Privacy & Cookies
Westcott House is committed to protecting and respecting the privacy of individuals who visit our website. Your support matters greatly to us and we want to let you know how much this means but only in ways that you are comfortable with.
We will only contact you in a way that works for you and make it easy for you to tell us how you would like to receive information from us, so you feel comfortable with how your personal data is gathered and used. We follow all applicable fundraising and data protection legislation and guidelines.
The policy outlined below is intended to describe how your personal information is processed and used.
1. What does this policy cover?
As a minimum we ensure that we use your data in accordance with all applicable laws concerning the protection of personal data. This policy explains:
- What data we may collect about you
- How we will use that data
- Whether we disclose your details to anyone else
- How we manage your personal data – security, storage and retention
- Your choices regarding the data you provide to us
2. Questions about your personal information
Any questions that you may have in relation to this policy or how we use your personal information should be addressed to:
The Data Protection Manager
Jesus Lane Cambridge
3. About Westcott House
Westcott House, registered as a Charity in England and Wales, with the charity number 311445. Our data protection controller number is Z5307751.
Westcott House is based at: Jesus Lane, Cambridge CB5 8BP.
4. How do we use your information?
As a supporter of Westcott House we collect personal information about you and store your record in our supporter database. We use this data for a number of purposes including administration, event management, alumni and supporter relations, promotional, marketing and fundraising communications in the following ways:
When you give us information
When you engage with us as a supporter we may ask for personal information when you:
- Subscribe to receive our newsletter or join our mailing list
- Register or attend an event
- Purchase merchandise
- Book accommodation
- Make a conference or meeting room booking
- Request Legacy information
- Notify us of the death of an alumnus, relative or supporter
- Engage with our social media or communication services
- Provide us with personal information in any other way that is relevant to your relationship with Westcott House.
This information may include:
- Your title, name, postal address, email address and telephone number.
- Financial data (such as bank account details provided by you, and whether donations are gift-aided. Please see Section 11).
- A record of the financial donations that you have made and data about your tax status for Gift Aid purposes.
- Details of your indicated interests, preferences and the ways you support or have supported us – e.g., in relation to any campaigns, events or fundraising schemes you have participated in. When you receive a communication we may collect data about how you respond to or interact with that communication, and this may affect how we communicate with you in future.
When you provide your personal information to Westcott House, please make sure that it is accurate and up to date. This will allow us to contact you effectively in order to deal with your donations, bookings, questions or provide you with data about our work. It is important that the personal information we hold about you is kept current. Please keep us informed if your personal information changes during your relationship with us. If you would like to change the personal details that we hold about you, please get in touch by contacting us at the address provided in Section 10.
When you use our website
When you use our website we collect data about the services and features you use and how you use them.
When you provide your personal details when filling out a contact form to join our mailing list or update your details, subscribing to our newsletter, making a donation or booking, communicating with us or signing up for or receiving a service on our website, we will collect this data and store it in your record so as to fulfil your request, answer your enquiries and keep a record of our correspondence with you.
When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies that collect small amounts of data.
We use the following cookies:
- Necessary cookies: these are cookies that are required for the operation of our website and enable you to use its features.
- Analytical/performance cookies: they allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. We find it helpful to examine visitor traffic so that we can ensure maximum compatibility for the various browsers and operating systems that visit our site, and improve functionality. By analysing visiting patterns, referring URLs and search engine terms, we can also strategically enhance our exposure across the Internet. This data does not contain any personal or identifiable information.
- Functionality cookies: these are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences.
Third party cookies
This website contains links to and from third-party sites. We use a number of suppliers who may also set cookies on their websites’ on its behalf. The Westcott House website does not control the dissemination of these cookies. You should check the third-party websites for more information about these.
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These are all standard uses of cookies, and we do not feel that they record any more information than they need to. However, if you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how.
Alternatively, learn how to remove cookies set on your device by visiting AboutCookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.
When you use social media
When you view information published by Westcott House using social media hosted across various platforms, we will collect and receive information that provides aggregate data relating to items such as video views, demographics and location data. Sources of this data may include:
Identifiable personal information about people who access these platforms is collected in order to allow Westcott House to reach and market new audiences.
5. Data from third parties
We may sometimes collect additional data about you from other organisations or companies that provide data from publicly available sources, to understand how we can communicate in a meaningful way and so we can make it easier for you to support Westcott House by providing you with details about the types of activities and services we can offer. We ensure that such data is only collected from legitimate sources on a lawful, fair and transparent basis in accordance with applicable data protection law.
The data about you that we may collect from third parties can include:
- Your name, postal address, phone number, email address, for example from Crockford’s Clerical Directory, or from Charities Aid Foundation (CAF) or Cambridge in America (CIA) for donations that have been received on our behalf.
- Data to categorise and create supporter categories. This does not include information that identifies people specifically, only creating profiles of general factors that we use to categorise sections of our records.
6. Information we share with other organisations
We may disclose information to third parties or individuals, when we are obliged to by law or a regulatory order, or in the good-faith belief that such actions are necessary, or when one or more of the following apply:
- If you have specifically agreed that we may share your personal information to those third parties or individuals for a particular purpose.
- When we use other companies (known as ‘data processors’) to provide services on our behalf who are only processing personal information in accordance with our instructions. For example, companies that provide: direct mailing or marketing services that send material to you by post, email or text message, customer analysis, assessment, profiling and when using auditors or advisors. Also, we may use third party organisations (again processing data under our instructions) to carry out fundraising on our behalf. For example, we may use a company to call supporters who have agreed to be contacted by phone about a campaign, appeal or donations.
- Processing credit/debit card payments. Westcott House does not handle or store credit/debit card data itself, but uses secure debit and credit card processing services that are provided by Barclaycard, First Data Merchant Services and PayPal in accordance with Payment Card Industry (PCI) standards. Debit and credit card data will be collected directly by these card processing service providers when you make a donation to Westcott House or when booking an event, conference or accommodation.
- We may disclose aggregate statistics about our supporters to describe our services and operations to prospective partners, advertisers, other reputable third parties and for other lawful purposes – these statistics do not include any information that identifies people.
- When we hold events or similar activity in partnership with other identified organisations, we may pass your personal information to these organisations.
7. Information created by us
We complete internal research and analysis of your personal data, which can result in new personal data being created and added to your record.
To identify patterns, trends and areas for future development, we complete research by analysing the success of our events and campaigns. This information allow us to gain a better understanding of our supporters, improve our relationship with you and provide you with a better supporter experience. By doing this, we ensure supporters are only provided with the communications, products, services and data which are important to them, and that our charity resources are used in a cost-effective way.
To achieve this, we analyse and research supporter data to group people together in terms of common characteristics in order to offer you more relevant and tailored information, advertising, services and communications.
We keep track of the amount, frequency and value of each person’s support. If, based on data that has been provided to us (such as geographical location, demographics, or previous donations), it appears you may be willing and able to provide more to support Westcott House’s mission, then we may contact you to see if you wish to do so.
We may also carry out supporter research that includes collecting data from public sources about a limited number of supporters who we think can influence policymakers to promote the interests of Westcott House. We may also research supporters who we believe can become significant financial supporters of Westcott House’s mission, including well-known or influential people. We make sure that the sources we use are reputable public databases such as Companies House, mainstream news outlets or other reliable media sources.
We will make sure that we do not use data about individuals that is clearly intended to be private or collect information in a privacy intrusive manner that would not reasonably be expected by you. We will also inform you of this use as soon as is reasonably possible.
The Trustees of Westcott House have a duty to ensure that there is no reputational or financial risk to accepting a donation or other kind of support. We may therefore carry out due diligence on you by using publicly available sources to ensure that we are fundraising within the law. For more information on the circumstances this may apply in and the type of information required please visit the Charity Commission.
8. Special category or sensitive data
We may collect or store what’s known as ‘special category’ or ‘sensitive’ personal information about supporters in accordance with GDPR Article 9(2)(d) which permits us to process special category data if:
‘Processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects’. (ico.org.uk).
For further information, please refer to our Data Protection and GDPR Policy located under the Polices & Safeguarding section of our website.
9. Legal basis
Westcott House relies on the following legal conditions that are described in the EU General Data Protection Regulation to use your personal information in the ways described in this privacy notice:
- Consent: when you consent or opt-in to receive information and marketing sent by post, telephone, or electronic means. We use this consent to offer you promotional, marketing or fundraising information using post, telephone or electronic means (including email and social media). We also have a consent renewal programme that we undertake every 60 months to ensure as our supporters, that you are still content to receive communications from us.
- Legal obligations: where we are under a legal obligation to process your personal data for a particular purpose. For example, obligations we have to hold information about donations or manage Gift Aid information in compliance with applicable tax laws. We may also sometimes need to process personal information for the purpose of us being able to establish or exercise our legal rights or to defend legal claims.
- Legitimate interest: where we have a legitimate interest. This is the legal basis that we rely on to send information and marketing by post or telephone when you take part in supporting Westcott House’s mission by making a donation, or requesting information about our work, marketing, campaigns and events or other services.
Telephone marketing will not include people who have indicated to us that they do not want to receive marketing calls made this way. The only time we will contact you by telephone is if you have given your consent directly to Westcott House to receive marketing calls.
We will also have a legitimate interest in being able to use and process personal information for internal administrative purposes, and when it is necessary to take measures to protect our IT network and data security or to protect ourselves (and our beneficiaries and supporters) from risks to our charity such as fraud, criminal conduct or reputational damage.
When processing your personal information based on a legitimate interest, we will make sure that it is exercised proportionately and is always balanced against the privacy rights and other legal rights you have as an individual.
- Contract: where we agree to provide any products and/or services to you, we will use your personal information in order to arrange for the provision of those products and/or services as well as performing obligations to you or enforcing our rights under any contract we have with you.
- If we are processing any personal information that is regarded as ‘special category’ or ‘sensitive’ as referred to above, we will only do this with your explicit consent; or, where needed to protect your vital interests (or those of someone else) in an emergency; or, where you have already publicised such information; or, where we have a need to use such data in connection with a legal claim relevant to us. Please see our Data Protection and GDPR Policy for further information.
Marketing, campaigning and fundraising
We send direct promotional, marketing or fundraising communications to our supporters. These types of communications can include:
- News, announcements or updates on Westcott House
- E-newsletters and other emails
- Information and invitations to our events, activities and campaigns
- Appeals and fundraising (including requests for donations)
- Information on ways to support us
- Information on leaving a legacy
- Surveys for information updates, communication and fundraising preferences
- Analysis and research to improve our relationship with our alumni and supporters and to target our communications more effectively
- Other relevant communications based upon your relationship with us
Westcott House relies on donations and support from others to continue its core mission of serving the Church of England by preparing individuals for lay or ordained ministry. Being able to contact you for marketing and campaigning purposes is an important part of our fundraising activity and purpose.
Fundraising is an important part of our marketing, but we will not share your data with any other organisation, individual or company to allow them to use your personal information for marketing or campaigning purposes, unless we have obtained your specific, freely given, informed and unambiguous consent to do so.
We may aggregate and anonymise personal information so that it can no longer be linked to any particular person. This anonymised data can be used for a variety of purposes (such as recruiting new supporters) or to identify trends or patterns within our existing supporter base. This data helps inform our actions and improve our campaigns, products, services and materials.
10. You are in control
You can change your personal information and preferences about how we contact you whenever you choose.
How to change or stop us contacting you by post, telephone or email
Your contact preferences can be changed at any time by contacting our Data Protection Manager:
Phone: 01223 741000.
How to unsubscribe from our email newsletters
If you have previously opted-in to receive email communications from Westcott House but wish to be removed from our list and no longer receive email communications, you may unsubscribe at any time by clicking the ‘unsubscribe’ link which should appear at the bottom of any of our emails.
Alternatively, please contact us on email@example.com with a request to unsubscribe.
11. How we protect your personal data
Westcott House considers keeping your information safe to be vitally important. We use all reasonable precautions to keep the information disclosed to us secure and have robust measures in place, employing a variety of physical, organisational and technical measures to ensure we do this, and prevent unauthorised access to – or use or disclosure of –your personal information.
Electronic data and databases that contain supporter personal data are stored on secure computer systems and we manage who has access to that data (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures and policies which staff must follow when handling personal information.
All hard-copy records and data are managed securely in lockable and access-restricted storage.
All electronic forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.
If you use a credit card to donate online your debit/credit card details are transferred securely to our payment card providers Barclaycard, First Data Merchant Services and PayPal who comply with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council. We do not store any payment card information.
We cannot guarantee the security of your home computer or any information sent over the internet or any publicly accessible communications network and using any online communications services are at the user’s own risk.
Where we store personal information:
Westcott House is based in the UK. Wherever possible we store our data in the UK or within the European Economic Union (EEA). Some organisations and companies that provide services to us transfer personal data to territories outside of the EEA such as the United States which does not have such EEA approval in relation to its data protection standards. In these cases, we will only permit such a transfer when there is recognised assurance, such as the service provider being a member of the EU-US Privacy Shield Framework (e.g., Facebook, Twitter, Mailchimp) to ensure that your data is adequately protected in accordance with EU privacy standards.
How long we store data
We will only use and store personal information for as long as it is required for the purposes it was collected for.
We have adopted a data retention policy (available on request) that sets out the different periods we retain personal information for in respect of these relevant purposes in accordance with our duties under applicable data protection law. The criteria we use for determining these retention periods is based on various legislative requirements; the purpose for which we hold data; and guidance issued by relevant regulatory authorities including but not limited to the Information Commissioner’s Office (ICO). Personal information that we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it. Some personal information may be retained by us in archives for historical research purposes, although we will do this in a manner that complies with applicable data protection law.
We continually review what personal information and records we hold and delete what is no longer required. We never store payment card data.
13. Your rights
We want to make sure that you are able to make your own choices about how we use your personal information. Part of this is making sure you understand your data protection rights, which are set out as follows:
- Right to be informed on how Personal Data is processed
- Right of access to your Personal Data. You can ask us if we are keeping any personal data about you and can request to receive a copy of that personal data. This is also commonly known as a Subject Access Request (SAR). Timescales for responses are usually a month for simple requests and timescales can be extended for complex requests.
- Right to erasure to have your personal information that we no longer need deleted from our records
- Right to rectification to update or have inaccurate personal information amended
- Right to restrict processing of your personal information in certain situations
- Right to object to personal information being used for marketing or profiling
- Right to data portability (in certain circumstances) to have a copy of your personal information provided for reuse in another service.
If you would like a printed copy of this policy, further details about your rights or would like to exercise them please write to our Data Protection Manager at firstname.lastname@example.org or addressed to:
The Data Protection Manager
We reserve the right to ask for further information to verify your identity (or clarify the information that you are seeking) when we receive such a request.
If you are dissatisfied with the response from Westcott House, you can contact the UK Information Commissioner’s Office (ICO) as follows:
Information Commissioner’s Office
Phone: 0303 123 1113 (local rate) or 01625 545 745
Fax: 01625 524 510
14. Job Applicants
Westcott House is an equal opportunities employer and abides by the privacy rules as set out in the Data Protection Act 1998 and subsequent General Data Protection Regulation. Please see our policies section to view a copy of the College’s Privacy Statement for Job Applicants and how Westcott House handles personal information.
15. Employees, Workers and Contractors
A copy of the Privacy Statement for Employees, Workers and Contractors is available upon request by contacting us on the details located under section 13.
A copy of the Privacy Statement for Students is available upon request. Please refer to section 13 for our contact details.
17. Further Information