Privacy Statement for CLP Website
The Conservation Leadership Programme (CLP) recognises that a crucial element of the trust we hope to earn from our alumni, members of the public, prospective award applicants, or any other individuals who engage with us, comes from being open, honest and lawful in the way that we process personal data. CLP respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
About the CLP
CLP is a partnership between three conservation organisations, BirdLife International, Fauna & Flora International and the Wildlife Conservation Society. Each of these organisations is a joint data controller under the terms of the General Data Protection Regulation and the UK’s Data Protection Act 2018.
BirdLife International is a company limited by guarantee, registered in England with its registered office at the David Attenborough Building, Pembroke Street, Cambridge CB2 3QZ. BirdLife is registered with the Information Commissioner’s Office under registration number ZA445038.
Fauna & Flora International (FFI) is also a company limited by guarantee, registered in England with its registered office at the David Attenborough Building, Pembroke Street, Cambridge CB2 3QZ, UK. It is also registered with the Information Commissioner’s Office (ICO) (Registration No. Z5599356).
The Wildlife Conservation Society (WCS) is an organisation created by New York State charter, with its main offices at 2300 Southern Boulevard Bronx, New York 10460, USA.
AS A VISITOR TO CLP’s WEBSITE
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Through Google Analytics, we can also see an overview of how many people are visiting the CLP website and from what countries. We do not collect any personal information using Google Analytics. You can opt out of Google Analytics tracking by following the guidance provided by Google here.
This website will also allow you to share pages with social networks such as Facebook, which you do at your own discretion. Although we will never share any personal information with third parties beyond what is strictly necessary in order to perform the service you have requested, we recommend that you familiarise yourself with the terms and conditions of any social media channels through which you choose to share a story (or engage in some other way with BirdLife, FFI and WCS) to ensure that you are happy with how they might combine the data they already hold on you with any interactions you have with us.
Basis for using your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
More information about this is below.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
AS A FUNDING APPLICANT TO CLP
The data we hold
As part of the funding application, applicants must share their name, age, postal address, email with us as well as other background information on education and employment as relevant to your application. As part of your funding application, this information will be temporarily stored and may be shared with external reviewers in the event that your application is eligible for funding. External reviewers will be instructed not to share application data with third parties. By applying to CLP, you acknowledge the transfer of your data to these parties, which are in several different countries. We store unsuccessful applications on our secure server for a period of seven years for reviewing and auditing proposes; successful applications that receive funding are stored in perpetuity, with personal data stored on a secure database.
AS A REVIEWER OF CLP APPLICATIONS
The data we hold
If you complete a review for a CLP application, we will share in confidence your review, including but not limited to your name and organisation, with the CLP’s Award Selection Committee. With your permission, we will retain your contact details in order for us to contact you if we need an expert review of an application relevant to your knowledge or expertise in the future. We store this information on our secure server, and this information is only accessible to CLP partner staff working. If you wish to withdraw your consent for us to hold your contact details for this purpose, please e-mail us at email@example.com at any time.
AS AN ALUMNUS OF CLP
The data we hold
If your CLP application is successful and you choose to share your name and postal address with us, then we will store this information on our database, where it will be held securely in the UK.
Access to the database is limited to only those members of CLP staff who need to use it for the legitimate reasons of supporting CLP alumni and keeping in touch related to CLP activities. These may include surveys and other items we believe will be interesting to you.
You can request to stop receiving our communications at any time by contacting firstname.lastname@example.org.
If you have provided CLP with an email address to keep you informed of CLP news then we will send you our enewsletter, which is currently published three times a year. We may also contact you about our call for funding applications. These emails will always be accompanied by a link allowing you to unsubscribe at any time. Your email address will be stored on our secure database in the UK, and the emails will be sent using a third-party application called MailChimp which processes and stores your email address securely in the US. MailChimp will also provide us with details about which emails you have opened and when, and what links within an email you may have opened. CLP will only use this information to ensure that what we send is relevant, timely and interesting to you. Mailchimp adheres to the Privacy Shield Principles and is EU-U.S. and Swiss-U.S. Privacy Shield certified through November 2020, and listed on the US Department of Commerce Privacy Shield website as The Rocket Science Group LLC d/b/a Mailchimp.
We maintain a history of interactions between CLP and our alumni on our secure database in the UK. These include notes about inbound and outbound communications (i.e. to tell us that we have sent you something, or to tell us that you have written, telephoned or emailed us for any reason).
DATA RETENTION, UPDATING AND SHARING
Keeping data up to date
We will do our best to ensure that all data we hold is kept as up to date as possible. If your information changes or you think the information we have is incorrect, please let us know so that we can make the necessary amendments to our records.
We will only keep your data for as long as is necessary. We will delete your information as soon as there is no longer any legitimate reason to retain it.
If you have provided us with your credit or debit card details for the purposes of making a donation, then we will use those details only for the purposes of processing that donation, which we do through a secure service provided by WorldPay. We do not store card details, electronically or otherwise.
Where a donation has been sent to us in the post, we will store a paper copy of the donation only for the purposes of maintaining an audit trail. Card details on these forms are destroyed before they are stored.
Except as explained in this Privacy Statement, CLP will never share your personal details with any third party, charity or commercial organisation. We will also never sell your personal details for commercial or other purposes. We do not rent or share lists with other organisations, and we will never do so.
WCS will have access to your data, as will our third party service providers such as Mail Dog and Worldpay (mentioned above). This may involve transferring your data outside the European Economic Area (EEA). We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
How we update this Privacy Statement
We may amend this Privacy Statement from time to time in order to reflect changes in the law, best practice or our internal procedures. You can see the last date at which any amendment or addition was made to this Privacy Statement by going to the bottom of this page. Please therefore review this Privacy Statement regularly to ensure you are aware of any changes to it.
We are committed to protecting your personal information. If, however, you have a concern about how we have handled your data or about the contents of this Privacy Statement, please contact us. We will respond to any complaints we receive. Our contact details are as follows:
Tom Beesley (Data Protection Lead)
If you are not satisfied with our response you can contact the Information Commissioner’s Office with your concerns: https://ico.org.uk/concerns/
Residents of the USA and Australia should also refer to the additional provisions set out below
United States of America
We confirm that we take all reasonable steps to comply with US laws and regulations in relation to online privacy.
CALIFORNIA – ONLINE PRIVACY PROTECTION ACT 2003
This Act relates to personally identifiable information (PII) collected in relation to residents of California. Details of how we comply with this Act are set out in our above Privacy Statement which sets out the categories of PII we collect and how to request details of the PII we hold. In addition, we confirm that we do not share your PII with any third parties for direct marketing purposes. In relation to “Do Not Track” requests, please see our section on Cookies and Google Analytics above.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT 1998 (COPPA)
CLP’s website is not directed at children under the age of 13 and, as such, CLP does not knowingly collect personal information from anyone under that age. If CLP is made aware that personal information has been obtained from a child (without parental consent) we will take steps to delete that information as quickly as possible. Please contact us if you believe that we may have collected personal information from a child.
In addition to the above information, we also confirm that we take all reasonable steps to comply with the Australian Privacy Principles (APP’s) as set out in the Privacy Act 1988.
We confirm that we process data anonymously except where it is impracticable to do so (for example, in order to maintain a mailing list). Any unsolicited personal information we receive which we cannot legally hold under the Act will be destroyed. As stated above, all the data we collect is primarily stored securely in the UK and is processed and stored in accordance with the Australian Privacy Principles. We ensure that any third parties we use to process or store information outside of Australia also comply with these principles.
If you have a complaint then please contact us at email@example.com. If you are not satisfied with our response to a complaint you can contact the Office of the Australian Information Commissioner.
Last updated: 27th June 2019