Just Whippets Rescue (which means Just Whippets Rescue and their associated companies) is committed to protecting your privacy when you use our on-line, telephone or other services (“Services”). In this policy we explain how and why we collect your information, what we do with it and what controls you have over our use of it.
We will not sell your data to any third parties.
What data do we collect and how do we use it?
Just Whippets Rescue collects information from the public in a number of different ways. For example, we ask for contact and other information when members of the public rehome or adopt a dog. This may include information such as your name, date of birth and contact information. We use this information to help us provide and improve our services as a charity and to keep a record of our communications with you.
If you are a financial supporter of Just Whippets Rescue, we will ask for information that enables us to administer your donation. This will normally include information such as your name, contact details such as address, email or telephone number and your payment details and Gift Aid status.
If you have given us your consent, we will contact you with information and updates on our work, products and how you can support us, (such as fundraising). This may be by post, email or telephone, depending on your preferences.
What the Law says about protection of personal information
The Law on Data Protection is derived from various pieces of legislation (can be found in a number of places). These include the Data Protection Act and the incoming General Data Protection Regulation (the ‘GDPR’) which will become enforceable in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the legal grounds must apply.
The four legal grounds that are most relevant to Just Whippets Rescue’s use of your personal information are:
- Legitimate Interest
- Legal Obligation
How the law applies to Just Whippets Rescue’s use of personal information
Just Whippets Rescue will only process (use) your personal information if we have:
- asked you and have a record of your express and recent consent for us to do so;
- a ‘Legitimate Interest’ to do so in order to support our charitable purposes. Our use will be fair and balanced and never unduly have an impact on your rights.;
- a contract with you that we can only fulfil by using your personal information, e.g. to send you an item that you have requested;
- a legal obligation to use or disclose information about you, e.g. we are required by law to keep records of gifts that are given to us with Gift Aid for 4 years; and we are compelled to disclose information relating to incidents involving dangerous dogs for insurance purposes under the Dangerous Dogs Act.
In extreme situations, such as an accident or medical emergency, we may share your personal details with the emergency services if it is essential for the preservation of life (yours or another persons’) for us to do so. This is the ‘vital interest’ ground for using your personal information. After the emergency, we will always try to inform you about how we had to use your information in that extreme situation.
We will not unduly prioritise our interests as a charity over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.
Just Whippets Rescue will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities.
Just Whippets Rescue will always ask for your consent before we communicate with you for certain purposes. For example, we will only email or phone you about our fundraising activities if we have an accurate record of your recent and freely given consent to do so.
You can withdraw your consent at any time by emailing email@example.com.
There are times when it is not practical to obtain and record consent. At those times, we will only process personal information if that processing would meet another legal ground e.g. Legitimate Interests, in which case we would only process in accordance with the law’s strict rules on legitimate interest processing.
What is Legitimate Interest
This legal ground for processing means that organisations can process your personal information if they 1. have a genuine and legitimate reason for doing so and 2. That use does not harm any of your rights and interests as an individual.
Just Whippets Rescue’s Legitimate Interest
We do not unduly prioritise our legitimate business interests as a charity over your interests as an individual. We always respect your rights. Which is why we carry out a balancing exercise of the rights of the charity with the rights of our supporters.
We believe that the best way to look after the interests of our supporters is to consider their unique interests and expectations. As a result, we have established the following categories of Just Whippets Rescue supporter. This provides us with an additional method for assessing that we use your personal information in a way that matches your relationship with us; your interests; and your expectations about your rights.
The four groups for our data protection supporter needs assessments are, supporters that have:
- rehomed a dog with us
- provided financial donations
- demonstrated an interest in our cause by contacting us for more information, e.g. to find out more about one of our products or services.
What we have a Legitimate Interest to do
We believe that Just Whippets Rescue supporters are connected to our mission and want to know how they can continue to help us to achieve our charitable aims. Unless you tell us not to, we think you are content for us to process (keep and use) your personal information for the following lengths of time. As of May 2018, we promise not to keep your personal information for longer than we specify below. This is not the length of time that we will continue to contact you – this could be a shorter period of time (see below for an explanation on our personalised approach to communications).
For supporters who have indicated an interest or pledged to leave us a gift in your will – we need to keep your information to ensure that your wishes are fulfilled.
These are supporters that adopted a dog from Just Whippets Rescue and on average a whippet lives to the age of 16 years old. We think that you and the dog you adopted from us would like to remain in contact with us throughout their lifetime and we will therefore keep your personal information to allow for this.
Financial Supporters of Just Whippets Rescue
These are supporters that help or have helped us with financial gifts. A supporter’s pattern of giving can often change over time. We have found that our financial supporter’s cycle of giving is on average 6½ years. That means the supporter may, for this period of time, stop providing financial support. This can be for a wide number of reasons, including because they choose to support us in a different way. Irrespective of their financial circumstances, these supporters still hold the same principles and values; and continue to be connected to Just Whippets Rescue and our mission. This is evidenced by the fact that many of this group of supporters restart regular-giving, and other financial support, within 6½ years from their last donation. We believe that supporters of our mission never stop believing in the importance of improving the lives of dogs, but we do stop using the personal information of these supporters after 6½ years from the time of the last donation.
Demonstrated an interest in Just Whippets Rescue via an enquiry
These are supporters of our mission, who have demonstrated an interest in our cause by contacting us for more information, e.g. to find out more about one of our products or services. We think someone that has reached out to us to find out more about Just Whippets Rescue and what we do, would like us to provide that information; perhaps a little more information; and even some support in fulfilling their initial query or request. To support this, we keep your personal information for a period of 2 years.
Supporters demonstrate their support in a number of ways and so could be in more than one, or even all, of the above categories. We will review and refresh these categories and the timescales on a rolling basis to ensure that as times and needs change we continue to do the very best by our supporters.
It is always your choice. If you don’t think this is quite right for you, you can tell us to change your communication preferences and our use of your information. You can do this at any time by emailing firstname.lastname@example.org.
Legitimate Interest to send you direct mail
Unless you tell us not to, we will rely on our Legitimate Interest ground (explained above) for sending you direct mail. From time to time, we would like to post you exciting updates about our work, products and how you can support us, including fundraising activities. Unless you have requested that we do not send you some, or all of this, our direct mailings do include marketing and fundraising asks which further the aims and objectives of Just Whippets Rescue.
We are always mindful of trying to only send you what you are interested in and only as often as is appropriate. If we do not appear to be sending communications that are of interest, we will review this and will endeavour to reduce and then stop these types of communications in a much shorter time than the above defined period of Legitimate Interest e.g. if you donated three years ago and do not seem to have been interested since then we are likely to reduce these communications, even though we have a legitimate interest to process for 6 ½ years. The average length of time required for us to be able to properly assess and reflect on your pattern of response is about two years. But you’re in control so if you want to ensure that we do not send this type of communication anymore, you can update your preferences at any time emailing us at email@example.com.
Legitimate Interest to process your information
We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.
When it is necessary we will contact you for administrative purposes, e.g. to contact you regarding a payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.
To help you to understand when and why Just Whippets Rescue would use Legitimate Interest to process your personal information we provide the following examples:
- To send postal communications (as explained above)
- To enhance, modify, personalise and improve our services and communications for the benefit of our supporters.
- To improve security of our websites and systems.
- To prevent fraud when transacting on our website.
- To process your donations.
To fulfil online transactions; process and deliver your order(s). To take payment and arrange delivery, we need to collect personal information, including your payment details, your full name, delivery address and contact details.
To analyse your personal information to ensure that our communications are relevant to you.
The above list of examples are on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop. You can do this at any time by emailing firstname.lastname@example.org.
In order to communicate with you more effectively, better understand your preferences and ability to support our work, we may analyse your data.
We like to find out about your personal motivation for supporting Just Whippets Rescue and your experiences as a supporter. This helps us to give you the information about products most relevant to you. In some instances, we may carry out research and/or analysis of the personal information that you have provided to us and add publicly available information (such as public records or social media) to help us tailor our communications to you, this may include wealth screening. We do this to create a fuller picture of our supporters, to improve our service and to manage our contact with you in an appropriate and cost-effective way. This information could include things like your interests, preferences and the level of any potential donations.
Just Whippets Rescue do not share, sell or swap your information with other organisations for their own marketing outside of our group.
In some circumstances it is necessary for Just Whippets Rescue to give relevant staff at our service providers access to your personal information. This access is only granted to the extent necessary for them to perform their services for us. We require all service providers to comply with strict rules to protect the information you have given us.
Changes to your data
From time to time we may contact you to ensure that the information you have provided us with remains accurate and up to date. In some circumstances we may use external data lists to avoid misdirecting our communications with you, this includes FPS and TPS.
Should you wish to change your preferences you can do this by email to email@example.com.
Like all organisations, we comply with requests for the disclosure of personal information where this is required or permitted by law. This could include requests from law enforcement or tax agencies. In these circumstances, the request must be submitted in writing and in accordance with the relevant legal requirements.
If you believe your privacy rights have been violated, you may file a complaint with us or with the Information Commissioners office https://ico.org.uk/
Log files/IP addresses
When you visit our Web Sites, we automatically log your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. We use IP addresses to help us administer our Web Sites and to collect broad demographic information for aggregate use. We do not link IP addresses to personally identifiable information.
Non personal information
We may automatically collect non-personal information about you such as the type of internet browsers you use or the site from which you linked to our Web Sites. You cannot be identified from this information and it is only used to assist us in providing an effective service on our Web Sites. We may from time to time supply the owners or operators of third party sites from which it is possible to link to our Web Sites with information relating to the number of users linking to our Web Sites from their sites. You cannot be identified from this information.
Updated April 2018, GDPR Compliant.