The Sir Peter O’Sullevan’s charitable trust’s Privacy Notice

We are delighted that you have shown interest in our organisation. Data protection is of a particularly high priority for the Sir Peter O’Sullevan’s charitable trust {the trust, we,our}.

This privacy notice explains how we process your personal information when you visit our website and/or if you’re a contact, donor, customer, applicant for funding or attend our annual event. It explains how we will protect data subjects, information and personal data, and the controls and safeguards we provide for this data. This includes understanding, at all times, precisely what data we’re storing for and about you, who (if anyone) can see that data, and whether you give permission for that data to be shared with third-parties.

The processing of personal data, such as the name, address, e-mail address, or telephone number shall always be in line with the General Data Protection Regulation (GDPR), The Data Protection Act 2018 and Privacy and Electronic Communication Regulations (PECR).

By means of this data protection declaration, we would like to inform you of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

Specific data protection declarations will be provided separately when booking onto the trust’s events, this will allow for the nuances of such event data processing to be communicated to you in a transparent manner.

TOPICS

Who we are?

The trust is an independent 22-year-old registered charity of England and Wales (294344). We focus predominantly on animal-related, racing welfare and equine causes supporting the legacy of Sir Peter O’Sullevan CBE. In total we have distributed £5 million equally between the six charities we support which are:

  • Blue Cross
  • Brooke
  • Compassion in World Farming
  • World Horse Welfare
  • Racing Welfare
  • British Thoroughbred retraining centre

In addition, the Trust has pledged over £2.5 million to other charitable causes.

Our principle fundraising activity is The Sir Pete O'Sullevan award lunch held annually, but we also sell a range of prints, cards and books and accept donations via our website.

The information we collect about you, why we need it and who it’s shared with

We collect information depending on the relationship we have with you but typically this would be:

  • When you donate money to our trust;
  • When you purchase a product or service from the trust
  • When you contact us by any means with queries, complaints etc. including via web-forms or contact emails;
  • When you ask one of our team to email you information about donating, a funding application or other products or services we offer;
  • When you register for any kind of event with us;
  • When you choose to complete any surveys we may send to you;
  • When you contribute any personal information to a processor of ours i.e. for the purposes of personalised products or services such as Christmas Cards

The personal data we may collect from you and process is:

Personal data type Source
Title, First Name & Last Name Taken via email, post or phone for processing a funding application/Attendance at a trust event/Web Form Entry/Donation via PayPal/Personalised Cards/Website Payment
Email Taken via email, post or phone for processing a funding application/Attendance at a trust event/Web Form Entry/Donation via PayPal/Website Payment
Company Postal Address Taken via email, post or phone for processing a funding application/Attendance at a trust event/Web Form Entry/Donation via PayPal/Website Payment
Personal Address Taken via email, phone or post for processing a funding application/Attendance at a trust event/Web Form Entry/Donation via PayPal/Website Payment
Telephone Number Taken via email, phone or post for processing a funding application/Attendance at a trust event/Web Form Entry/donation via PayPal/Website Payment
Debit or credit card, Bank details, Cheque Information Taken via email, phone or post for processing a funding application/Attendance at a trust event/ Donation via PayPal/Website Payment
Dietary Requirements/Health Conditions Provided if attending any Trust Event

The personal data we collect may be used for the following purposes depending on the relationship we have with you:

  • Processing a donation that you have made to the Trust
  • Processing a payment that you have made for the Trust’s products or services;
  • Managing and using any contributions you provide to us, whether via the site or otherwise for our campaign purpose or our activities; 
  • Processing a funding grant;
  • Sending you information about the trust, our events, activities and campaigns and for marketing/campaigning/fundraising purposes;
  • Responding to correspondence you have sent to us.

In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

The legal basis we use under the General Data Protection Regulation for the processing of personal data:

  • Our legitimate interests as the Sir Peter O’Sullivan’s charitable trust
  • Your consent
  • Any Legal Requirement we may have

Processing through use of our Legitimate Interests

Broadly speaking this means that we are processing your personal information if:

  • We have a genuine and legitimate reason and we are not harming any of your rights and interests

The legitimate interests we pursue are to run a charity in favour of the well-being of all our members, donors, employees, trustees and for the good of the recipient charities of our support.

When you provide your personal details to us we use your information for our legitimate business interests to carry out our work providing help and support to animal-related, racing welfare and equine causes in the UK. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.

Some typical examples of when we might use this lawful basis are for direct marketing such as sending reminder cards via post to individuals who have attended one of our events as a delegate in the past, maintaining the security of our system, data analytics, research, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.

Direct marketing/Fundraising is generally seen as an important tool, but we want to respect the wishes of the recipients of these communications. For this reason, we have undertaken a balancing test to compare our legitimate interests versus your interests and indeed fundamental rights and freedoms, which require the protection of personal data.

We believe that the recipients of our marketing have a reasonable expectation that the trust will store and process their Personal Data in this manner.

Our assessment has taken into consideration the technical and organisational security measures that the trust is implementing in 2018 and the safeguards being put in place in regard to your privacy, and the protection of your personal data.

The trust conducts Data Protection Impact Assessments with outputs that support privacy by design and default and include:

  • Always ensuring we have identified a legal basis for processing;
  • We are transparent about we use personal data via our privacy notice;
  • Data minimization and only requesting or retaining information we absolutely need de-identification and anonymization;
  • We have ensured that we have commercially reasonable and appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed;
  • Adding extra transparency;
  • Data retention limits depending on what we’re using it for;
  • Restricted access to systems;
  • Where appropriate encryption, hashing, salting; other technical security methods used to protect data;
  • Privacy training;
  • Engaging a data privacy consultant

The likelihood of impact and the severity of negative impact of our processing on your data has been assessed and deemed to be negligible.

Processing using Consent

There are certain circumstances, particularly in regards electronic marketing and fundraising communications where we may need consent from you, in order to process your data.

If this is the case we will ensure that the consent that you we request and you provide is by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data relating to you.

The trust is monitoring future developments in EU electronic marketing regulation presently being in debated and subject to change via the EU Council. EU Parliament and newly formed European Data Protection Board.

Email Marketing and Fundraising

In relation to any email marketing that you may receive from us, either at your request or in any other circumstances, we may monitor whether you open and/or click on any links in such emails and we uses various tracking techniques to measure the effectiveness of our email campaigns and tailor our communications to your interests.

If you no longer wish to receive these emails, you can unsubscribe directly by following the instructions in the relevant communication.

We conduct this email marketing in adherence with the Privacy and Electronic Communications Regulation which derive from the European Directive 2002/58/EC.

If you make a donation, we’ll use any personal information you give us to record the nature and amount of your gift and thank you for your gift. If you interact or have a conversation with us, we’ll note anything relevant and store this securely on our systems.

Charity Commission rules require us to be assured of the provenance of funds and any conditions attached to them. We follow a due diligence process which involves researching the financial soundness, credibility, reputation and ethical principles of donors who’ve made, or are likely to make, a significant donation to the Trust.

We’ll always act upon your choice of how you want to receive marketing communications (for example, by email, post or phone). However, there are some communications that we need to send.

These are essential to fulfil our promises to you as a donor or buyer of goods or services from the Trust. Examples are:

  • Transaction messaging, such as payment confirmation, donor purchase confirmations and event booking confirmations and chase ups

Who your information is shared with

The trust will share your personal data with third parties only for the purposes of essential sub-contracted processing. We will seek assurances that these contractors/processors have in place appropriate technical and organizational measures to safeguard the security of your data. Where appropriate robust data processing agreements will be in place as per article 28 of the GDPR and mechanisms allowing the monitoring of such safeguards will be agreed.

For example, if you make a donation or payment on our site, cookies are used by PayPal to enable your visit to be identified between page loads, and to make sure that at the payment point only your specific computer can continue with payment. These cookies are destroyed each time you close your browser. You can find PayPal’s privacy policy at the following link - https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Website cookies and tracking software

You do not have to give us any personal data in order to use this website. However you may provide us with personal data by completing forms on this website or by contacting us by telephone or email.

Outside of this when you visit this website we do not use any tracking technology or cookies to identify you in anyway. You can browse our website completely anonymously.

Your privacy rights explained

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you free of charge.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that the trust refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Other websites

On occasion our website will contain links to other websites, for example to purchase framed prints. This privacy policy only applies to the trust’s website. When you link to other websites you should read their own privacy policies.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 6th June 2018.

How long we keep your personal data

How long we keep information collected about you.

Any information provided by you will be retained for as long as necessary in connection with the purposes for which it was provided, for example, to respond to your enquiry or to understand the preferences of our supporters. In respect of any contact information stored within our electronic filing systems, we will delete your details upon request and if we have not had any further communication with you within a period of 3 years.

If decide not to support the Trust any more or request that we have no further contact with you, we will keep some basic information in order to avoid sending you unwanted materials in the future and to ensure that we don’t accidentally duplicate information. We will always dispose of your personal information securely, using specialist companies if necessary to do this work for us.

In any case, once we have processed any information about you in connection with the purposes for which it was provided or collected, we will securely delete or anonymise (to the extent such information was capable of identifying you in the first instance) such information upon expiry of the above time periods.

How to contact us in regards your rights, or to make a complaint

In the event that you wish to make a complaint in regards to how your personal data is being processed by the trust (or the third parties above), please contact the trust’s data protection representative, if you are unhappy with how your complaint has been handled, you have the right to lodge a complaint directly with the ICO.

  Data Protection Representative contact details
Contact Name The Sir Peter O'Sullevan Charitable Trust, c/o Nigel Payne
Address line 1 c/o The Old School
Address line 2 Bolventor
Address line 3 Cornwall
Post Code PL15 7TS
Email nigel@earthsummit.demon.co.uk
Telephone 07768 025265