How we respect your data
1. Introduction
The David Sheldrick Wildlife Trust, known as Sheldrick Wildlife Trust, is committed to protecting and respecting your privacy. This policy, together with any other documents referred to in it, explains how we will treat your personal information and sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read our privacy policy carefully to understand our practices regarding your personal information and how we use it.
This privacy policy relates to The David Sheldrick Wildlife Trust (UK) (registered charity number in England and Wales: 1103836, company number: 4791958); The David Sheldrick Wildlife Trust (Kenya) (PIN: P051097749N); and The David Sheldrick Wildlife Trust USA (EIN: 30-0224549). For the purpose of our privacy policy, henceforth to be referred to as the SWT.
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 SWT 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?
When you provide us with your personal data, you are agreeing to consent to the collection and use of any information you provide in accordance with the stated purposes and this privacy policy. We are required by law to tell you what information we keep on file and what we use it for, and we will always make sure that we consider why we are processing your personal data and our legal basis for doing so.
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:
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 SWT that we believe may be of interest to you.
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 SWT 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
In most instances we will rely on obtaining your consent to use your personal information, however in certain instances we collect and use your personal information by relying on the legitimate interest basis. Examples would be; where you request information about the work of the SWT, we have a legitimate interest to use your personal information to respond to you and in doing so, there is no overriding prejudice to you by using your data in this way; where you have made a donation to the SWT, we have a legitimate interest to inform you of how your support is making a difference; to update our database records to keep them accurate, such as amending an address where we receive returned mail; to contact former job applicants if a suitable role becomes available. You have the right to object to us processing your data on the grounds of legitimate interests, and if you would like us to stop using your data on this basis, please contact us (contacts details can be found at the end of the privacy policy and on our website).
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 SWT 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;
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 SWT. Examples of companies we works with include; JustGiving, Crowdrise, Facebook, Virgin Money Giving, Charities Trust, Payroll Giving in Action, Active Network (Active Works).
When completing our online quizzes, statistical and non-identifying data may be collected and temporarily stored by our quiz provider platform, Riddle.com, in order to ensure smooth running of the quiz service. At the end of the quiz, the SWT may also invite you to share your feedback about the quizzes, to help us improve the content of these quizzes and to make them more suitable for SWT’s audience. This includes asking if you enjoyed the quiz, if you adopt any orphans in the care of the SWT and your general age bracket. This information does not identify any individual. Any feedback you choose to submit will be collected and stored by Riddle and processed by SWT solely for the purpose of improving our quizzes. However, it is not obligatory for quiz-takers to provide this feedback.
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 SWT website or the rights, property or personal safety of any person.
Access to the SWT’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 SWT 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 SWT 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.
We use Hotjar in order to better understand our web users’ needs and to optimise people's online experience with us. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our website with user and supporter feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a non-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile - this means that any personal data that was collected can not be attributed to a specific person. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
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 SWT 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 MyAccount section of the website if you have registered an account.
11. Third party websites
Our websites include hyperlinks to, and details of, other websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties and always advise you to read the privacy policy of any website you visit, to ensure you agree with the policy before actively using the website.
12. Changes to the policy
We reserve the right to change this policy from time to time and you will always be able to see here when it was last updated. If we make significant changes, such as to how we process your personal information, we will publicise these changes or may contact you directly with more information. This privacy policy was last updated in May 2018.Please do revisit this policy from time to time, to remind yourself of its details.
13. Contact
You can contact us at any time, at any of our locations. If you have any questions or comments about this privacy policy, please direct these to: [email protected]
Post (UK): The Sheldrick Wildlife Trust, 1 Oak Place, Rosier Business Park, Coneyhurst Road, Billingshurst, RH14 9DE
Post (USA): The Sheldrick Wildlife Trust USA, 25283 Cabot Road, Suite 101, Laguna Hills, CA 92653
Post (Kenya): The Sheldrick Wildlife Trust, PO Box 15555, Mbagathi, 00503, Nairobi