Torbay Coast and Countryside Trust is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and can be confident about giving us your information.
We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.
1. Who are we?
Torbay Coast & Countryside Trust (TCCT) is an independent conservation charity that has been caring for over 1,700 acres of Torbay’s most precious natural spaces since 1999. We strive to manage, protect and enhance Torbay’s unique and precious natural heritage for now and for future generations. We aspire to ensure Torbay’s diverse natural environments remain healthy and rich in wildlife. We want residents and visitors alike to have opportunities to explore, enjoy and appreciate Torbay’s natural heritage without causing damage.
As a charity we seek to build lifelong relationships with people who care about Torbay’s precious and special coast and countryside. We rely upon the support of members and volunteers working alongside our staff to achieve our goals. We seek to nurture long-term support for our mission from within the local community and visitors through our ongoing commitment to protecting and enhancing Torbay’s natural heritage. We aim to conduct ourselves according to our core values, which include independence and integrity, delivery and results driven, respect for others, proactive communication and engagement and valuing and support staff and volunteers.
2. Our Commitment to your Privacy
TCCT and its trading subsidiaries hold and process data (including personal data and sensitive data) so that we can deliver our charitable mission as defined by our charitable objects and mission statement. This includes holding data, so that we can grow and sustain our valuable and vital community networks.
We collect, hold and process personal data to build and maintain relationships; to secure the resources we need to deliver our mission; to provide a strong evidence base for our work; to keep our staff, volunteers, supporters and service users safe and to meet our legal and contractual obligations.
We are committed to gathering and processing personal data with full regard for the General Data Protection Regulation (GDPR), and to the principles of personal choice and control, transparency, fairness and security. We always collect and process data on lawful grounds to meet the genuine needs of our organisation, but we do so with the highest regard for an individual’s rights and freedoms.
We only share information when it is absolutely necessary to meet our organisational needs and legal obligations and only with strict controls and data sharing and processing agreements in place. We will never sell personal data to third parties.
We are committed to keeping the personal details of our members and supporters safe. This Notice explains how and why we use your personal data, to ensure that you remain informed and in control of your information.
For more information about your rights with regards to personal data, please see the Information Commissioner’s Office (ICO) website. www.ico.org.uk
3. Key terms in this document
Any references to Torbay Coast & Countryside Trust, TCCT, the Trust, or to ‘we’ or ‘us’ in this and Related Policies refer to TCCT the charity – a registered charity in England and Wales (registered charity number 1077561) and to our wholly owned trading subsidiaries : Torbay Coast & Countryside Enterprises Ltd (Company No. 03855040 ) and South Devon Biomass Company Limited (Company No. 07121496).
We use the following key definitions to describe people mentioned in this document. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk)
• ‘Data subject’: this is you, one of our valued members and supporters. As the data subject, we respect your right to control your data.
• ‘Data controller’: this is us, Torbay Coast & Countryside Trust. With your permission, we determine why and how your personal data is used (as outlined in this document).
• ‘Data processor’: this is a person, or organisation, who processes your data on our behalf, with your permission. For example, this might be a mailing house who sends your event guides to you on our behalf. Due to the size of our organisation, it is more cost-effective to outsource ad-hoc and large-scale tasks like this.
When we work with other organisations or individuals in this way, we always set up a written contract with them to protect your data. The third parties we work with at no point ‘own’ your data, so you will never hear from them independently and they will always delete your data from their systems when they have completed the task in hand. We always send your data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.
4. Why do we collect your personal data?
We use your personal data to keep in touch with you.
We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The ICO refers to this as a ‘lawful basis’. Further information about why we collect your personal data is outlined below.
a) To administer your Torbay Coast & Countryside Trust membership
We collect your personal data to administer your membership, which may involve:
• Sending you membership information when you first join us or at renewal;
• Processing your Direct Debit subscription payments, if you have chosen this payment process;
• Sending you information when your membership is due for renewal;
• Getting in touch should there ever be any issues processing your subscription payment
• Keeping your personal details up to date
The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.
b) To send you items purchased from us
We collect your personal data to send you:
• items you have purchased
• information about events you have booked onto
The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.
c) To administer and acknowledge gifts and donations you have made to us
We collect your personal data to:
• process any donation payments
• acknowledge receipt of any donations and to claim gift aid when you have indicated that you would like your donation to be gift aided
The ICO define the lawful basis for processing your data for these purposes as ‘contractual’
d) To deliver services that you have asked for
We collect personal data to:
• provide funded or chargeable services – educational activity etc.
• process any payments related to these services
• process any monitoring information related to these services
The ICO define the lawful basis for processing your data for these purposes as ‘contractual’. Where it is a contractual requirement to share your personal data with third parties – or any regulatory bodies – we will always make this clear when we first collect information from you.
e) To send you information about our work and ask for your opinion
We also collect your personal data so that we can send you information about our work that we consider will be of interest to you. This includes fundraising appeals, events, campaigns, volunteering opportunities, job and trainee opportunities at the Trust, membership, our projects, activities going on in your area, services, products, newsletters, feedback questionnaires, competitions, raffles, café events, Occombe Festival and other activities.
This information is in addition to that outlined in sections a), b), c) and d) and is defined as ‘direct marketing’ by the ICO.
f) Joint and family membership
If you are a ‘joint’ or a ‘family’ member of TCCT, we will address communications to all those listed on your membership. If you wish to update this at any point, please let us know.
g) Gift membership
If your TCCT membership was purchased as a gift, we will use the address provided by the purchaser to send you information about our work in the post. This will include a ‘renewal letter’, which we will send you when your membership is due to expire, to see if you would like to continue supporting our charity.
h) When your membership has ended
Unless we hear from you directly, we will continue to send you information about our work for up to 12 months after your membership has ended. This is just in case your support was cancelled accidentally, by for example changing your bank account details, and you wish to update your details with us.
Your personal data also helps us to get to know you better and to develop a ‘profile’ of you on our secure supporter database. This ‘profile’ enables us to send you appropriate information in a timely and relevant way, to suit you. For example, keeping track of the donations you make to our organisation helps us to send you information about fundraising appeals that we feel you would like to hear about. As defined by the ICO, we use two different lawful bases for processing your data for ‘direct marketing’ purposes:
i) Legitimate interest
This is where we have identified a genuine and legitimate reason for contacting you, which crucially does not override your rights or interests.
We use legitimate interest to send you the information listed above by post or telephone (if you have given us your telephone number and consent to contact by this means).
j) Opt-in consent
This is where you have given us express permission to contact you by particular communication channels.
We use opt-in consent to send you the information listed above by email, telephone (if you have given us your telephone number and consent to contact by this means)
We respect your right to update the way we get in touch with you about our work at any time.
k) To enable you to volunteer with us
If you are a TCCT volunteer, we collect and hold your personal data so that we can keep in touch with you about, for example:
• our current work;
• changes to planned volunteer work programmes that you may be taking part in;
• the positive impact you have on our work, by sending you our newsletter or similar;
• events relevant to volunteers (e.g. training opportunities, ‘thank you’ events, informative events);
• new volunteer opportunities;
• thank you letters and information relating to our volunteer awards;
• Christmas cards, get well cards, etc.;
• feedback about your volunteering for example volunteer satisfaction surveys and exit reviews; and
• your feedback about our work.
As defined by the ICO, the lawful basis for processing your data for these purposes is ‘contractual’ (where administering your volunteer record) and ‘legitimate interest’ (when sending you information about our work).
If you are participating in a volunteering programme or activity that is supported by an external funder, we sometimes need to share your data with them so that they can check that their funds are being spent properly. The lawful basis for processing your data in this case would be ‘contractual’ and we will always make this clear when we first collect information from you.
l) To let you know when a product or service becomes available if you have asked to be notified when.
5. What kind of personal data do we collect? How do we collect it?
a) Basic information
We will usually collect basic information about you, including your name, postal address, telephone number, email address and your bank details (if you are supporting us financially).
Most of the time, we collect this data from you directly. Sometimes this is in person; other times, it is over the telephone, in writing or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (but only where you have explicitly given permission for such information to be shared with us).
b) Getting to know you better
We also collect information about you that helps us to get to know you better. This may include:
- records of donations you’ve made towards fundraising appeals;
- your preferences of how you would like us to contact you;
- ways you’ve helped us through volunteering your time;
- records of events you’ve attended, or campaigns (such as crowd funding) or activities that you’ve been involved in;
- details of the types of information about TCCT or our work about which you are interested in receiving more information.
Sometimes we will collect other information about you such as your date of birth and gender. When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission.
Once again, most of the time we collect this data from you directly. Occasionally we also obtain data from external sources. For example, we may check against Royal Mail’s National Change of Address database to ensure that the address we have listed for you is up to date. We know moving to a new house can be a busy time and appreciate that you don’t always have the chance to send us your new address. By undertaking this exercise, we can update your record without you needing to get in touch.
If you do not wish your data to be collected in any of these ways, or have questions about them, please contact us.
Other ways in which we collect personal data to get to know you better include:
c) Our website
Our website uses ‘cookies’ to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.
Our cookies help us:
• Make our website work as you’d expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you
d) Sensitive personal data
We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and members.
When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission. In these situations, we collect the data from you directly. Generally, we anonymise sensitive personal data wherever possible.
If you are a volunteer then we may collect extra information about you, for example:
• criminal records checks
• details of emergency contacts
• medical conditions
We may also collect sensitive personal data if you have an accident on one of our sites. This information will be retained for legal reasons, for safeguarding purposes and to protect us (including in the event of an insurance or legal claim). If this does occur, we’ll take extra care to ensure your privacy rights are protected.
e) Children and young people
In line with data protection law, unless we have the express permission from your parent or guardian, we will not collect, store or process your personal details if you are under 13 years of age.
If we have the permission of your parent or guardian, we will record your date of birth at the point of joining, so that we can send you information that we feel is suitable to your age.
6. How do we store your data?
All of the personal data we process is processed by our staff in the UK. However, for the purposes of IT hosting and maintenance your information may be situated outside of the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.
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 clear Data Protection Policy and associated guidance which personnel are required to follow when handling personal data.
b) Payment security
All electronic forms that request financial data will use encryption to protect any data exchanged between your browser and our servers.
If you use a credit card to donate, purchase a membership or purchase something online we use Worldpay, SagePay and PayPal.
Torbay Coast & Countryside Trust complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council and will never store card details.
Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.
c) Data retention policy
We will only use and store information for as long as it required for the purposes it was collected for. We continually review what information we hold and delete what is no longer required.
7. Your rights
We respect your right to control your data. Your rights include:
a) The right to be informed
This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this policy, please contact us
b) The right of access
If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request, we will respond within one month. To make a Subject Access Request, please contact our Business & Commercial Manager (see point 10 for contact details).
c) The right to rectification
If we have captured information about you that is inaccurate or incomplete, we will update it.
d) The right to erase
You can ask us to remove or randomise your personal details from our records.
e) The right to restrict processing
You can ask us to stop using your personal data.
f) The right to data portability
You can ask to obtain your personal data from us for your own purposes.
g) The right to object
You can ask to be excluded from marketing activity.
h) Rights in relation to automated decision making and profiling
We respect your right not to be subject to a decision that is based on automated processing.
For more information on your individual rights, please see the Information Commissioner’s Office.
8. Making a complaint
Torbay Coast & Countryside Trust aspires to do the best we can in everything we do. However, we do not claim to be perfect and there may be times when we fall short of meeting expectations. When this happens, we want to hear about it, to deal with the situation as quickly as possible and make changes to stop it happening again.
We take complaints very seriously and we treat them as an opportunity to improve and strengthen our relationship with our supporters and volunteers. This is why we are grateful to hear from people who are willing to take the time to help us improve.
Our policy is:
- To make sure everyone in our organisation knows what to do if a complaint is received.
- To make sure all complaints are investigated fairly and in a timely way.
- To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
- To learn from complaints and feedback to help us to improve what we do.
All complaint information will be handled sensitively, in line with relevant data protection requirements.
Overall responsibility for this notice, handling of complaints related to data protection and the implementation of our Data Protection Policy lies with the Business & Commercial Manager (for details see below).
Information Commissioner’s Office
For further assistance with complaints regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.
Information Commissioner’s Office
Telephone: 0303 123 1113
9. Leaving our website
We are not responsible for the privacy practices or the content of any other websites linked to our website. If you have followed a link from this website to another website you may be supplying information to a third party.
10. Get in touch
Business & Commercial Manager
Telephone: 01803 520022
Address: Torbay Coast & Countryside Trust, Occombe Farm, Preston Down Road, Paignton, TQ3 1RN
Our office hours are Monday – Friday, 9am – 5pm