser’s ‘help’ function will show you how to do this. However, please remember that cookies are often used to enable and improve certain functions on our website. If you chose to switch certain cookies off, it could affect how our website works on your device.

Your legal rights

Individuals have specific rights contained within data protection laws that relates to their personal information. These rights can be enforced against any organisation, from any sector, that holds your information. This section will detail what these rights are and how you can exercise them.

You have the right to be informed of how and why your information is being used and who it is being shared with. This right relates to the first data protection principle of fair and lawful processing and the second data protection principle that relates to processing personal information for specified and lawful purposes. Both of these principles obligates organisations to be open, honest and transparent with what and how they use personal information.

The WTT has published this Privacy Policy to detail how and why we use your information and what we will do with it. This privacy policy is available from our website and on request. The WTT will also endeavour to place data protection statements on all documents that capture or ask for your personal information that draws your attention to how your information will be used as well as how to obtain a copy of this policy.

You have the right to access information about you. This is called a Subject Access Request. This means you can have a copy of your personal information held by the WTT. If an exemption is being relied on to restrict your right to access specific details that contain your information, you are entitled to know which exemption applies. There is no charge for a Subject Access Request and the WTT must provide you with a copy within 30 days.

You have the right to have any incorrect or inaccurate information about you rectified or erased from our records. If we are holding information about you that you know or feel is incorrect you have a right for this to be corrected.

You have the right to be forgotten. This means you have the right to ask the WTT to delete or remove your information from our systems where there is no lawful reason for its continued processing.

You have the right to restrict processing of your information. For example you can request that we do not use your information in a way that will cause you any distress such as the publication of your photograph on our website or in our magazine or newsletters.

You have the right to withdraw consent. If you have given your consent to us using your personal data for fundraising communications, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). Refer to the section above ‘Fundraising Communications’.

You have the right to object to automated decisions and profiling. This right relates to decisions being made about you by automated or mathematical reasoning applied by a computer. There is no human input to the decision making process. This is quite common for online credit card applications where the decision is based upon an algorithm. The WTT does not use this kind of technology.

You have the right to data portability. This means you have the right to move your information from one database to another. For example you could ask to move all of your personal data from one utility provider to another.

There are other more general rights that you have within the law, these are:

The right to compensation for distress caused
The right to complain to the Information Commissioner by calling 0303 123 1113 or visiting the ICO’s website https://ico.org.uk/concerns/
The right to privacy and confidentiality and for your information not to be disclosed without your knowledge or consent.

If you have any questions or queries relating to this privacy policy or any of your rights detailed above please contact the WTT Trust & Data Manager, Christina Bryant, by email at office@wildtrout.org or by calling 023 9257 0985.

Our lawful obligations

All organisations that process personal information are under strict obligations that govern how they use and process personal information. Predominantly these are found within the data protection principles:

Fair and lawful processing. This means we need to tell you about how and why we collect and use your information. The WTT does this through data protection statements and privacy notices.

Specified and legitimate purpose(s). This means that we need to be clear, honest and transparent as to the purpose(s) that we will use your information for. This is also achieved through the use of data protection statements and privacy notices.

Adequate, relevant and not excessive. This relates to the capture of information about you not being excessive for the intended purpose. For example asking for your banking details when they are not required would be excessive.

Accurate and where necessary up to date. This relates to our obligations around the management of your information.

Not kept for longer than necessary. This principle means that the information held about you cannot be held indefinitely. Your information can only be retained for the purpose(s) required and to comply with certain other legal obligations. For example tax laws requires information to be retained for seven years. The WTT will retain your information to conform with legal requirements and for as long as is justifiable for the management and historical account of the WTT’s work.

Appropriate security against unlawful and unauthorised processing. This obligation means that organisations are under a lawful duty to protect your information. Information security comes in different forms from physical security, technical and organisational measures to restrict access to your information and protect it from unlawful or unauthorised disclosure.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

Postal communications of a fundraising nature will be sent to you under the legitimate interest of the WTT. Refer to the section above ‘Fundraising Communications’. You can stop these communications at any time by emailing office@wildtrout.org or by calling 023 9257 0985.

The WTT will comply with your request without unreasonable delay, but please note that it may be difficult to stop communications that are in the process of being mailed.

Electronic communications of a fundraising nature (emails) require your consent before the WTT can lawfully send them. All emails of a fundraising nature will contain an unsubscribe link. You can stop these communications immediately by clicking on the link within the email.

Alternatively you can email office@wildtrout.org or call 023 9257 0985 and the WTT will stop all email communications of a fundraising nature without any unreasonable delay.

If you have previously agreed to us using your personal information for fundraising purposes, you may change your mind at any time by writing to us, emailing us at office@wildtrout.org or by calling 023 9257 0985.

You are entitled to enforce any of your legal rights and to make a complaint to the Information Commissioner’s Office. Refer to the section above ‘Your legal rights’.

If you believe that any information we are holding on you is incorrect or incomplete, please let us know as soon as possible. We will promptly correct any information found to be incorrect.

If you have any questions, concerns or complaints please contact the WTT Trust & Data Manager, Christina Bryant, by email at office@wildtrout.org or by calling 023 9257 0985.