The Wisdom Trust is registered under the Data Protection Act 2018 under number ZA736857 and for the purposes of this policy is the Data Controller. Our registered charity number is 1112323 in England and Wales. The Wisdom Trust Ltd. (registered Company in England & Wales no. 05364460) is a wholly-owned subsidiary of ours which trades on our behalf. We have appointed a DPO namely, Graham Soper.
Below we have answered a range of questions to help you better understand how we protect your personal data.
What information do we collect?
Personal data is any information that can be used to identify you or another living individual. So for example, if you donate money, use our services or visit our offices, request our products, or become involved in our campaigns or volunteering work, we will collect and process the personal data that you’ve provided.
We may also collect personal data from you when you report a problem with our website, if you complete a survey which we use for research or evaluation purposes, or if you give us your details as part of a referral to our Wisdom Grants or when you give us feedback or contact us (see below for more information).
We may collect the following personal data:
Basic personal details (your name, email address, postal address, telephone or mobile number and date of birth)
Financial details (bank account number, UK taxpayer information for gift aid)
Credit or debit card information
Photos, videos or audio recordings used as part of our work with you
CCTV which is in use at various Wisdom Trust premises.
We may also collect, store and use the following ‘special categories’ of more sensitive personal data which require a higher level of protection, called a ‘condition of processing’. We will not process any of the following special categories of data without a condition of processing:
Information about your race or ethnicity, philosophical or religious beliefs, sexual orientation and political opinions:
Trade Union membership
Information about your helath, including any medical condition, health and sickness records
Information about criminal convictions.
We also collect more technical data which may identify your device or web browser, relating to details of your visits to our website, for example location data, how you found us and the resources accessed on our website. We use this to provide you with the information, services or products that you’re interested in and are most relevant to you.
This data is collected by cookies, which are small files stored on your computers’ or mobile devices’ web browser. Our site uses these cookies to keep you logged in as you move around the site, to provide some of our content, and to monitor the websites’ performance. This helps us make the website better for you and for others.
To understand how we use information about the communications devices you use, such as IP address (the location of the computer on the internet) and cookies, please see our Cookies Policy page. This page also provides information on how you can prevent or control the cookies that are stored on your computer or device web browser via our cookies management tool, as well as remove them completely.
How do we use your personal data?
There are a number of ways that we may use your personal data in accordance with the lawful basis described in ‘Our lawful basis for processing your personal data below. The following are the ways we use your personal data for our core activities:
To provide you with information (such as fundraising or campaigning activities), services or products you’ve requested or which we feel may interest you. When you interact with an email sent from the Wisdom Trust, such as opening an email or clicking on a particular web link, we will receive information about that interaction. We use this information to ensure that we understand how our campaigns are being received, as well as to ensure that we continue to act in accordance with how you’ve chosen to hear from us. We may also permit selected third parties to provide you with information on our behalf. But all this will only happen when you’ve consented to this. For more information, please see “Sharing your information with third parties” below.
To provide key services for the promotion of raising awareness about important issues affecting the future of our planet. This could include the collection of ethnicity and health data. This helps us ensure that we are able to effectively assess the needs of all individuals so that we can work with the most appropriate agencies, and ensures that our services reach the right people.
To enable us to support you in our work with you. Sometimes we may use mobile phones, cameras or laptops for filming, voice recording or slideshows as part of our work with you. These may be used to improve your relationships or help you understand our work better, and may also be used to help our workers learn how to support you better.
To evaluate and improve our fundraising activities as well as the services we provide to members of the public. This could be analysing demographics to inform our campaign, marketing and service provision strategies. This helps us ensure we understand how effective our services are and ensures we spend our charitable donations in the most effective way. If you start using a Wisdom Trust service, we may continue to use your data for evaluation purposes, but this will be in statistical form and will not identify you as an individual. As part of our quality assurance to ensure we are delivering the highest quality of service, the information we hold about you may be audited and inspected by other members of our organisation.
To analyse and improve the services offered on our websites. This means we can provide you with the most user-friendly navigation experience we can, which may involve providing your information to third parties.
To allow you to participate in interactive features on our website when you choose to do so. For example, we may help you auto-complete forms by inserting your contact details for you to edit.
To use your IP addresses to identify relevant information. This may include information such as your approximate location. It also helps us to block disruptive use or establish information like the number of visits to the website from different countries.
To make our marketing campaigns more targeted and relevant to potential donors and customers.
To record and respond to any compliments, comments or complaints from supporters or service users and to appropriately investigate and implement necessary changes. All feedback helps us to learn and to improve what we do. For more information please read our Compliments, Comments and Complaints policy.
To conduct prospect research. For more information please see the Prospect research section below.
To promote our activities. Where you have given us your consent we may use photos of you, or testimonials, for promotional activities and communications.
To match information collected from you through different means or at different times. That could include using information collected online and offline, along with information obtained from other sources, including third parties and publicly available sources, to ensure that the information we hold about you is up to date and accurate. These include third parties such as BT OSIS, Post Office Address File and Experian Quick Address.
To assess your suitability for a role at the Wisdom Trust as an employee or a volunteer. This may involve conducting internal searches against our database as part of the application process.
To protect staff and visitors to Wisdom Trust sites.To protect staff, visitors and to protect the organisation against theft, some sites will have CCTV installed.
Some of these activities may also involve ‘automated decision-making’. However, you have the right to object to the use of your personal data for profiling and automated decision-making processes. For information on how to exercise these rights, please see the section on ‘Your Rights’ below.
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
Where we have notified you of the decision and given you 21 days to request a reconsideration
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
If you wish to change or update your consent for direct marketing you can contact our Supporter Care team. Please see ‘Complaints’ below.
Research and Evaluation
Our researchers use personal data, including sensitive personal data, in their research activities. This might include research such as evaluating our services such as the Wisdom Trust Ambassadors Programme or commissioning research to help us understand what our users want from our services. Research allows us to ensure our services, programmes and campaigns support our beneficiaries as effectively as possible, effectively scale up our services, and identify additional areas for research, campaigns and programme development. We don’t seek consent to use your personal data for this purpose but rely on legitimate interests as our lawful basis. For our research activities, we ensure that we have conducted an assessment to ensure that our interests as a charity have not outweighed your rights and freedoms as an individual.
We conduct prospect research to identify people who may be interested in supporting the Wisdom Trust with a major gift. We do this by analysing the information we hold on current or past supporters, as well as credible sources in the public domain, to find people who we believe have the capacity and propensity to support us at this level. To help us make these decisions, we have developed a scoring system that we use to calculate how likely a person is to donate a major gift, and the level of support they could provide. This enables us to prioritise our resources and ensure that the funding proposals that we develop are appropriately tailored as we seek to generate support for ending child abuse.
We only use information from credible sources in the public domain, and we never use third parties to conduct research on our behalf. We do not seek consent to conduct this research but rely on legitimate interest as our lawful basis. If we do conduct research on you we will notify you at the first available opportunity so that you have the opportunity to view the information we have collected along with any score that we have applied to your record and request its deletion. If we are unable to notify you within six months, then our policy is to proactively delete this information from our records.
Our lawful basis for processing your personal data
Data Protection law requires us to have a reason or justification, also known as a ‘lawful basis’, for using any of your personal data:
Consent This is where we’ve asked for your permission to use your personal data in a specific way, and you’ve agreed. For example to send you marketing via email or SMS.
Contract We may process your personal data as part of an agreement you have with us. For example if you work for us or if you purchase something from our online shop.
Legal obligation We may collect or share your personal data where we are required to do so by law. For example to fulfil a regulatory requirement or for fraud detection.
Vital Interests Where there’s an immediate risk to your health we may use your personal data. For example if we’re concerned for your health or safety at one of our fundraising events.
Public task Some activities are undertaken in the public interest. For example, collecting personal data in relation to safeguarding concerns raised via the Wisdom Trust Online Chat Service.
Legitimate interests Our legitimate interest is in engaging with the public to further our charitable aims.
Whenever we use this justification we will always conduct a balancing exercise to ensure that we consider the impact on you as an individual to ensure that our interests are not overridden by the impact on you. Some examples of activities where we rely on legitimate interests are:
Sending you direct marketing via post;
Conducting research to better understand our supporters and improve the services we offer to families;
The use of CCTV in certain Wisdom Trust offices for monitoring and security purposes;
Sharing personal data amongst relevant teams within the Wisdom Trust to ensure we communicate with our supporters in the most effective way;
Purchasing marketing lists to promote our professional services via email to those who work directly or indirectly with those who may be interested in our work;
Handling any compliments or complaints in line with our policy.
How long will we keep your personal data
We always have your best interests at heart and your personal data will not be retained by the Wisdom Trust for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed.
We’re legally required to hold some personal data to fulfil statutory obligations. For example the collection of Gift Aid or to support certain financial transactions. We may be asked to keep records for longer periods or receive statutory instruction not to delete records.
If you’ve used any of our services, for example, Wisdom Trust Grants or Wisdom Trust Ambassadors, we will make notes of the work we do. We will keep these notes for 25 or 75 years depending on the nature of our work and your circumstances. For more information, or to request a copy of our data retention policy, please contact our Data Protection team at email@example.com.
Please see the ‘Sharing your information with third parties, keeping your information safe’ section for further details on data processing of the Facebook Pixel.
Making our communications relevant to you
We want to ensure that we provide you with information that is relevant to you. In order to do this, we may need to analyse the information we hold on you for supporter analysis and data quality purposes. This analysis includes modelling (e.g. how likely you are to respond to the invitation) and segmenting (looking at people who are similar to you), so that you receive targeted and relevant communication.
This ensures we can spend our charitable donations effectively to obtain the biggest impact on our beneficiaries. Additionally, as our data is captured from various different sources (e.g. donation or through our website, campaign data), for data quality purposes we will analyse your data to ensure we do not have unnecessary multiple versions of information on the same person on our database.
Using third parties to update our records
In carrying out the above activities, we may from time to time use publicly available information or information gathered from specialist companies. These include Directory of Social Change and UKChanges; companies that collate and analyse information from public registers to help ensure we have accurate and up to date information about our supporters. These companies may have obtained this information directly from you and in circumstances where you legitimately expect that they will pass on your information to other entities.
We will only use data collected in this manner for purposes to which you have consented or, if this is not reasonably practical, where we believe it is reasonably necessary to process your personal data for the purposes for which it has been provided. Throughout all of this, we will always ensure that the privacy and security of your personal data are protected.
How do we handle your direct debit or credit card information?
The Wisdom Trust will ensure that when collecting information such as debit cards, credit cards or personal data that this is done so securely. We and our partners use TLS (Transport Level Security) to encrypt data sent between the customer and us or our partners.
The Wisdom Trust is PCI compliant and uses external Payment Card Industry (PCI), compliant providers, to collect this data on our behalf. We do not store PCI data on our own systems.
How to best protect yourself and your personal data
To protect yourself when sending us sensitive information, please ensure that you use devices running supported operating systems that are regularly patched, and incorporate some form of malware protection. Only connect your devices to networks that you trust.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping the password confidential. You agree not to share that password with anyone else.
Where do we store your information?
The personal data collected from you may, in very rare circumstances, be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by individuals operating outside the EEA who work for us or working on our behalf. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services.
By submitting your personal data, you agree to this transfer, storing and processing at a location outside the European Economic Area. Where data is transferred outside the EEA, we have gone through a full due diligence process to help ensure the data is afforded the same levels of security. In addition, we will ensure that the transfer of data outside the EEA is undertaken in a manner that is legally compliant and in a way that is consistent with and which respects EU and UK laws on data protection.
Unfortunately, the transmission of information via the Internet is never 100% secure and we cannot guarantee the security of your data transmitted to our website. This means any such transmission is at your own risk.
Keeping your information up-to-date
To make sure we always have the most up-to-date information about how to contact you, we may also, from time to time, update your records to reflect any changes to your personal data.
This information may come directly from you, or it may come from a third party that we consider is legitimate and trustworthy and in circumstances where it is appropriate and where you will have had a clear expectation that your details would be passed on for this purpose.
We may also combine the information you provide us with information we collect from trusted third parties and partners such as business partners, sub-contractors, advertising networks, analytics providers, search information providers, credit reference agencies as well as publicly available sources. These third parties include UKChanges, Post Office Address File and Experian Quick Address.
For more information on cookie files and IP addresses read our cookies policy. This page also provides information on how you can prevent or control the cookies that are stored on your computer or device web browser, as well as remove them completely. This also provides information on how you can prevent or control cookies from being stored on your device or web browser by using our cookies management tool, as well as how to remove them completely.
If you’d like to access any of your rights, please contact us using the information below.
a. Right to access your personal data You have the right to access the personal data that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal data to you (or someone else on your behalf), we will provide it to you or them and aim to do so within 30 days from when your identity has been confirmed. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be excessive in nature.
We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal data.
b. Right to correct your personal data If any of the personal data we hold about you is inaccurate or out of date, you may ask us to correct it.
If you would like to excercise your right, please contact us as set out below.
c. Right to stop or limit our processing of your personal data You have the right to object to us processing your personal data for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances. If you would like to exercise this right, please contact us as set out below.
d. Right to stop or limit our processing of your personal data You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.
If you would like to exercise this right, please contact us as set out below.
e. Right to portability The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used and machine-readable format. It also gives them you the right to request that a controller transmits this data directly to another controller.
If you would like to exercise this right, please contact us as set out below.
Data Protection Officer The Wisdom Trust 5 Livingstone Road CATERHAM CR3 5TJ
We want to make sure that your personal data is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
If you would like to change the way we contact you please contact our Supporter Care team on 01883 341199 or emailing us at firstname.lastname@example.org.
The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here: https://ico.org.uk/for-the-public.
You also have the right to contact the Information Commissioner’s Office on 0303 123 1113, via their website www.ico.org.uk or via post:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF