Privacy Notice: how we respect privacy when we deal with personal information collected by our organisation.
RSPCA Branches are independently registered charities run according to national RSPCA Branch rules. We respect your privacy and are committed to protecting your personal data.
This notice will tell you how we, the RSPCA Guildford and Epsom Branch (the Branch) will treat the information we collect about individuals who interact with us. Please read this privacy notice together with any other information that we may provide on specific occasions when we ask to collect or process your personal data so that you are fully aware of how and why we are using it.
The identity of the Branch is clear from our name and charity number, which is on our website and public information. The Branch, acting through our committee, is the Data Controller and responsible for your personal data. If you have questions about how the Branch handles your information, please contact us using our contact details listed on our website; www.rspcaguildfordepsom.org.uk.
This privacy notice supplements any other notices provided by the Branch and is not intended to override them.
As this website is hosted by the national RSPCA, charity number 219099, certain technical data will be processed by us and the national charity as joint data controllers. Please see the RSPCA’s Privacy Notice at www.rspca.org.uk/utilities/privacy.
1. Lawful processing
We need a lawful basis to collect and use your personal data. The law allows the following legitimate ways for our charity to process people’s personal data:
- Information is processed on the basis of a person’s consent
- Information is processed on the basis of a contractual relationship
- Information is processed on the basis of the ‘legitimate interests’ of the Branch.
2. Personal data that we process
The following explains the types of data we collect and the legal basis for processing it under current data protection legislation.
If you sign up as a branch member the national RSPCA will take your name, address and email address and payment information. The legal basis for this is fulfilling a contract - by paying your membership fees and being accepted as a member, you have entered into a contractual relationship with the RSPCA governed by our Rules. If you consent to applying for Branch membership, your details will be passed to the Branch and your application/membership are governed by our governing document (Branch rules).
If you enquire about our branch and our work, or wish to make a complaint, we will take your name, email, telephone contact number, or postal address and a message. The legal basis for this may be to fulfil a contract with you e.g. to be considered for adoption of an animal, or legitimate interest - it is necessary for us to read and store your message so that we can respond in the way you would expect. We may have a legitimate interest in sharing some of your personal data with the national Society, who support branches in governance and administration, including complaint handling.
To register you as a potential adopter or to place an animal into your home for adoption or fostering we will ask you for your name, address, email and telephone numbers along with information about your family, home and lifestyle. The legal basis for this is performance of a contract with you (the adoption/fostering agreement). As part of our adoption/fostering process we may carry out a home visit to help match you with the right animal. This home visit may be carried out by a volunteer of the Branch, or another charity within the RSPCA network, who will be acting for our Branch for these purposes. In processing your application, we may collect special category data, in particular about your health, and we will only process this information on the basis of your explicit consent and specifically for the purpose of ensuring a suitable match between you and the animal available for adoption/fostering (e.g. fur allergy).
If you report an animal as lost or found we will take your details and provide you with advice on what to do.
To process your request for financial help towards veterinary costs we will take your name, address, contact number and email and may ask to see proof of means tested benefits and identification. The legal basis for this is performance of a contract with you and so we can ensure you are eligible for our charitable services and that we deliver public benefit. We may share your information for use by a vet in treating your animal and invoicing the Branch.
If you ask us to rehome your animal we will take your name, address, email and contact numbers and any history relevant to the animal’s welfare and behaviours, including veterinary information. The legal basis for this is performance of a contract with you to acquire the full title and rehome the animal. We may seek your consent to contact your previous vet to obtain a veterinary history.
If we register or amend microchip details on an animal belonging to you we will ask you for your name, address, email and contact numbers in order to pass to the relevant microchip database company (principally Identibase, Anibase, Petlog). The legal basis for this is performance of a contract between you and the microchip company.
If we scan a microchip in a stray animal we will contact the microchip database company and follow their process to contact you to let you know we’ve found your pet. The legal basis for this is our legitimate interest as an animal welfare organisation in matching stray animals with owners. If, after taking all reasonable steps to trace an owner, we are unable to make contact, we will seek to rehome the animal and re-register the microchip accordingly.
To register your interest in volunteering or applying for a job with the branch we will collect your name, address, email and contact telephone numbers and ask you details regarding your application. Sometimes, criminal records and other checks may be required in line with our safeguarding and legal obligations. In processing your application, we may collect special category data, in particular about any disability, and we will only process this information on the basis of your explicit consent and specifically for the purpose of ensuring we meet our legal obligations e.g to make reasonable adjustments. We may also seek references from whom you will need to obtain consent to being contacted by the Branch. Next of kin details will also be requested if your application is successful, as part of our legal responsibility for your safety whilst with us. Occasionally we may need to contact a third party if concerned about your vital interests e.g. in a medical emergency. We may also have a legitimate interest in sharing some of your personal data with the national Society, who support branches in governance and administration, including recruitment of staff and volunteers.
We may use images of you on our social media sites such as in relation to fundraising events or successful adoptions. We would always ask for your explicit consent before capture and any use of these images and you can always request their removal at any time.
If you wish to receive updates by email or post about our work, including fundraising updates we will take your name, email or postal address and a contact number. The legal basis for this is consent - you will need to have given us your active consent to be contacted in this way and can rescind this at any time. Further information will be given at the point we collect your data.
If you make a donation to us we will request your name, email, address. In general we will not take your financial information but ask you to donate through your bank or via a third party processor e.g paypal or Justgiving who are data controllers in their own right. We may thank you for your donation on the basis of legitimate interest - this is necessary for us fulfill your intention of receiving your donation and your expectation of receiving an acknowledgement.
If you ask us to claim gift aid on your donation we will collect the information that is required by HMRC because of legal obligation of completion of a gift aid form. This applies to both monetary donations and donations made through our charity shops.
We may have installed CCTV systems in some of our premises for the purposes of our legitimate interest in crime prevention and detection. CCTV is also installed on the outside of some of our buildings for the purpose of monitoring security of our people and property. Images captured by CCTV will not be kept for longer than necessary however, on occasions, there may be a reason to keep images for longer e.g if a crime is being investigated. You have the right to access CCTV images of yourself. Signage advising of CCTV equipment will give notice of areas covered by CCTV.
2. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the information at the top of this policy.
For example, we may use your personal information to:
- Reply to enquiries you send to us.
- Handle donations or other transactions that you initiate.
- Where you have specifically agreed to this, send you communications by email relating to our work which we think may be of interest to you.
- Conduct research on demographics and animal welfare needs to enable a better understanding of requirements for our services and where we can improve in providing those services.
- If you are a Branch Member, we will send you an invitation to our General Meetings (AGM once a year) by post or email and possible information updates about us.
3. When we share your data
We will not exchange or sell your personal information to another organisation for their own marketing purposes. However, there are legitimate 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, or provision of a service with another organisation e.g. our cat neutering scheme operated jointly with Cats Protection. Otherwise we will only pass your data to third parties in the following circumstances:
- you have provided your explicit consent for us to pass data to a named third party;
- we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or
- we are required by law to share your data.
In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.
4. How long we keep your data
We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.
Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.
5. Rights you have over your data
You have a range of rights over your data, which include the following:
- Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this.
- You have the right to ask for rectification and/or deletion of your information.
- You have the right of access to your information.
- You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.
A full summary of your legal rights over your data can be found on the Information Commissioner’s website.
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.
Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.
6. Cookies & usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, e.g. remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
We may use data analytics to improve our website products/services, marketing, customer relationships and experiences. We may use technical and usage data in order to do this. The legal basis for this is legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Privacy Notice adopted by the branch committee on 11 March 2019