The General Data Protection Regulation (GDPR) will come into effect in the UK on 25th May 2018. This will replace the existing Data Protection Act and introduce new legal requirements for charities, business and other organisations when processing individuals personal data.
East Sussex WRAS has always been concerned about Data Protection, protecting and respecting people's privacy.
If you wish to be removed from our Mailing List:
Please call 01825-873003 quoting the ID number which will be next to your address on any mailings we have sent you. Alternatively please e-mail firstname.lastname@example.org with your name, address, postcode and ID number and we will remove you too.
Please be aware that e-mail on this account is not checked daily so may take up to 2 weeks to be processed.
What and When Does WRAS Collect Personal Data?
WRAS currently only collects personal data for the following reasons:
1) When rescuing a casualty.
2) When processing a donation, on receiving a phone call or a donation through the post.
3) When a person asks to be added to WRAS Newsletter list.
WRAS has a database which records rescues and supporters information. WRAS records only the essential personal data:
- Address, Town, Post Code
- Phone Numbers
- E-mail Address when given.
WRAS also records information on:
- Donations received - date, amount, the reason for donation and Gift Aid Notification.
- Casualties - including species, date, the person who found the casualty, location where found, general assessment of the casualty and other relevant information relating to the Casualty and but not the finder.
Does WRAS Share, Buy or Sell Personal Information?
WRAS has always stated that it does not sell personal data to any other organisation nor has it ever purchased lists of personal data from other charities or agencies.
Occasionally casualties need to be passed to other organisations due to their specialist knowledge, facilities or equipment. It is necessary to pass over the finders contact details purely on animal welfare grounds to ensure casualties are treated and released correctly.
A tawny owl was found in the middle of a large wood. The finder took the owl home before contacting WRAS. The owl was collected from the finders home and admitted to WRAS. Due to a problematic fractured wing the bird was sent to another rescue centre further afield for a specialist vet to operate on the wing. Once recovered the owl needed to be returned to the exact location where found to ensure it was safely back in the birds home range. This required the finder showing rescuers exactly where the bird had been found, therefore the other rescue centre contact the finder direct.
WRAS is in the process of writing to all such organisations pointing out their responsibility to be compliant under the GDPR and the need for such information to be treated correctly.
These organisations are:
Folly Wildlife Rescue - Near Tunbridge Wells. RSPCA Mallydams Wood - Fairlight Hastings. Vale Wildlife Rescue, - Gloucestershire. Badger Trust Sussex - East Grinstead. Sussex Bat Group and the Sussex Bat Hospital at various locations. Swan Sanctuary - Sheperton. Bird Aid at Hailsham. Wildlife Aid - Leatherhead.
Where a criminal offence has occurred it may be necessary to pass on personal information to the relevant authorities giving details of any witnesses or persons involved.
What Does WRAS Use Personal Data for?
WRAS’s Database is used for three key areas:
- To met the requirements and recommendation (and sometimes legal requirements) of the Veterinary Medicines Directive, Royal College of Veterinary Surgeon, British Wildlife Rehabilitation Council and various animal welfare legislation relating to the rescue of wild animals and bird for veterinary treatment, their safe rehabilitation and return to the wild.
- To met the requirements and recommendations of the Charities Commission and HMRC in the processing of donations with or without Gift Aid.
- To keep people who use our service informed of the work the charity undertakes and for encouraging support of our charity and its aims and objectives.
WRAS also uses its database for statistical analysis of casualty data but all addresses are used in an anonymous manner.
What is WRAS’s Current Policy on Direct Marketing?
Fundraising comes within the term “Direct Marketing” as set out by the GDPR.
After a consultation with people who received our newsletters back in 2012 it was decided that the majority of people felt between 4 and 6 mailing a year would be the right level of communication.
WRAS sends out 4-5 newsletters a year and 1-2 appeals or information letters a year only.
WRAS does not buy in personal data for marketing/fundraising purposes.
WRAS does not sell on personal data for any purpose.
When a rescue call is received the name and address is added to WRAS’s Database. A leaflet is handed out with each casualty to the finder giving further information as well as WRAS’s Contacted details stating…
“All names & addresses are kept on a confidential database which is not sold or passed to any other organization. If you do not wish to receive newsletters or other mailings from WRAS or would prefer to receive them by e-mail please e-mail email@example.com with your name, address and casualty reference from this leaflet asking to not receive any mailings.”
"Privacy Notice: Under the new fundraising and marketing guidelines it is considered “legitimate interest” to contact people who have made donations to our charity from time to time. You can call 01825-873003 at any time to stop future contact. Further details are on our website www.wildlifeambulance.org"
This is accompanied by a tick box to clearly tell us if you don't want us to contact you further with direct marketing.
All WRAS donation forms which contain personal information have clearly stated “If you would like to be removed from our mailing list please call 01825-873003 & quote your ID number”
If a person does not want to be sent any mailings then their status on the database is changed to reflect this by selecting “Zero—No mailing at all”. However their personal data is kept as it is a requirement of the Casualty Record and Patient care or Gift Aid.
On our database people have their mailing status changed to...
"Archive" if they have not made contact or made a donation for 12-18 months or more.
"Gone Away / Deceased" if envelopes are returned by Royal Mail with notes on or where people e-mail or call saying they are moving or where we have been informed that a person has died.
"Newsletter Only" some people have requested that we only send newsletter and not appeal letters so this option is selected.
Archived people will only be mailed to again if they use WRAS’s service at a later date, make a donation or request a newsletter.
"NO CONTACT" if the person has specifically requested no communication from WRAS. WRAS will delete or make anonymous records where possible unless the information is required gift aid or other such purposes.
Refreshing & Updating Data.
The Fundraising Regulator requires charities to review and refresh consent as appropriate stating that “The core question that organisations should consider in establishing their timescale for refreshing consent is not what the organisation would consider ‘reasonable’ for its own purposes, but for how long would the individual consider it reasonable to be contacted before they were asked to renew consent?”
The ICO and Fundraising Regulator suggests that a 24 month period may well be appropriate to renew consent as best practice.
WRAS’s current policy of mailing to contacts for up to 12-18 months would fall within this timescale. Before every mailing records are checked and up-to-date and those not heard from for 12-18 months are archived.