Updated 12th April 2021 and written in accordance with GDPR Regulations.

WAVE Trust’s registered charity numbers are 1080189 in England and Wales and SC044168 in Scotland. WAVE Trust is a company limited by guarantee and registered at Companies House in England & Wales under number 3863110.

WAVE Trust (WAVE) may collect personal information about trustees, staff, charity partners, funders, donors, volunteers, fellows, supporters, suppliers and other relevant contacts.

WAVE will collect information where, in the charity’s reasonable opinion, it is essential for (i) the smooth and efficient running of the organisation; (ii) the attainment of the charity’s objects, aims and strategies; (iii) the performance of employment contracts, HR and legal issues; (iv) the performance of contracts with third parties or partners; (v) the performance of obligations/requirements of trust funders and private funders

Personal data is any information that can be used to identify you or another living individual. So for example, if you donate money, use our services or visit our offices, request our products, or become involved in our campaigns or volunteering work, we will collect and process the personal data that you’ve provided.

We may also collect personal data from you when you report a problem with our website, if you complete a survey which we use for research or evaluation purposes or when you give us feedback or contact us.

We also collect more technical data which may identify your device or web browser, relating to details of your visits to our website, for example location data, how you found us and the resources accessed on our website. We use this to provide you with the information, services or products that you’re interested in and are most relevant to you.

This data is collected by cookies, which are small files stored on your computers’ or mobile devices’ web browser. Our site uses these cookies to keep you logged in as you move around the site, to provide some of our content, and to monitor the websites’ performance. This helps us make the website better for you and for others.

To understand how we use information about the communications devices you use, such as IP address (the location of the computer on the internet) and cookies, please see our cookies policy page. This page also provides information on how you can prevent or control the cookies that are stored on your computer or device web browser via our cookies management tool, as well as remove them completely.

 

We may collect the following personal data:

  • Basic personal details (your name, email address, postal address, telephone or mobile number and date of birth)
  • Financial details (bank account number, UK tax payer information for gift aid)
  • Credit or debit card information
  • IP address
  • Photos, videos or audio recordings used as part of our work with you

WAVE may request that Employees complete and hand to the Company Secretary a ‘Next of Kin’ form and any information on that form will be confidential and kept off site. This may include name, address, date of birth and emergency contact details.  WAVE will seek explicit consent to collect and use the Employee’s email, address or mobile phone number for any purpose not connected with the Employee’s contract, employment & HR issues.

 

Our lawful bases for using your personal data

Data Protection law requires us to have a reason or justification, also known as a ‘lawful basis’, for using any of your personal data:

  • Consent: This is where we've asked for your permission to use your personal data in a specific way, and you've agreed. For example to send you marketing via email or SMS.
  • Legal obligation: We may collect or share your personal data where we are required to do so by law. For example to fulfil a regulatory requirement or for fraud detection.

Some activities are undertaken in the public interest. For example, collecting personal data in relation to safeguarding concerns.

 

Legitimate interests

Our legitimate interest is in engaging with the public to further our charitable aims.

Whenever we use this justification we will always conduct a balancing exercise to ensure that we consider the impact on you as an individual to ensure that our interests are not overridden by the impact on you.

WAVE will seek explicit consent to collect and use any sensitive information concerning any Employee which is not connected with employment & HR issues and will explain how it will use it.

WAVE reserves the right to record and monitor telephone calls for quality control purposes.

WAVE may share contact information with other organisations who are supportive of its aims and objectives and where it is appropriate to do so. WAVE will only keep information for as long as it needs to do so for legal purposes.

WAVE will not disclose any personal information to anyone else except under special circumstances, such as when it believes that the law requires it or when the person concerned has given express or implied consent for the information to be shared.

WAVE TRUST is committed to keeping personal information safe and secure from loss, theft, damage or alteration. WAVE has put security policies and technical measures in place to protect personal information.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while WAVE strives to protect personal information, WAVE Trust cannot ensure or warrant the security of any information which is transmitted to WAVE, and senders do so at their own risk.

 

Your rights

If you'd like to access any of your rights, please contact us using the information below.

  1. Right to access your personal data: You have the right to access the personal data that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal data to you (or someone else on your behalf), we will provide it to you or them and aim to do so within 30 days from when your identity has been confirmed. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be excessive in nature. We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal data.
  2. Right to correct your personal data: If any of the personal data we hold about you is inaccurate or out of date, you may ask us to correct it. If you would like to exercise your right, please contact us as set out below.
  3. Right to stop or limit our processing of your personal data: You have the right to object to us processing your personal data for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances. If you would like to exercise this right, please contact us as set out below.
  4. Right to stop or limit our processing of your personal data: You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. If you would like to exercise this right, please contact us as set out below.
  5. Right to portability: The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used and machine readable format. It also gives them you the right to request that a controller transmits this data directly to another controller. If you would like to exercise this right, please contact us as set out below.

WAVE will review this policy from time to time and aim to comply with the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and amendments thereto.

 

Keeping your information up-to-date

To make sure we always have the most up-to-date information about how to contact you, we may also, from time to time, update our records to reflect any changes to your personal data.

This information may come directly from you, or it may come from a third party that we consider is legitimate and trustworthy and in circumstances where it is appropriate and where you will have had a clear expectation that your details would be passed on for this purpose.

If you're concerned about the way your personal data is handled, or would like us to change the way we contact you please contact the Data Protection team at [email protected]

The Information Commissioner's Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here: https://ico.org.uk/for-the-public.

You have the right to contact the Information Commissioner’s Office on 0303 123 1113, via their website www.ico.org.uk or via post:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF