Wirral Community Narrowboat Trust
Privacy Policy
INTRODUCTION
Wirral Community Narrowboat Trust is a British charity with a mission to ‘To seek to
improve the quality of life for people who, by virtue of age, infirmity, physical
disability, mental disorder or social factors, are disadvantaged or deprived.
To make provision for the social, recreational and educational needs of the said
people.” www.wcnt.org.uk
We value everyone who engages with us by whatever means, and we do all we can fully to
protect your privacy and to make sure the personal data you provide us is kept safe.
This Privacy Notice is designed to comply with the General Data Protection Regulation
(GDPR) and is issued in the interests of transparency over how we use (“Process”) the
Personal Data we collect. We also have specific Terms of Conditions for the use of our
websites, which you should read as well.
We treat all our supporters and contacts in line with our values and ethos and we welcome
any feedback about any of our actions. Just call our office between 1000 hrs and 1200 hrs
weekdays on 0151 647 6300 email us at info@wcnt.org.uk
YOUR INFORMATION
We collect personal information each time you deal with us, for example when you make a
donation, book a boat trip or otherwise provide your personal details.
When you visit our websites
We collect non-personal data such as IP addresses. Website usage information is collected
using cookies (see the section on Cookies below). If you provide us with any personal data
while using our websites we may use it to provide you with any information or services you
have requested.
Information from social media
We may collect information that you make available on social media, for example, Twitter,
Facebook or Instagram. You may wish to check their privacy policies to find out more about
how they will process your data.
Information from third parties
We do not collect information from third parties all our events are organised and arranged in
house by our volunteers.
Other publicly available information
We may collect information from Companies House, Charity Commission and information
published in articles, newspapers or blogs.
Sensitive Personal Data
We do not collect sensitive personal data, such as race, sexual orientation or other data in our
day to day running of the Trust.
WHAT DO WE DO WITH YOUR PERSONAL DATA?
We may use the personal data we collect to:
Keep you up to date on news and stories about our work.
Ask for financial and non-financial support, such as volunteering.
Process donations you give us, or to support your fundraising for us, including Gift Aid.
Keep records of your relationship with us e.g. questions you have asked or suggestions or
complaints / suggestions you have made.
Classify supporters by name.
We may use publicly available information such as newspaper articles, or information you
have given permission to other organisations to share such as the Canal River Trust., Inland
Waterway Association etc.
If you make a major gift to our work, and where you agree to such a relationship with us, you
will be given a Wirral Community Narrowboat Trust contact who will discuss and agree with
you any sensitivities you may have about the personal data we hold and the methods of
contact suitable for you. We will do this at the earliest convenient opportunity. Where you do
not wish to pursue such a relationship with us, we will not retain any additional publicly
sourced personal data about you we have used for this purpose.
OUR LEGAL BASIS FOR HOLDING AND PROCESSING YOUR PERSONAL DATA
Legitimate interest: Contacting you
We may contact you by post or telephone where we have a legitimate interest to do so. For
example, when booking a boat trip and going on a boat trip, in order to ensure number of
passengers and or wheelchairs, person in charge and date and time of boat and trip location.
Where you have previously asked us not to contact you in this way we will respect your
contact preferences. You can change your preferences at any time or stop us processing your
data by contacting us by telephone, post or email as shown in the section ‘Your rights and
telling us when things change’ below.
Consent: Contacting you
We may contact you by email or text if you have given us your consent to do so. We will
only communicate in accordance with your preferences and you are free to change your
preferences at any time by contacting us by telephone, post or email as shown in the section
‘Your rights and telling us when things change’ below.
Volunteering with us
Where you provide personal data and sensitive personal data when volunteering, such as the
information on your application form we will process, store and disclose the personal data we
collect to:
Support the recruitment process.
Enable you to submit your application form.
Answer any questions you may have.
Use third parties to provide services such as references, qualifications, criminal referencing,
and checking services such as DBS. to volunteer with us we will store, process and disclose
the personal information we collect to:
Deliver the volunteering opportunity, including the disclosure of personal data, such as
contact information, to our skipper where necessary to deliver a safe trip or event for all
involved.
Monitor the quality of the volunteering opportunity or trip provided.
Answer any questions or feedback you may have.
HOW AND WHERE WE STORE YOUR INFORMATION
How long?
We will keep your personal information only for as long as we consider it necessary to carry
out each activity, in the case of booking and taking a trip we will hold your data for the
duration of the season only, all data regarding booking and trips taken will be destroyed after
the season.
We have a data retention policy to implement this. We take account of legal obligations and
accounting and tax considerations as well as considering what would be reasonable for the
activity concerned.
For example, we will retain details of donations for 7 years to meet tax and accounting
requirements, and we will retain any safeguarding records indefinitely. We will only hold
personal information provided to participate in a trip until the end of the year.
Legacy income is an important source of income for our beneficiaries. We may keep data you
provide indefinitely to carry out the administration of legacies and to communicate with the
families of those leaving us legacies.
If you have any questions about our Data Retention Policy please contact our Data Protection
Officer, Hans Lesage, in writing at Wirral Community Narrowboat Trust, c/o Hillyer
McKeown Solicitors 1 Hamilton Square, Birkenhead, CH41 6AU or by email at
info@wcnt.org.uk
HOW SAFE IS THE PERSONAL INFORMATION WE HOLD?
We ensure that we have appropriate technical controls in place to protect all the personal data
you provide. For example, we ensure that any online forms are robustly protected from
unauthorized access and is routinely monitored.
We ensure that access to personal data is restricted only to those officers and volunteers
whose job roles require such access and that suitable training is provided for these officers
and volunteers.
We will not use external companies to collect or process personal data on our behalf. If we do
use external companies, we remain responsible for the storing and processing of your
personal data.
However, we need to remind you that despite all our efforts, the internet cannot be
guaranteed to be 100% secure, and that you submit data at your own risk.
Credit / debit card security
We may use a third party to process donations or purchases using cards but will ask them to
process your information in line with the GDPR and the Payment Card Industry Data
Standard.
If you use your debit or credit to donate to us, purchase something or pay for a trip, whether
online, over the phone or by mail, we will process your information securely in accordance
with the Payment Card Industry Standard.
We do not store your debit or credit card details once your transaction has completed. All
card details are securely destroyed once your donation or payment has completed.
We hold bank account details for the purpose of collecting direct debits in accordance with
direct debit mandate rules.
Where we store your personal information
We use cloud-based systems to process data and therefore data may be processed outside of
the European Economic Area (EEA). We adopt the Information Commissioners approved
measures and therefore ensure that personal data is held in compliance with European data
protection regulations. We take all reasonable steps to ensure that your data is stored and
processed securely in accordance with this policy. By submitting your personal data you
agree to this transfer, storing and processing of your information.
WHEN WE SHARE YOUR INFORMATION
In line with our ethos, we do not share or swap your information with any other charities.
Legal duty
We may need to pass on information if required by law or by a regulatory body. For example,
a Gift Aid audit by the HMRC, or if asked for details by a law enforcement agency.
We may use IP address information to identify a user if we feel that there are or may be
safety and/or security issues or to comply with legal requirements.
COOKIES
What are Cookies?
We collect data using cookies. A cookie is a text file that is sent from our website as soon as
you visit the site. It is stored on your computer’s hard drive and helps us to identify your
computer (not you) and collects information in an aggregate, anonymous way.
Cookies may be used to collect information about your visit to our website, for example,
traffic data, location data, device information, the date and time of your visit and the pages
that you visit.
The use of cookies is an industry standard for most major websites. You can find more
information about cookies by following this link.
Wirral Community Narrowboat Trust’s use of cookies on our websites
To enjoy our websites to the full, we recommend that you leave cookies turned on. If you
turn off cookies then you may not be able to enter parts of the sites.
The cookie data that we collect we may use to:
Customise the content on our website and to help to understand visitor’s current and future
needs.
Process any requests, applications or transactions you may make.
Aid internal administration and analysis.
Managing cookies
Most browsers allow you to turn off the cookie function. To do this you can look at the help
function on your browser.
Wirral Community Narrowboat also uses third party suppliers such as Facebook, Twitter, and
Instagram and these providers may use cookies. They may also use tracking pixels, which are
commonly found in advertising to track the effectiveness of adverts. As some of these
services may be based outside of the UK and the European Union, they may not fall under the
jurisdiction of UK courts. If you are concerned about this you can change your cookie
settings (see above) and can find more information about this here.
HOW WE TREAT CHILDREN AND VULNERABLE PERSONS
Aged under 13 years
We do not actively seek to collect children’s data. If at any time we create any materials
which may lead to someone aged under 13 years providing their details, we make it clear that
we will need their parent’s /guardian’s permission before giving us their personal
information.
Clients or Supporters in vulnerable circumstances
We recognise the importance of identifying and supporting clients and supporters in
vulnerable circumstances. All volunteers who interact with clients are trained and fully DBS
checked to be aware of, to identify signs of vulnerable circumstances and to deal with the
client appropriately in accordance with our vulnerable person policy.
Personal information will be recorded so that we may respond appropriately in future, for
example by ceasing fundraising requests or no longer making calls.
YOUR RIGHTS AND TELLING US WHEN THINGS CHANGE
We fully recognise your right to have your data removed, to be forgotten, to opt out of
communications or withdraw consent and to have a copy of your personal data. You also
have the right to lodge a complaint with the Information Commissioner’s Office at
https://ico.org.uk
Preferences
You can change your preferences at any time about what you receive from us, including
marketing and fundraising materials, or how we contact you, by mail, phone or email.
You can do so by:
Calling us on: 0151 647 6300 between 1000 hrs and 1200 hrs weekdays or
Email us on: info@wcnt.org.uk Write to us at: Wirral Community Narrowboat
Trust, c/o Hillyer McKeown Solicitors, 1 Hamilton Square, Birkenhead CH41 6AU.
Updating your details
We do appreciate it if you keep your details up to date. You can do so in the same way as
updating your preferences (above).
We may use Royal Mail’s Postcode Address File or other available sources to confirm data
that you provide us with, where, for example, we are unsure of what you have completed on a
form.
We will not use these sources to create data that you have chosen not to provide, for example,
if you have left a telephone number blank; nor will we automatically update changes of
address, we will normally only update your address when you tell us it’s changed. However,
if you are a regular giver, continuing to give regularly, and items are returned to us, we may
use external sources to update your address details so that we may update you on how your
money has been spent through our news and stories.
Telling us to stop processing
You have the right to ask us to erase your personal data, to ask us to restrict our processing or
to object to our processing of your personal data. You can do so at any time by writing to us
at:
Wirral Community Narrowboat Trust, c/o Hillyer McKeown Solicitors 1 Hamilton Square,
Birkenhead CH41 6AU
ACCESS TO YOUR INFORMATION
You have the right to request details of the information we hold about you. To receive a copy
of the personal information we hold please write to our Data Controller at the address given
below. We will respond within one month of receiving your letter.
For more information about your rights please visit the website of the Information
Commissioner’s Office (https://ico.org.uk/for-the-public/personal-information/)
CHANGES TO WIRRAL COMMUNITY NARROWBOAT TRUST’S PRIVACY &
SECURITY POLICY
Changes to this Policy
This policy was last updated in May 2018. We may amend this policy from time to time to
take account of changes to our processes or changes to data protection or other legislation. If
we make any significant changes to this policy we will show this clearly on our website, in
our publications or by writing to you directly. By continuing to use our website you will be
deemed to have accepted these changes.
Feedback
We welcome feedback or questions on this policy or on any of our actions by
Calling us on: 0151 647 6300 between 1000 hrs and 1200 hrs weekdays or
Email us on: info@wcnt.org.uk
Write to us at: Wirral Community Narrowboat Trust, c/o Hillyer McKeown Solicitors, 1
Hamilton Square, Birkenhead CH41 6AU