Battersea Privacy Policy

CONTENTS

  1. Who we are
  2. Data protection
  3. Types of personal data we collect
  4. Where does this information come from?
  5. How we use your data
  6. Rehoming
  7. Volunteering
  8. Marketing & Fundraising
  9. Financial transactions
  10. Analysing your information
  11. How the law applies to Battersea’s use of personal information
  12. Data retention
  13. Data storage
  14. Data sharing
  15. Your data protection rights
  16. Filming and photography at events
  17. Notification of changes to this privacy policy
  18. What to do if you are not happy
  19. Contact us
  20. Cookie Policy

WHO WE ARE

Battersea is here for every dog and cat, and has been since 1860. We believe that every dog and cat should live in a home where they are treated with love, care and respect.

Battersea Dogs & Cats Home is a company registered in England and Wales (company no. 278802) and a charity registered in England and Wales (charity no. 206394). Please note that our trading company (Battersea Dogs Home Limited) (company no. 3472633) is wholly owned and controlled by our charity and any information we collect may be used by both entities.

DATA PROTECTION

Our commitment to care doesn’t stop at our animals. We care about your personal data and ensuring you’re informed about how we use it. Battersea promises to protect your data, and to manage any information you share with us in line with data protection laws.

This Privacy Policy sets out how and why Battersea (including both the charity and the trading company) will collect and use your personal data and our legal basis for its use, to ensure you remain informed and in control of your information.

Please read this policy carefully, along with our Terms and Conditions and any other documents referred to in this policy, to understand how we collect, use and store your personal information.

If you have any questions about how Battersea processes your information, please get touch using the details in the “Contact us” section below.

TYPES OF PERSONAL DATA WE COLLECT

Depending on your interaction with Battersea, we’ll collect the following types of information about you:

  • Your contact details, such as name, postal address and email address
  • Your date of birth
  • Your financial information such as bank account details
  • Your Gift Aid declaration
  • A record of our communications with you
  • Your communication preferences
  • Your giving history
  • Your interests, and reasons for your support
  • Information collected as part of our rehoming service, such as details relating to your personal circumstances
  • Information about your dog or cat, such as their behaviour, medical conditions and treatments as part of the gifting process
  • Your next of kin details, such as when you are participating in a Challenge Event

Sensitive information

Under data protection law, certain categories of personal information are recognised as sensitive, including health information, race, religious beliefs. Battersea will sometimes collect sensitive personal data in connection with our rehoming services (for example that the right animal is rehomed with you), or where you volunteer or apply for a job with us. In these cases we will obtain your consent to process this data, or alternatively ensure that we have a valid legal basis for doing so, such as when it is in the substantial public interest.

WHERE DOES THIS INFORMATION COME FROM?

Most personal data we process is given to us directly by our supporters, customers and volunteers in the course of their interactions with us.

We may also receive your personal information when you donate to Battersea through third-party services such as Just Giving or Virgin Money Giving.

We occasionally use external lead-generation organisations to provide us with the contact details of people who’ve expressed an interest in Battersea, and agreed to receive communications from us. In addition, we sometimes conduct research using third party sources, as set out in the “Analysing your information” section below.

In some situations, we may update our supporters’, customers’ and volunteers’ personal information using information from public registers or other agencies. For example, we might do this to check we have a valid and deliverable postal address for you, or to check if you are on Telephone Preference Service (TPS) or Fundraising Preference Service (FPS).

HOW WE USE YOUR DATA

In simple terms, your personal data may be used to help us effectively deliver our charitable services or to help us raise funds for those charitable services.

We have summarised below the different reasons why we do this (these are often referred to as ‘purposes’). How we use your data for these purposes will depend on the nature of our relationship with you.

CATEGORYEXAMPLES OF PURPOSES FOR WHICH WE COLLECT, STORE AND PROCESS YOUR DATA

Rehoming dogs and cats

  • If you have registered to rehome a dog or cat from us we will use the information you provide us to help us find you the right animal
  • To provide you with aftercare services once you have rehomed an animal
  • To communicate with you regarding our wider work and how you might support Battersea in other ways

Taking in dogs and cats

  • If you have contacted us to gift us your dog or cat for adoption, we will use the information you provide us to establish how we can best look after your dog or cat while it is in our care
  • To assess how we might safely and permanently rehome your dog or cat
  • To enable us to meet the relevant legal requirements where they apply to dogs or cats brought into our care

Reporting lost or found dogs and cats

  • To register details of a lost or found dog or cat for the purposes of reuniting owners with their pet

Volunteering

  • To enable us to recruit volunteers and foster carers
  • To support and train volunteers and ensure their safety
  • To enable us to communicate with volunteers regarding their volunteering work, the wider work of Battersea and how they might support in other ways

Marketing and Fundraising

  • To send you marketing including behind the scenes news, updates about our animals, general information about rehoming, volunteering and various ways you can support Battersea, including fundraising, events and campaigning
  • To efficiently raise the fundraising income to allow us to be here for every dog and cat
  • To manage, facilitate and record financial transactions associated with fundraising
  • To manage events and fundraising activities
  • To manage Battersea Best Friend membership including renewal
  • To ensure that as many supporters as possible maximise the value of their donation through Gift Aid

Legacies

  • If you have got in touch with us about leaving us a legacy, we will manage and administrate your legacy pledge

Events

  • To process registration fees, administer events

Media & PR

  • Contacting you about press enquiries and case studies to help promote our work

Analysis, targeting and segmentation

  • To better understand our supporters and allow us to serve you messages and marketing that are optimised for you and tailored to you, and to find more people like you

Donations

  • To process your donation and send you a thank you letter
  • We may also use your personal information for the recovery of Gift Aid (where you have completed a Gift Aid declaration)

Retail trading and online purchases

  • To fulfil orders for goods and services

Enquiries

  • To enable us to record, consider and reply to enquiries

Research

  • To send you surveys
  • To carry out research in relation to our supporters and services

Employment

  • To enable the Home to select and recruit staff

REHOMING

When you rehome one of our dogs or cats we ask you to provide us with information about your home, personal circumstances, and in some cases health or mobility requirements so that we are better able to match you with an animal that is going to best meet its, and you or your family’s needs.

We will also ask for certain information about your animal and you (including the reason or circumstances that led to you needing to rehome your pet, and any information about your pet's behaviour towards yourself and others in the household that will help us with their care or onward rehoming) when you bring in an animal that you would like to be rehomed, or that you are reporting as a stray.

We also ask for this information so that we can comply with the relevant legal requirements when rehoming an animal such as establishing the legal ownership of animals or updating microchip details.

VOLUNTEERING

Volunteers provide invaluable support across all aspects of Battersea. Where you have provided us with your information to volunteer, we process this in order to recruit volunteers and foster carers (for example, by reviewing volunteering applications), support/train volunteers and communicate with you generally about the work we do to ensure that you are kept well informed about Battersea, your own volunteering and how you can get more involved.

As mentioned, in some cases we may collect sensitive data about you so that we can ensure that you are matched with the most appropriate animal (where you are fostering a cat or dog), meet any access, health or dietary needs you may have and to monitor equality and diversity.

MARKETING AND FUNDRAISING

Battersea’s marketing activity helps to find more animals permanent and loving homes, and helps us to raise the income we need which enables us to do this. Our marketing activity also helps us to provide help to animals beyond our gates, such as through our community engagement work, educational and campaigning activity.

Battersea will seek your consent to send you marketing via email, phone or text message (SMS). If you choose to hear from us in this way, you’ll receive behind the scenes news, updates about our animals, general information about rehoming, volunteering and various ways you can support Battersea, including fundraising, events and campaigning. Examples include a monthly update email, emails inviting you to events, and email updates on our campaigning activity

Battersea will rely on legitimate interests to send you marketing and fundraising communications by post, if you have provided a postal address. Unless you tell us not to, we’ll contact you by post with communications we believe you’ll be interested in. If you would like to opt out of these communications, you can let us know by contacting us.

When you register to attend or take part in one of our fundraising or challenge events we will use you information to process the registration fees (if any), administer your participation in the event and provide you with information about the event.

We will never rent, swap or sell your details for marketing purposes.

You’re free to change your contact preferences at any time, just let us know by contacting us.

FINANCIAL TRANSACTIONS

If you donate to us, or buy something from us, we’ll process your debit or credit card details. We will also pass your card details securely to our payment-processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Security Standard and don’t store the details on our website or databases.

If you have kindly added Gift Aid to your donation to Battersea we must record the fact that you are a UK taxpayer and we have to maintain a record of the amount of Gift Aid we have claimed.

When you purchase an item from one of our centers or our online shop, we will collect certain information from you including your name, address, phone number, email address and payment details, so that we can process and send you your item or contact you if we have any queries regarding your purchase.

Where you purchase something from our online shop you will be asked to create an account which you can use to purchase additional products in the future, or if you wish to rehome a cat or dog.

ANALYSING YOUR INFORMATION

It’s important for us to know why you choose to support Battersea, as this helps us to give you the information that is most relevant for you. We’ll analyse your data in order to better understand your preferences, to improve our services, and to tailor our marketing communications to you. The information we’ll use to do this might include things like your interests, preferences, and level of potential donations so that we can see who may be interested in supporting us or who may be able and willing to give more.

In some instances, we may add publicly available information to our analysis. This might include information that is contained in the Companies House or Charity Commission Registers, press and web articles and Linked In.

Battersea uses the Mosaic postcode-based segmentation tool from Experian Ltd to understand the demographic make-up of geographical areas of the UK. This allows us to get a better understanding of the types of people who live in different parts of the country.

Battersea also carries out click-through email tracking, which allows us to analyse when an email has been interacted with (e.g. opened or when links within it are clicked). This helps us to better understand the impact of our communications and success of our campaigns.

HOW THE LAW APPLIES TO BATTERSEA’S USE OF PERSONAL INFORMATION

We are required under law to make sure that we have a valid ground for processing your data. The law sets out six different grounds for when personal data can be processed (plus additional ones where sensitive data is used) The four legal grounds that are most relevant to Battersea’s use of your personal information are:

  • Consent
  • Legitimate Interest
  • Contract
  • Legal Obligation

Overview

Battersea will only process your personal information if any of the following apply:

  • We have asked you for your express consent and have a record of this (for example, we will ask for your consent to send you marketing communications by email)
  • We have a legitimate interest to do so. Our use will be fair and balanced and never unduly have an impact on your rights (for example, it is in our legitimate interests to analyse the data you provide so that we can improve our services and tailor our communications to you)
  • We have a contract with you which we can only fulfil by using your personal information (for example, if you purchase something from our shop)
  • We have a legal obligation to use or disclose information about you (for example, we are required by law to keep a record of Gift Aid declarations for six years).

Consent

In some cases we will rely on consent, for example, to send you or make marketing and fundraising emails, phone calls and text messages.  In addition, if you register as a Battersea volunteer it can be very helpful if you share information on any medical conditions that may affect your ability to perform your voluntary work. You can withdraw consent for these channels and activities by contacting us.

Legitimate Interests

This legal ground for processing means that we can process your personal information if we have a genuine and legitimate reason for doing so, and that reason is not overridden by your rights and interests as an individual.

Examples of the legitimate interests processing activities we undertake are:

To allow us to provide the best possible care for every dog and cat

  • To assess suitability for rehoming and to follow up with you about your rehoming enquiry
  • To capture the information we need when we take in an animal, to allow us to care for that animal and ultimately rehome it
  • To provide you with aftercare services once you have rehomed an animal from us
  • To conduct home visits to assess suitability as part of the rehoming process
  • To register new owners’ details with microchip databases

To raise the fundraising income to allow us to be here for every dog and cat

  • To process your donations and Gift Aid where you have asked us to do so
  • To send you marketing communications by post

For administration purposes

  • To provide you with information necessary to an event you have signed up for
  • To provide you with information about any fundraising activities you have agreed to take part in
  • To follow up with you about your enquiry

To conduct research

  • To conduct supporter satisfaction research
  • To invite you to take part in surveys or research to help improve our services
  • To conduct desk research to help identify high value supporters

To analyse data to better understand our supporters and tailor our communications to them

  • To analyse your data in order to better understand your preferences, to improve our services, and to tailor our marketing communications to you
  • To use public sources to add to our analysis
  • To conduct segmentation to allow us to make our marketing communications more relevant to you, and to enable us to identify potential new supporters

To recruit and manage volunteers

  • To assess volunteer (including foster carer) applications and recruit volunteers
  • To communicate with volunteers about information that is essential to their role, and about the wider activities of Battersea
  • To process volunteers and foster carers data to effectively administer their close relationships with Battersea and provide them with appropriate care and support

We have considered and balanced our legitimate interests against individuals’ privacy rights in these scenarios and we do not believe that any adversely affect our supporters’ rights or interests. If you would like to find out more or ask us to stop processing your data in these ways, you can do this at any time by contacting us.

Contractual Relationships

In some cases, we will be under a contractual obligation to provide you with goods and services, which means that we have to process your data in order to fulfil those obligations. Some examples of this include if you are a Battersea Best Friend, or if you are rehoming a dog or cat from us, or purchasing something from our shop.

A legal obligation

Sometimes we may have a legal obligation to process information about you – for example we are obliged to keep financial records including Gift Aid for six years.  We’re required to notify the local dog wardens about strays that come into our care, and we’re also required to keep a record of your communication preferences, in accordance with the General Data Protection Regulation.

DATA RETENTION

We’ll retain personal information for different periods of time depending on your relationship with Battersea.

For example, if you donate to us, we’ll keep your financial information for up to seven years after your last interaction with us. If you rehome an animal, we’ll keep details relating to your rehoming circumstances for 20 years (the upper limit lifetime of the dog or cat).

We will keep some data indefinitely (for example, your name and giving history). It’s important for us to retain this information as a majority of Battersea’s legacy income comes from people we weren’t aware would leave us a gift in their will. Sometimes this legacy is left decades after the supporter’s last interaction with Battersea. Knowing that the individual was a supporter in the past is important for us to know in case that will is contested.  

In these cases, we’ll only retain data that is necessary for these purposes, and we will delete or anonymise other parts of the record.

If you decide you no longer wish to hear from us, we’ll need to keep a note of that on our suppression list indefinitely.

If you’d like more information on our retention policy, please contact us.

DATA STORAGE

Battersea’s operations are based in the UK and we store our data within the European Economic Area (EEA).

Some organisations which provide services to us may transfer personal data outside the EEA for processing purposes, but we’ll only allow them to do so if your data is adequately protected (for example, if they are certified under the EU/US Privacy Shield scheme, or if we have a prescribed contract in place with them).

DATA SHARING

Battersea or its trading subsidiary will not exchange or sell your personal information to another organisation for their own marketing purposes.

However, there are some situations where we may have to share your personal information with other organisations.  An example could be sharing your details to reunite you with a lost animal via a Local Authority Dog Warden, or to update microchipping databases. In some cases, we may have to share data about you when requested to do so by statutory agencies, such as the police.

We may also share your data with our contracted suppliers, and external service providers, such as our:

  • email service providers;
  • fulfilment houses;
  • fundraising agencies;
  • and marketing agencies.

In these situations, the relationship between Battersea and the third-party data processor will be governed by a contract and strict security requirements will be in place to protect your personal information.

YOUR DATA PROTECTION RIGHTS

When Battersea is using your personal information on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to ask Battersea to stop using your personal information for direct marketing purposes. Simply contact us and we will amend your contact preferences.

Presuming that these rights are not overridden by our legal obligations, or where our legitimate interests are not overridden by your rights and interests as an individual, you have the following data protection rights:

Right to be Informed

You have the right to be told how your personal information will be used. This policy document, and shorter summary statements used on our communications, are intended to be a clear and transparent description of how your data may be used.

Right of Access

You can contact us asking what information we hold on you and to request a copy of that information. From May 2018 we will have 30 days to comply once we are satisfied you have rights to see the requested records and we have successfully confirmed your identity.

Right of Erasure

From May 2018, you have the right to be forgotten (i.e. to have your personally identifiable data deleted). We’ll be required to keep an appropriate record (such as a suppression list) so that we can make sure you don’t receive future communications.  In some instances a legal basis will override the right to erasure.  An example of this would be the legal requirement to record financial transactions for six years.

Right of Rectification

If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated.

Right to Restrict Processing

In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

Right to Data Portability

Where we are processing your personal data under your consent the law allows you to request data portability from one service provider to another. This right is largely seen as a way for people to transfer their personal data from one service provider to a competitor.

Right to Object

You have an absolute right to stop the processing of your personal data for direct marketing purposes.

Right to object to automated decisions

In a situation where a data controller is using your personal data in a computerised model or algorithm to make decisions that have a legal effect on you, you have the right to object. This right is more applicable to mortgage or finance situations; Battersea does not undertake complex computerised decision-making that produces legal effects.

If you want to exercise any of these rights, please contact our Supporter Services team on: Phone: 0300 323 1216 Email: supporterservices@battersea.org.uk Post: Supporter Services Team, Battersea Dogs & Cats Home, 4 Battersea Park Road, London SW8 4AA.

FILMING AND PHOTOGRAPHY AT EVENTS

Please note that Battersea (or our authorised service providers) or our commercial partners may film or photograph participants, volunteers and spectators attending or taking part in events and use such footage or photographs.

We do this in order to publicise the event for commercial and/or fundraising purposes including, but not limited to: television broadcasts, advertising, publications, marketing material, merchandising, social media, personalised direct mail and other media that may be made available to the public. Secondly, to enable our commercial partners to publicise their involvement and/or association with the event.

No personal details (including names) of any under 16-year-old participants will be used in any publicity materials without the written consent of their parent or legal guardian, but we may use images where children are incidentally included (for example, images of mass participation in the warm-up exercises, or on the starting line).

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may change from time to time. For example, we will continue to update it to reflect new legal requirements. Please visit this website page to keep up to date with the changes to our Privacy Policy.

WHAT TO DO IF YOU ARE NOT HAPPY

In the first instance, please talk to us directly so we can help resolve any problem or query. You can reach our Supporter Services team on: Phone: 0300 323 1216 Email: supporterservices@battersea.org.uk Post: Supporter Services Team, Battersea Dogs & Cats Home, 4 Battersea Park Road, London SW8 4AA.

You can also register with the fundraising preference service (FPS). This service is run by the Fundraising Regulator and allows you to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at www.fundraisingpreference.org.uk or by calling 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days.

You also have the right to contact the Information Commissioners Office (ICO) if you have any concerns about Data Protection using their help line 0303 123 1113 or at www.ico.org.uk

Contact us

If you have any questions about this Policy, or about how Battersea manages your data, please contact our Supporter Services team:

Phone: 0300 323 1216

Email: supporterservices@battersea.org.uk

Post: Supporter Services Team, Battersea Dogs & Cats Home, 4 Battersea Park Road, London SW8 4AA.

COLLECTION OF DATA THROUGH COOKIES

1. What are cookies

Like most websites, we use cookies.  Cookies are tiny pieces of data saved on your computer or mobile device.  There are several types of cookie and they each have different functions or uses.

2. How do we use cookies

2.1 We use the following types of cookies:

(a) Essential cookies – these are required for the operation of our website and include, e.g. to enable you to log in to secure areas of the website or make use of a shopping cart and e-payment services.

(b) Analytic/performance cookies - these allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it.  This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

(c) Functionality cookies – these are used to recognise you when you return to our website so that we can personalise our content for you and remember your preferences, e.g. whether you are signed up to email alerts.

(d) Targeting cookies – these record your visit to our website, pages you have visited and links you have followed.  We may use this information to make our website and the advertising displayed to you more relevant to your interests, and may share this information with third parties for this purpose.

2.2 The table below provides more information about the cookies we use and why:

Type of cookie

Function and further information

Google Analytics

This is common performance cookie that many websites use.  It allows us to collect anonymous information about how you and other users use our website and helps us to improve the Website.

Facebook Pixel

To monitor how useful our Facebook advertising is to users and enable them to be served Facebook adverts that are relevant to them.

SSESS

To recognise users when they move from page to page within our Website and remember any information they have entered.

Quantcast (_qca)

This may use user computers’ IP addresses, pixel codes, HTTP locations, search strings, time of access, searches made on the Website and other statistics in order to analyse Log Data from different websites and combine it with other non-Personally Identifiable Information to produce the reports that are made available on the Quantcast site.  This enables web publishers and advertisers to deliver audience segments that are appropriate for their products or services.

3. Third party websites and social networks

If you click on a hyperlink from our website to any third party websites (e.g. if you ‘share’ content from our website with friends or colleagues on social media), you may be sent cookies from these third party websites.  They will do so pursuant to their own policies on privacy and cookies.  It’s a good idea to check their privacy policies to fully understand their use of cookies.

4. Disabling cookies

4.1 By using our website you consent to our use of cookies as updated from time to time and the cookies we use will be stored on your device (unless rejected or disabled by your browser).

4.2 Internet browsers normally accept cookies by default.  However, it is possible to set an internet browser to reject cookies.  If you do not accept our use of cookies as set out in this policy, please set your internet browser to reject cookies.  This may impair your ability to use our website so that some features may not work.

5. Changes to this policy and further information

5.1 We may update our use of cookies, and this policy, from time to time, so please check this policy regularly.

5.2 You can find out more about cookies generally and how to disable them at www.allaboutcookies.org or by contacting digital@battersea.org.uk