Privacy and cookies policy

To be fully transparent, this privacy statement sets out the type of personal information we may collect and hold and how it may be used.  Any personal information given to us will be treated with care and will be processed lawfully and fairly in accordance with the Data Protection Acts 1998 & 2003, and the General Data Protection Regulation May 2018 and the subsequent Data Protection Act. 

When you share your information with us, World Horse Welfare as the Data Controller is responsible for processing your data and keeping it secure.  If you have any questions, please call (+44 (0)1953 498 682), email (info@worldhorsewelfare.org) or write to us (Anne Colvin House, Snetterton, Norfolk NR16 2LR, UK).

World Horse Welfare is a participating member of the Fundraising Regulator and follows their recommendations.

1. Collecting Personal Information
2. Processing Data
3. Publicly available information
4. Profiling
5. Storing Data
6. Sharing Data
7. Data Breach
8. Call recording and CCTV
9. Communication
10. Recruiting new supporters
11. Safeguarding vulnerable or young people
12. Financial data
13. Legacies
14. Online
15. Social Media Advertising
16. Website Terms and Conditions
17. Changes to this privacy policy

1. Collecting Personal Information

We collect personal information and contact details through:

• Events and activities at our four Rescue and Rehoming Centres and at our trade stands
• Fundraising and campaigning activities
• Memberships or sponsorships
• Welfare calls (which can be given anonymously)
• Our work helping horses in the UK and internationally
• Rehoming a horse
• Gifts, donations and purchases
• Website forms

When collecting contact information, a clear onwards communication statement is used.  Supporters are given the opportunity to opt in or out of communications as per data protection regulations, and are given a telephone number, address or email to get in touch for further information, to change how they hear from us or to change how their information is processed.

The personal data we may collect includes without limitation your name, address, email address and information you may provide to us about your health (for example when you request wheelchair accessible spaces or you request a sign language interpreter at an event).

2. Processing Data

We may process your data to fulfil a donation; for example, we may verify your address.

We store your data on our secure database and use this to manage all communications with you and to store your preferences, which help to build a profile, so that you receive communications which are relevant to you.

We may sort your data, for example, via location to send you information for an event at a farm near you.

When we are asked to stop sending communications, we will keep your details on our database and add a communication block to ensure you do not receive any further mailings.

Occasionally we may delete your data if requested but would always recommend that if you would not like to receive a  future mailing from us, that you remain on the database and a communication block is added to your record to ensure you are not contacted again.

3. Publicly Available Information

We may use information in the public domain to verify information given to us and to assist with fundraising or furthering the charity’s aims, for example to help write a biography for a special event, or to find a telephone number to contact you urgently about a query.

We have a duty to ensure that the information we hold on you is accurate.  We do use the Post Office service to trace a new address for post that we have sent that has been marked as gone-away.  This is a service that you will have previously opted in to.

We may do additional research using publicly available information to show due diligence, for example when deciding whether to accept a donation or work with an individual or company.

4. Profiling

We may use anonymised data to help inform marketing campaigns to help us ensure that promotional activity is cost effective and more likely to have an impact, enabling us to help more horses.

5. Storing Data

Information held within our electronic database and website is securely stored for as long as is necessary in line with data protection regulations before being archived or deleted as appropriate.

Paper-based information relating to a financial transaction is held for 7 years before being securely shredded.

6. Sharing Data

World Horse Welfare values our supporters, which is why we never share or sell your personal data for a company or organisation to use for their own purposes.

We do work with reputable companies under an agreement which complies with data protection regulations to process data to fulfil the following areas of our work:

• To send postal mailings and to process responses for World Horse Welfare communications
• To manage our raffle through the online platform and to process funds raised through this
• To send out emails and manage campaign actions
• To maintain and develop our databases

If we would like to share your personal information for any other purpose, for example for research or to fulfil a petition, we will ask for your consent to do so.

In general your personal data is stored and transported securely in the EU and is used for the purposes stated above except in the case of our email updates and campaigning actions where data is held securely in Canada.

If data needs to be processed outside the EU, it will be processed securely and where the organisation receiving the personal data has provided adequate safeguards.

We do work with other animal welfare organisations, local authorities and police forces to share information to safeguard horses.

Personal and sometimes sensitive data may be shared, under a data sharing agreement which complies with processing data for a legal purpose or in the public interest, for the purposes of protecting an animal or to assist with a prosecution.

7. Data Breach

The charity has a process in place for reporting any data breaches and has a Data Protection Officer.

8. Call recording and CCTV

• Calls to our welfare line can be made anonymously, but are recorded
• Calls to our fundraising line are recorded for training purposes
• CCTV is in operation at all of our centres for the safety and security of staff and the horses

9. Communication

We will send you information on our work and fundraising and details about how your support helps horses through the following methods:

• If you have given us your address and have not opted out of specific communications, we will post you the newsletter, appeals, raffle or fundraising updates in accordance with how you have supported us in the last four years and tailor these to your preference, as we believe you would legitimately like to receive these.  We will make sure you have a clear option to opt out of communications and processing when you give us this information
• Mailings can be tailored; for example you can request to receive the newsletter only.  Please do get in touch if this is the case at +44(0)1953 497239 or email info@worldhorsewelfare.org
• If you have not responded or engaged with us in the last four years we may contact you by post to ask for your consent to contact you about our work and fundraising in the future

By telephone

If you have given us your telephone number and have not opted out of communications we may use this to call you occasionally about our work and fundraising in a way that you would reasonably and legitimately expect.

If calling for marketing purposes, we would also check your telephone number against the Telephone Preference Service.

By email or SMS

We will only contact you for marketing purposes, for example receiving the e-newsletter or email updates, if you have consented and opted in to this.

Every marketing email communication provides supporters with the opportunity to opt out of future email contact. The consent to email will remain until you have told us otherwise.

If you have contacted us in a specific way about something, for example, emailed about an event, we will usually communicate with you in the way that you contacted us about your query.

Membership and sponsorship communications

You will receive information relating to membership, insurance and sponsorship by post or alternatively by email if consent has been given.  We will also send you information about the wider charity as we believe you would be interested in receiving this information, unless you have opted out of this communication.

10. Recruiting new supporters

To enable us to continue to help horses we need to recruit new supporters.

New supporters are recruited face to face at trade stands and our farms, and through other methods, including advertisements, online and by post through unaddressed and addressed postal mailings.

We also recruit new supporters online and may use an agency to help manage campaigns in line with the General Data Protection Regulation.  We also do promotion through social media channels and may use their in-house tools to aid with promotion.

For addressed mailings we work with an established data controller whom we have an agreement with to rent data from for the mailing with the intention of inspiring new supporters to help horses.

We always cross reference any rented data with the Mailing Preference Service and the Fundraising Preference Service and against our own database to try and ensure we are only contacting people who would expect to receive mail.  We also put in additional safeguards and also review data consent statements from the list brokers.

We encourage anyone who does not want to be contacted by us to let us know.  We also recommend encouraging people to consider utilising the appropriate preference services (including the  Fundraising Preference Service, the Telephone Preference Service (TPS) and Mailing Preference Service (MPS)) and advise people to be wary of lifestyle surveys and competitions.

If you do not wish to receive future mailings we may need to add your details onto our database with a do not mail block to make sure that we can ensure your details are not on any mailing lists we may lease to reach new supporters. We check any list we use against our own records and the Mailing Preference Service and Fundraising Preference Service before sending a communication to those on the mailing list in line with guidance issued by the ICO.

11. Safeguarding vulnerable or young people

We comply with guidance issued by the Direct Marketing Association and Code of Fundraising Practice to safeguard vulnerable people and regularly review our policies and training.

For activities involving juniors (under 18 years of age) we ask for a date of birth and guardian or parental consent for age-appropriate communications.

Once over 18 years old, permission to contact passes to the individual as an adult.

12. Financial data

When you use a debit or credit card to make online payments, or you are asked to provide bank account details to setup a direct debit, your data is transmitted using Secure Socket Layer (SSL) protocol which encrypts your details. Your information will be provided directly to a Payment Card Industry (PCI) compliant third party acting on our behalf – either PayPal or Sage Pay.

We may collect your bank details – for example to set up a Direct Debit on your behalf – these will be held securely by us and wherever possible we will only display the last four digits of your account number. We will only collect these details when you are in a secure area of our website. On the website you can see that you are in a secure area if you can see a closed padlock or “https” at the top of your screen.

13. Legacies

World Horse Welfare is very grateful to receive gifts from donors in their Wills.  In order to meet our legal requirements, we need to carry out correspondence with relevant parties during the administration of an estate.  Legacy administration relates to the communication between a charity and a personal or chosen executor after a donor has died and left a gift to charity, to ensure that the donor’s wishes are carried out and respected according to the details in their Will.

We will communicate with the executors, solicitors and any other parties that are involved in the distribution of assets including other charity co-beneficiaries to administer the Will.  Such correspondence includes thanking the donor’s family and friends, and asking and answering questions relating to the distribution of their assets. It is a sensitive process and one that we always carry out with the utmost levels of tact, respect and gratitude.

As part of this process we need to collect, hold and use personal data relating to a number of individuals. Data is held securely, retained for only as long as is necessary, and processed in a lawful way.

We collect personal information about:

• Deceased charity legators
• Solicitors or lay executors
• Other named beneficiaries mentioned in a Will
• Next of kin and/or family members that we will want to thank and report on the progress of a legacy gift
• Employees of organisations that we need to communicate with during the administration process including charity legacy officers, solicitor employees etc.

Personal data relating to a Will  is collected in the following ways:

• From copies of Wills
• Provided by third parties, such as Smee & Ford
• From communication with executors, solicitors and any other professional third party during the legacy administration process
• Provided to us from other co-beneficiary charities that are involved in the specific legacy it relates to
• That which is already in the public domain

The types of personal information that we may collect, store and use as part of the legacy administration process include records relating to:

• Home address and contact details as well as contact details for next of kin and co-beneficiaries
• Co-beneficiaries’ level of entitlement to any gifts or share of an estate which our charity benefits from
• Telephone, email, internet, fax, instant messenger or other electronic communication details where provided to us
• We do not usually collect sensitive personal information unless it can be proven to be pertinent to the legacy case and there is a clear reason for doing so

We will use personal information to carry out our legacy administration in line with best practice standards.  We will lawfully process this information:

• Where the data subject has provided their consent
• Where the processing is necessary for compliance with a legal obligation
• Where necessary for the purpose of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject

Charities have a legal entitlement to any legacy gifts they are given and are accountable to the Charity Commission under Charity Law to ensure the money is received and used according to their charitable purposes.  In order to fulfil these obligations we may need to use personal data of living individuals, for example to write a letter to the executor to pass on thanks and gratitude to the family of the deceased donor, and to communicate about the practicalities of the estate.

• We will not use this personal data to market or fundraise from the executor or next of kin without their express consent to do so
• We may need to share information with “data processors” such as associated organisations and agents who provide us with a legacy administration service.  These “data processors” will only act under our instruction and we will not allow these organisations to use your data for their own purposes and will take care to ensure they keep your data secure
• We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing)
• We will hold personal information on our systems for as long as is necessary for the relevant activity and this can vary from case to case.  In certain circumstances – for example in a life interest case where we have an interest in an asset that someone else is entitled to live in during their lifetime we may hold information for longer.  In these situations we will ensure we only retain information that is required and relevant to the specific situation

14. Online

We want our website to be as user-friendly as possible.  To help us understand how well the website is working, and how we can improve it, we use third-party analytics tools such as Google Analytics.

Analytics tools help us collect information about how people in general use our websites.  For instance, it helps us monitor how many people visit each page, how long people stay on each page, which search engines people use to find our website and which links are clicked on.  These cookies do not collect or store personal information about you. Analytics data cannot be used to identify you, or to tell us what you did on our website. It is completely anonymous.

Profile Management

• Some World Horse Welfare micro-websites allow you to login to an account (e.g. our shop and the rehoming website).  These sites use a cookie in order to remember account information, like your password

Cookies

• Cookies are small text files that are placed on your device that help us make our website work better for you
• No official World Horse Welfare website uses cookies that give us access to any personal information about you. If you’d like to learn more about cookies in general, please visit AboutCookies.org
• Some World Horse Welfare website pages have ‘share’ buttons that let you share pages with your friends through websites like Twitter and Facebook. These sites may set a cookie when you login to share things
• To help monitor the success and efficiency of campaigns, we may also use a pixel

You are able to set your devices to accept all cookies, to choose the types of cookies you accept, to notify you when a cookie is issued, or not to receive cookies at any time. For instructions on how to do this visit www.aboutcookies.org.uk/managing-cookies. Please note that if you choose not to accept cookies some features of our website may no longer work for you.

Security

• World Horse Welfare holds your data securely and has implementing specific technologies and procedures designed to protect your privacy, such as secure servers, firewalls and SSL encryption and staff training

15. Social Media Advertising

If you have given us permission to use your email address, we may match it with your social media account so we can share relevant information with you. We may also use your information for lookalike audiences, to identify other users similar to you on social media.

Meta will not see any of your data as it is locally hashed on our systems so Meta only sees your data in a coded format. Meta is covered by the same GDPR restrictions as any other organisation and are also governed by the UK Advertising Code (non-broadcast CAP).

Please be aware, if you are a Meta or Google user, you may still see advertisements about World Horse Welfare online, even if you don’t give us permission or when we don’t share your email addresses with these platforms. You can control this via your settings, and we have no control over this.

16. Website Terms and Conditions

This website contains information regarding the work of World Horse Welfare.

Copyright

• Unless otherwise indicated, the copyright in the content of this website, including the screens displayed on the website, is owned by World Horse Welfare.  You may not modify, copy, reproduce, republish, upload, post, transmit, publicly display, prepare derivative works based on, or distribute in any way any portion of the website, including but not limited to the code and software underlying the website.  You can view the material contained in this website and print off copies for your non-commercial or study purpose

Disclaimer

• Every effort has been made to ensure the accuracy of the information contained on this site, but World Horse Welfare cannot accept any responsibility for errors or omissions, or for any consequences arising from the use of information contained herein.  This site includes links to external websites. World Horse Welfare has no control over the content on these sites and therefore cannot be held responsible for any content contained within them

Linking policy

• World Horse Welfare is happy for third party websites to link to our site, but we cannot be held responsible for any content within these sites and World Horse Welfare does not necessarily agree with any views or opinions contained within them.  Linking does not in any way convey endorsement of the site

17. Event photography and filming

When taking photographs/filming at events World Horse Welfare displays notices at the venue to inform participants of this. These notices advise event attendees in advance that photography/filming will be taking place, and how they can notify us if they do not wish to be photographed/filmed.

This process is used at events with multiple individuals, where it would be impractical and disproportionate to obtain signed consent forms for all individuals.

With the exception of events detailed above, World Horse Welfare obtains signed consent forms for individuals for photography/filming.

World Horse Welfare uses photographs and videos for marketing and promotional activities in a range of marketing channels including:

• Magazines and publications
• Websites and microsites
• Direct mail
• Posters
• Banners
• Social media

18. Changes to this privacy policy

• We may change this policy at any time by posting amendments to it and without the need for consultation.  Please ensure you read the policy that is available at the time of your support