Policies

Hertfordshire & Middlesex Wildlife Trust is a local charity supported by people who care about protecting wildlife, including over 22,000 members. With volunteers, we manage a network of 40 nature reserves covering nearly 2,000 acres, from beautiful wetlands and woodlands to rare patches of heath and orchard.

We take practical action every day to help wildlife flourish. With long term strategies for the conservation and restoration of environments rich in wildlife, we want everyone to be able to enjoy and benefit from access to nature.

In the face of climate change, the survival of our native wildlife now depends not only on retaining existing habitats but on the active expansion and reconnection of these green spaces. Our vision is of a Living Landscape, where we work with others to improve our towns and countryside for wildlife.

Hertfordshire & Middlesex Wildlife Trust is one of 47 Wildlife Trusts working across the UK; each is a corporate member of the Royal Society of Wildlife Trusts. We are the only charities working to protect the full range of UK wildlife and habitats at a local level. Collectively we have 800,000 members and 200,000 acres of wild spaces in our care.

We are committed to keeping the personal details of our members and supporters safe. This policy explains how and why we use your personal data, to ensure that you remain informed and in control of your information.

Any references to Herts & Middlesex Wildlife Trust, HMWT, the Trust, or to ‘we’, ‘our’ or ‘us’ refer to:

• Hertfordshire & Middlesex Wildlife Trust. We are a registered charity in England and Wales, and our registered charity number is 239863. Company Registered No: 816710.

We use three key definitions to describe people mentioned in this policy. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk)

• ‘Data subject’: this is you, one of our members and supporters. As the data subject, we respect your right to control your data.
• ‘Data controller’: this is us, the Herts & Middlesex Wildlife Trust. With your permission, we determine why and how your personal data is used (as outlined in this policy).
• ‘Data processor’: this is a person, or organisation, who processes your data on our behalf, with your permission. For example, this might be a mailing house who sends your membership magazine to you, on our behalf.

When we work with other organisations or individuals in this way, we always set up a written contract with them to protect your data. The third parties we work with at no point ‘own’ your data, so you will never hear from them independently and they will always delete your data from their systems when they have completed the task in hand. We always send your data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations. 

We will never sell your personal data.

Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:

Head of Fundraising and Communications
Telephone: 01727 858901
Email: info@hmwt.org  
Grebe House, St Michael's Street, St Albans, AL3 4SN
Our office hours are Monday – Friday, 9am – 5pm.

We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The ICO refers to this as a ‘lawful basis’. Further information about why we collect your personal data is outlined below.

a) To administer your HMWT membership

We collect your personal data to administer your membership, which may involve:

• Sending you your membership welcome pack when you first join us
• Processing your Direct Debit subscription payments, if you have set this donation process up with us
• Sending you your membership renewal letter
• Getting in touch should there ever be any issues processing your subscription payment.

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.

b) To send you items purchased from our online shop, including event bookings

We collect your personal data to send you:

• items you have purchased from our online shop
• information about events you have booked onto.

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.

c) To record your wildlife sightings

When you submit a wildlife sighting, we will collect your name, date and place of the sighting.  This information will be added to our database of wildlife records.

d) To send you information about our work and ask for your opinion

We also collect your personal data so that we can send you information about our work that we feel will be of interest to you. This includes your membership magazine, fundraising appeals, events, campaigning opportunities, membership services, products, newsletter requests, feedback, competitions and other activities, as well as information about other carefully selected organisations that we work in partnership with (such as Vine House Farm’s bird seed catalogue). From time to time, we may also use your personal data to ask for your opinion about our work.

The following information is in addition to that outlined in sections a) and b) and is defined as ‘direct marketing’ by the ICO.

1. Joint and family membership - If you are a ‘joint’ or a ‘family’ member of our Wildlife Trust, we will address communications to all those listed on your membership and where we have the necessary consent in place. If you wish to update this at any point, please let us know.

2. When your membership has ended - Unless we hear from you directly, we may continue to send you information about our work for up to 12 months after your membership has ended. This is just in case your support was cancelled accidentally, by for example changing your bank account details, and you wish to update your details with us.

Your personal data also helps us to get to know you better and to develop a ‘profile’ of you on our secure supporter database. This ‘profile’ enables us to send you the information listed above in a timely and relevant way, to suit you. For example, keeping track of the donations you make to our organisation helps us to send you information about fundraising appeals that we feel you would like to hear about. Likewise, keeping a record of your wildlife interests that you may tell us about in one of our Membership Surveys, helps us to send you relevant project updates.

As defined by the ICO, we use two different lawful bases for processing your data for ‘direct marketing’ purposes:

1. Legitimate interest

This is where we have identified a genuine and legitimate reason for contacting you, which does not override your rights or interests.

We use legitimate interest to send you the information listed above by post or telephone (if you are not registered with the Telephone Preference Service, and you have given us your telephone number).

2. Opt-in consent

This is where you have given us express permission to contact you by particular communication channels.

We use opt-in consent to send you the information listed above by email, text message (SMS) or telephone (if you are registered with the Telephone Preference Service)

We respect your right to update the way we get in touch with you about our work at any time.

e) To enable you to volunteer with us

If you are a HMWT volunteer, we collect your personal data so that we can keep in touch with you about, for example:

• changes to planned volunteer work programmes that you may be taking part in
• the positive impact you have on our work, by sending you relevant newsletters
• dedicated volunteer thank-you events.

As defined by the ICO, the lawful basis for processing your data for these purposes is ‘contractual’ (where administering your volunteer record) and ‘legitimate interest’ (when sending you information about our work).

f) To buy or sell goods or services

We collect personal data to comply with contractual responsibilities when we buy and sell goods and services from and to others. 

The ICO define the lawful basis for processing personal data for these purposes as ‘contractual’.

g) To meet our legal obligations 

We collect personal data in order to comply with legal obligations such as providing information to bodies such as HMRC, Charity Commission, Companies House and HSE.

The ICO define the lawful basis for processing personal data for these purposes as ‘legal obligation’.

h) To enable effective functioning of our organisation

We collect personal data to enable the Trust to operate effectively in a variety of ways such as: 

• responding to complaints and comments
• complying with regulators eg Fundraising Preference Service, Fundraising Regulator
• fundraising efficiently and effectively
• safeguarding, health and safety, security
• maintaining records of reserve management and local wildlife sites
• maintaining biological and geological records
• liaising with landowners and tenants about conservation activities
• running engagement activities such as events and competitions
• evaluating events, campaigns and website activity
• research and statistical analysis

The ICO define the lawful basis for processing personal data for these purposes as ‘legitimate interest’.

a) Basic information

We will usually collect basic information about you, including your name, postal address, telephone number, email address and your bank details if you are supporting us financially. 

Most of the time, we collect this data from you directly. Sometimes this is in person; other times, it is over the telephone, in writing, using a web-based form, or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (only where you have given permission for such information to be shared).

b) Getting to know you better

We also collect information about you that helps us to get to know you better. This may include:

• information about your wildlife interests, which you tell us through membership or other supporter surveys
• records of donations you have made, for example towards fundraising appeals
• details of purchases you have made, for example wildlife gifts or sponsorships
• your preferences of how you would like us to contact you
• ways you have helped us through volunteering your time
• records of events you have attended, or campaigns or activities that you have been involved in.

Sometimes we will collect other information about you such as your date of birth and gender. When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission.

As a fundraising organisation, we may gather information about you from publicly available sources, such as Companies House, the Electoral Register, company websites, social networks or property registers.  We may occasionally use profiling and wealth screening services provided by trusted third party organisations. These processes enable us to better understand and develop your relationship with us and ensure any requests for support are appropriate, proportionate and tailored. 

We may also use publicly available sources to carry out due diligence on donors or potential donors, in line with our Fundraising Policy and to meet money laundering regulations

If you would rather your personal data was not used in these ways, or have any questions then please contact us.

Head of Fundraising and Communications
Telephone: 01727 858901
Email: info@hmwt.org  
Grebe House, St Michael's Street, St Albans, AL3 4SN
Our office hours are Monday – Friday, 9am – 5pm.

Other ways in which we collect personal data to get to know you better include:

Our website

Our website uses ‘cookies’ to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

• Make our website work as you would expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you

For more information on our Cookies Policy, see annex 1.  

c) Sensitive personal data

We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and members. However, there are some situations where this will occur.

When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission. In these situations, we collect the data from you directly.

If you are a volunteer or applicant for work or member of staff then we may collect extra information about you, for example:

• references
• criminal records checks
• details of emergency contacts
• medical conditions

We may also collect sensitive personal data if you have an accident on one of our reserves. This information will be retained for legal reasons, for safeguarding purposes and to protect us (including in the event of an insurance or legal claim). If this does occur, we will take extra care to ensure your privacy rights are protected.

d) Children and young people

In line with data protection law, we will not collect, store or process your personal details if you are under 13 years of age; unless we have the express permission from your parent or guardian to do so.

If we have the permission of your parent or guardian, and you are a Wildlife Watch member, we will capture your date of birth at the point of joining. This is so that we can send you information that we feel is suitable to your age. 

For further information, please contact us for details of our Safeguarding Children and Vulnerable Adults policies.

a) Security

All of the personal data we process is processed by our staff in the UK. However, for the purposes of IT hosting and maintenance your information may be situated outside of the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff and relevant volunteers receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

b) Payment security

All electronic HMWT forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.

If you use a credit card to donate, purchase a membership or purchase something online we will pass your credit card details securely to our payment provider (Stripe).

Herts & Middlesex Wildlife Trust complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details.

We cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.

d) Data retention policy

We will only use and store information for as long as it required for the purposes it was collected for. We continually review what information we hold, and delete what is no longer required.

For further information on our data retention policy please contact us.

We respect your right to control your data. Your rights include:

1. The right to be informed

This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this policy, please contact us.

2. The right of access

If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request, we will respond within one month.

3. The right to rectification

If we have captured information about you that is inaccurate or incomplete, we will update it.

4. The right to erase

You can ask us to remove or randomise your personal details from our records.

5. The right to restrict processing

You can ask us to stop using your personal data.

6. The right to data portability

You can ask to obtain your personal data from us for your own purposes.

7. The right to object

You can ask to be excluded from marketing activity.

8. Rights in relation to automated decision making and profiling

We respect your right not to be subject to a decision that is based on automated processing. 

For more information on your individual rights, please see the Information Commissioner’s Office.

Herts & Middlesex Wildlife Trust want to exceed your expectation in everything we do. However, we know that there may be times when we do not meet our own high standards. When this happens, we want to hear about it, in order to deal with the situation as quickly as possible and put measures in place to stop it happening again.

We take complaints very seriously and we treat them as an opportunity to develop our approach. This is why we are always very grateful to hear from people who are willing to take the time to help us improve.

Our policy is:

• To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.
• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
• To make sure everyone in our organisation knows what to do if a complaint is received.
• To make sure all complaints are investigated fairly and in a timely way.
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
• To learn from complaints and feedback to help us to improve what we do.

Confidentiality
All complaint information will be handled sensitively, in line with relevant data protection requirements.

Responsibility
Overall responsibility for this policy and its implementation lies with the Chief Executive.

If you have any concerns or wish to give feedback then please contact us:

Telephone: 01727 858901
Email: info@hmwt.org  
Grebe House, St Michael's Street, St Albans, AL3 4SN
Our office hours are Monday – Friday, 9am – 5pm.

Information Commissioner’s Office

For further assistance with complaints regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk

Our websites contain links to third party websites that we believe may be of interest to our website visitors. This privacy policy only governs our website and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data.

We operate a number of social media pages (including Facebook, Twitter, YouTube and Instagram). Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:
Head of Fundraising and Communications
Telephone: 01727 858901
Email: info@hmwt.org
Grebe House, St Michael's Street, St Albans, AL3 4SN
Our office hours are Monday – Friday, 9am – 5pm.

We review this policy annually and update as required. We may make updates from time-to-time without notice. We therefore advise you to consult this policy frequently.

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Visitors to our website are given the opportunity to opt out of non-essential cookies.

Our cookies help us:

• Make our website work as you'd expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you

We do NOT use cookies to:

• Collect any personally identifiable information (without your express permission)
• Collect any sensitive information (without your express permission)
• Pass personally identifiable data to third parties
• Pay sales commissions

You can learn more about all the cookies we use below:

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaopto

The Trust collects a range of information about you. This can include:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the Trust needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.

The Trust collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

The Trust may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

The Trust needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

The Trust has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability and decide to whom to offer a role. We may also need to process data from applicants to respond to and defend against legal claims.

The Trust processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment and volunteering.

Where the Trust processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

For some roles, the Trust is obliged to seek information about criminal convictions and offences. Where we seek this information, it does so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment and volunteering.

If your application is unsuccessful, the Trust will keep your personal data on file for 6 (six) months in case there are future employment opportunities for which you may be suited. The Trust will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The Trust will not share your data with third parties, unless your application is successful and it makes you an offer of employment or volunteering. We may then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

The Trust will not transfer your data outside the European Economic Area.

The Trust takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

If your application is unsuccessful, the Trust will hold your data on file for 12 (twelve) months after the end of the relevant recruitment process. At the end of that period your data is deleted or destroyed.

If your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained in accordance with our retention policy. If you are employed by the Trust the periods for which your data will be held will be provided to you in a new privacy notice. 

We respect your right to control your data. Your rights include:

1. The right to be informed

This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this policy, please contact us.

2. The right of access

If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request, we will respond within one month.

3. The right to rectification

If we have captured information about you that is inaccurate or incomplete, we will update it.

4. The right to erase

You can ask us to remove or randomise your personal details from our records.

5. The right to restrict processing

You can ask us to stop using your personal data.

6. The right to data portability

You can ask to obtain your personal data from us for your own purposes.

For more information on your individual rights, please see the Information Commissioner’s Office.  If you believe that the Trust has not complied with your data protection rights, you can complain to the Information Commissioner.

The Trust’s full Privacy Policy can be found our website.

You are under no statutory or contractual obligation to provide data to the Trust during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

We will:

• Not tolerate any form of abuse or neglect within The Wildlife Trusts
• Take all reasonable steps to protect children, young people and adults at risk who visit our sites, take part in our activities or engage with us online
• Give equal priority to keeping all children, young people and adults at risk safe from harm, regardless of their age, disability, gender, race, beliefs, sex, or sexual orientation
• Provide our staff, volunteers and trustees with the knowledge and tools to guide them in protecting children, young people and adults at risk from abuse and neglect

We will achieve this by:

• Supporting staff and volunteers by establishing a clear policy and procedural framework, transparent reporting, and by promoting a culture of learning throughout the movement
• Encouraging staff and volunteers to discuss any concerns immediately or as soon as practically possible with the line manager/supervisor or designated safeguarding lead
• Listening to and hearing the voice of children, young people and adults at risk and respecting their views
• Recruiting our staff and volunteers safely including references, disclosure and barring checks as appropriate
• Recording and storing information safely and in accordance with the UK General Data Protection Regulation
• Recognising the position of trust in which staff, trustees and volunteers are regularly placed and use our procedures and work with our local authorities to manage any allegations against them appropriately
• Adhering to Online Safety guidelines to keep children, young people, adults at risk and staff safe when using any digital communications
• Ensuring that we provide a safe physical environment for children, young people, adults at risk, staff and volunteers by adhering to health and safety measures in accordance with the law and regulatory guidance
• Working in partnership with the statutory agencies responsible for the Safeguarding of children, young people and adults at risk
• Ensuring that any third-party individual or organisation involved in delivering activities on behalf of The Wildlife Trusts has appropriate experience, qualifications and/or accreditation and insurance. If they are operating with any degree of autonomy, Trust staff will assure themselves that safeguarding procedures are equivalent and arrangements are adequate for the activity.

We have policies for Safeguarding Children and Young People, and for Safeguarding Adults at Risk, and a Safeguarding Procedure. We review the policies annually, and we have a nominated Trustee for safeguarding matters who works with the Chief Executive and the staff team.

Our policy is:

• To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.
• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
• To make sure everyone in our organisation knows what to do if a complaint is received.
• To make sure all complaints are investigated fairly and in a timely way.
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
• To learn from complaints and feedback to help us to improve what we do.
• All complaint information will be handled sensitively, in line with relevant data protection requirements.
• Complaints must be made within a reasonable time.

If you have a complaint:

Please contact us either by:

• Calling 01727 858901
• Writing to HMWT, Grebe House, St Michael’s Street, St Albans AL3 4SN
• Emailing info@hmwt.org

Our procedure is:

• All complaints will be entered into a central register.
• All complaints will be investigated thoroughly and fairly.
• The complaint will be acknowledged within 3 working days, setting out who is dealing with the complaint and when a reply can be expected. 
• The complainant will be notified of the outcome of any investigation within 30 working days. If it is anticipated that the investigation will take more than 30 working days to complete, the complainant will be notified of this.
• Where the Trust is at fault we will endeavour to put things right as quickly as possible. In any case a full explanation will be given to the complainant.
• If the complainant is not satisfied with the outcome of the investigation then they may refer their complaint to the HMWT Chief Executive or Chair of Trustees.
• If the complainant remains unsatisfied by our final response then they will be signposted to the Charity Commission, and/or the Fundraising Regulator if the complaint is related to our fundraising practice.