Website(s): sheldrickwildlifetrust.org; enormouselephantrun.com; elephantorphans.com; daphnesheldrick.com
Your personal information (such as your name and contact details, known as ‘personal data’) is protected by specific legislation. From 25 May 2018 processing and retention of personal information is governed by General Data Protection Regulation (GDPR).
2. How and when we collect personal information
There are a number of ways that we collect information; most often this will be directly from you, for example, if you sign a petition on our website, make a donation by post, telephone or online, adopt an orphan animal in our care or correspond with us via email. You always have a choice about how we communicate with you.In some very limited circumstances we gather data from publicly available sources, to help us in our work with High Net Worth Individuals. Sometimes you will provide data to third parties who then pass it to us with your permission. For example, you may be raising money for the DSWT through JustGiving, Crowdrise, Facebook or similar fundraising platforms. You can find out more about this in Section 4 about how we work with third parties.We do not buy lists of data for marketing purposes or share data with other charities or organisations for them to use for marketing purposes.
3. What does providing personal information mean?
Fundraising and Campaigning
We aim to make it easy for you to tell us if you would like to receive fundraising or campaigning communications from us and to hear about our work, and the ways in which you would like to hear from us; by phone, email, SMS, post, social media and Mobile APP direct messaging platforms. If you tell us that you do not want to receive fundraising or campaigning communications, we will remove you from our list and we will not send you any further materials, unless you change your mind at a later date and expressly request future communications.
Processing your data on the basis of consent
When you give your consent for us to contact you, we will not treat this as valid indefinitely. We understand that our supporters want to hear from us while they have an active relationship with us and for a period afterwards. Examples of what we mean by an active relationship include:
Making a donation, purchasing an item of merchandise, including regular monthly, quarterly and annual gifts.
Taking part in a challenge event on our behalf (i.e. London Marathon, Boston Marathon)
Taking a campaign action, such as signing a petition
Attending one of our events
Ongoing conversations with our employees about our work
Adopting an orphan in our care
We consider your consent to be valid while you take these types of actions, and for 24 months after your last action, to allow us to keep you informed about our work and show you other ways you might choose to get involved and support us. We will invite you to re-confirm your consent, if you wish to continue to hear from us, 24 months after your last action.
You can withdraw your consent at any time by contacting us by email, telephone or post (our contact details are available at the end of this policy and in the contact us section on our websites).
The information we hold
We hold information that is necessary for the administration of your donations, including donations to adopt, and regular donations, including direct debits. We may wish to contact you by phone, post sms, or email to update you on our work, campaigns, events, appeals or other activities related to the work of the DSWT that we believe may be of interest to you.
Your name and postal address
Your email, if you have told us. We will only email you if you have said you would like to receive email communications. Marketing emails we send give you the option to unsubscribe and decline future emails. In the case of emails linked with orphan adoptions, you may request to stop receiving these emails on the understanding that this will prevent us from providing you with regular updates on your adopted animal.
Your telephone number, if you have told us.
Your date of birth, if you have told us.
Details of donations you have made, including date, amount, communication source code, method of donation (cash/cheque/card/bank). We have a legal responsibility to keep track of these details and to retain certain financial records for not less than 7 years.
Gift Aid Declaration; only in the case of those paying UK income tax, that have provided a declaration. This is used to enable us to claim from HM Revenue & Customs the tax paid on your donations to the DSWT (UK).
Details of any regular payment and direct debit instructions. We have a legal responsibility to keep track of these details and to retain certain financial records for not less than 7 years.
Details of any orphan animal adoptions and donations made to enact animal adoptions, including in the case of gift adoptions, details you provided to us for the gift recipient (we will seek the consent of the gift recipient to use the details you provided for them).
Details of communications we send to you and contact we have with you, including communications you send to us, for example; comments about our work, fundraising, website; reports of a problem or issues with our websites.
Some personal information is legally considered to be sensitive under GDPR, known as; sensitive personal data and special category data. This covers information related to health, race, religion, political beliefs, ethnic origin. The DSWT does not usually collect sensitive data about supporters, unless there is a clear and demonstrable reason in doing so, such as participation in an event where we need the information to ensure we provide appropriate facilities or support to enable you to participate safely. We would also make it clear if and when we collect sensitive information from you, what information we are collecting and our reasons for this.
Processing your data on the basis of legitimate interest
The privacy of our supporters and donors is extremely important to us and all personal data we collect is held safely and securely.
4. How we work with third parties in processing personal information
The DSWT does not sell, swap or share personal information or supporter lists with any other organisations.
We sometimes work with third parties, where we disclose your personal information, examples include;
for the administration and processing of your donations, particularly online donations, regular donations, direct debits, payroll giving and employer matched giving programs;
where you register to take part in an event (such as the London Marathon, Ride London, Brighton Marathon, Tough Mudder) and we provide your details to the event organiser in order to secure your place;
where we use companies with specific expertise or as the cost-effective solution for the printing, packing and delivery of postal mail communications on our behalf (in this instance, companies are vetted and we enter into agreements with them to ensure they treat your data legally and with due care, and only the data required for a communication will be sent and the company is required to delete it once they have completed the service).
Some third party organisations collect data on our behalf, and share it with us, in accordance with their data protection policies and based on your consent. This could be where you have chosen to create a fundraising page with a third party platform in order to secure sponsorship for the DSWT. Examples of companies we works with include; JustGiving, Crowdrise, Facebook, Virgin Money Giving, BT MyDonate, Charities Trust, Payroll Giving in Action, Active Network (Active Works).
In processing online donations, credit/debit card telephone donations, online direct debit and regular donations, and online merchandise orders, you will be directed to a payment gateway. In the case of telephone donations, the telephone operator will utilise a secure online payment gateway. Payment gateways use security features and encryption to keep your data safe, secure and encrypted. Credit/debit card donations are processed using PayPal, Braintree, CAF, DonorPerfect and WorldPay. We do not store or manage any credit/debit card details.
We will share your data where we have a legal requirement to do so. Examples include providing audit information to HMRC for Gift Aid claims or if we are required by law enforcement officials, if we believe such action is necessary to prevent fraud or to protect the DSWT website or the rights, property or personal safety of any person.
Access to the DSWT’s data is secured and protected. It is restricted to a limited number of trained staff in the organisation.
5. How long we keep your data
The DSWT wants to ensure we have up to date records for you as long as you are actively supporting us, so for as long as you engage with us and take actions on our behalf, such as donate to us, adopt an orphan, sign a petition or correspond with us. If you are no longer an active supporter, we will keep your personal information for a set period of time.
In the case of financial donors, we will keep records for at least seven years after your last financial contribution to us, to meet our requirements for any Gift Aid audit from HM Revenue & Customs (UK) or general audit from the Inland Revenue Service (USA).
In the case of active supporters with no financial record, for example those that requested to receive marketing emails from us, or requested any of our fundraising resources, we will keep records for at least 24 months after you corresponded with us or provided your consent to receive marketing communications. At that time we will ask if you wish to continue to hear from us. If you do not renew your consent, we will remove your personal information.
If you are a legacy supporter we will keep your personal information for 10 years after your legacy case is closed. It is important that we ensure we have the records to administer any legacy gifts in the way you want. Legacy records will always be deleted after 100 years at the maximum.
If you have adopted an orphan animal in our care, we will keep your personal information for at least 7 years from the date you made a financial donation to adopt. For multiple year adoptions, for example when you donate to adopt an orphan for 4 years at the outset, we will keep your personal details for at least 4 years after the end of your active adoption. Orphan animals are reliant on us up to 10 years before going wild and we want to ensure you can re-activate an expired adoption should you choose to while your adoptee remains in our care.
At the end of the time periods outlined above we will remove your personal information from our records, to ensure they are anonymous. We keep records of how supporters interact with us, but not of who those supporters are. For example, we want to be able to identify how many supporters adopted a specific orphan, donated to an appeal, purchase different types of merchandise. This helps us understand the effectiveness of our actions and to be able to improve them so that we raise funds in the most effective way.
You have the right to be forgotten at any time, which means you can ask us to delete your personal information before the end of the time limits listed above. In certain circumstances we may need to keep your details, for example, to comply with a legal obligation. If this happens, we will discuss this with you and explain the situation.
6. International data transfers
Personal information we collect may be stored, processed and transferred between any countries in which we operate to enable us to communicate with you in the best way for you and in accordance with this policy. Any transfer of personal information will be through secure means and data will be protected at all times. Information we collect may be transferred to Kenya, the United States of America and Canada.
7. Online privacy and cookies
The DSWT may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This information does not identify any individual and is statistical data about our users’ browsing actions and habits. It is used to help us identify popular and less popular content, to allow us to improve the content we make available to you on our website and offer you a good experience when you browse the website. Cookies can either ‘persistent’ or ‘session’ cookies. A persistent cookie will be stored by a web browser and will remain valid until its expiry date, unless deleted by the user before the expiry date. A session cookie will expire at the end of a user session, when the web browser is closed.
Please see our Cookies Policy for more information.
8. Security of personal information
The security of personal information is of great importance to us and we have security measures in place to attempt to protect against loss, misuse and alteration of personal information in our control. We store all personal information you provide on secure servers. All electronic financial transactions entered through our websites are protected by encryption technology. If you use a password to access our websites it is your responsibility to keep your password confidential and we will never ask you for reveal your password to us verbally or via email or post. You acknowledge that submission of information over the internet is never entirely secure. If you use a shared computer or computer in a public space to access our websites, or any websites, it is advisable to clear the browsing history in the browser and to close the browser when you have finished your user session to help ensure others do not access any personal information you shared in your session.
9. How to control the communications we send you
We want to ensure we keep in touch with you when and how you want. Marketing communications we send you will outline how you can update your contact preferences and our marketing emails include an unsubscribe link. If you do not want to receive certain communications from us, or no longer wish the DSWT to contact you in any form, please tell us. We will always respect your wishes.
Users that have active fosterings and adoptions of orphan animals in our care will, as clearly stated in the fostering programme on sign up, receive monthly email updates on the Orphans’ Project, including information when available on ‘their’ orphan. These emails are part of the product/service that a user signed up for when creating their fostering/adoption and so we need to provide these emails to ensure the user receives their complete order. As an active foster parent (adopter) you have the right to ask us to stop sending you your monthly orphan updates, on the understanding that in doing so, you are choosing not to be updated on your orphan. This does not terminate your fostering/adoption and you can request for these emails to re-commence at any time, as long as the fostering/adoption is still active. Foster parents / adopters will not receive marketing communications from us unless they have expressly requested these communications from us.
10. Your rights
You have a legal right under GDPR to contact us at any time to request a copy of the personal information we hold about you and to amend and update the information we hold about you. On receiving such a request and proof of your identity, we will provide you with a copy of this information. Subject access requests should be sent to: [email protected]
You have the right to ask us not to process your personal information for marketing and fundraising purposes. In practice you will usually expressly agree in advance to the use of your personal information for marketing purposes and you can exercise your right to prevent such processing by only selecting and/or checking certain boxes on the digital and paper based forms we use to collect your data.
You have the right to update the information we hold on you at any time. Should your personal information change, please help us to keep your information up to date by contacting us. You can also exercise your right to change your contact preferences at any time by contacting us or in the MyDSWT section of the website if you have registered an account.
11. Third party websites
12. Changes to the policy
Post (UK): The David Sheldrick Wildlife Trust, 3 Bridge Street, 2nd Floor, Leatherhead, KT22 8BL
Post (USA): The David Sheldrick Wildlife Trust USA, 25283 Cabot Road, Suite 101, Laguna Hills, CA 92653
Post (Kenya): The David Sheldrick Wildlife Trust, PO Box 15555, Mbagathi, 00503, Nairobi