Privacy Policy

Please note: Our privacy policy is updated periodically, and it is advised that you check back for updates regularly. If you have subscribed to our mailing list, we will inform you of any changes to our privacy policy. Any changes will replace all previous versions and will be in force from the date of publication.  

Last updated: September 2023

1. Overview

1.1 National Trails UK (“We”) are committed to protecting and respecting your privacy, and we will look after any personal information that is made available to us in accordance with data protection law. We ask that you read this Privacy Notice carefully as it sets out the basis on which any personal data and sensitive personal data that we collect from you, or that you provide to us (“Your Data”), will be processed and used by us.
1.2 Under the General Data Protection Regulation 2018, a “data controller” is a person, company, or other body that determines the purpose and means of processing personal data. For the purpose of GDPR, the data controller is National Trails UK, c/o Unit 11, Residence 2 Royal William Yard, PL1 3RP, Registered Charity Number 1196805.
1.3 Please direct any enquiries via email to National Trails UK’s Data Protection Officer, Polly Martin, at polly@nationaltrails.uk


2. Why we process your data

2.1 All the personal data that we hold about you is information that you have provided to National Trails UK or information which is in the public domain.
2.2 We will only ever collect, store and use your personal data when we have a legally compliant purpose and reason to do so. The Information Commissioner’s Office (ICO) refers to this as a ‘lawful basis’.
2.3 In general terms, we process your personal data to improve your experience and engagement with National Trails UK. More specifically, we process personal data for the following purposes:
     2.3.1 Information and updates
          i. To send you information about our work that we feel will be of interest to you, including our newsletter, fundraising appeals, campaigning and research opportunities and the latest sector news.
     2.3.2 Improving your experience of our website.
          i. Our website uses cookies to help provide you with the best experience we can. Cookies are small text files that are placed on your device when you browse websites. See section 8 for further information.
     2.3.3 Membership administration
          i. To send you information about your membership;
          ii. To deliver the membership benefits you are entitled to;
          iii. Internal record-keeping and administration in order to process and manage your membership.
     2.3.4 Gift administration
          i. Thanking you for any gifts that help National Trails UK’s philanthropic objectives;
          ii. Internal record-keeping and administration, for example, to process your donation;
          iii. Undertaking any necessary research for our due diligence to meet money laundering regulations in alignment with our Ethical Fundraising Policy;
          iv. To validate any Gift Aid claims in order to claim Gift Aid from HMRC.
     2.3.5 Event Management
          i. To ensure that events are well organised and administrated, taking in to account any necessary adjustments, for example dietary and accessibility requirements, to ensure our event is inclusive, in line with the provisions of the Equality Act 2010.
          ii. To ensure that you are informed about the event you are attending, for example through email communications and phone calls;
          iii. To publish photographs and videos relating to our activities and events;
          iv. To inform you of other events you may be interested in, providing you have given your consent.
     2.3.6 Generating further philanthropic support for National Trails UK’s charitable purposes
          i. With your consent we will send you publications (for example impact reports, magazines, updates and invitations to events; email newsletters about National Trails UK and its projects, and fundraising campaigns) in a way which is tailored and relevant to you;
          ii. With your consent we will approach you to ask if you would like to support National Trails UK in other ways (for example, by making a donation, contributing to surveys, volunteering)
          iii. Reviewing publicly held information to give an indication of the financial giving capacity of individuals. This is known as wealth screening. Please be assured that we never use the data produced by wealth screening exercises as the sole basis for sending out communications. These exercises are a starting point for further research which we carry out about a person to identify if they may be interested in supporting National Trails UK. We consider any previous engagement with National Trails UK, your philanthropic interests and previous donations. This enables us to identify and contact only those individuals whose interests we believe align with our philanthropic objectives.
     2.3.7 Due Diligence and Gift Oversight
          i. To undertake our due diligence in ensuring that we do not solicit or accept gifts which may put National Trails UK or its staff under any financial, reputational, legal or security risk, or which may conflict with National Trails UK’s institutional and ethical values. This is in line with National Trails UK’s Ethical Fundraising Policy.
     2.3.8 Research (including market research) and analysis
          i. To compile anonymised reports to assess National Trails UK’s progress against targets;
          ii. To track trends and strategically analyse information in order to inform our strategy and communication

3. The information we collect

3.1 Website visitors and newsletter subscribers.
     3.1.1 If you enable the use of cookies on our website, we will collect a unique user ID, your browsing history, the links you’ve clicked and how long you’ve spent on each page, your geo-location and IP address.
     3.1.2 If you subscribe to our newsletter using the online form on our website, we will collect and store your name, email address and any other information you provide to us using the form. We will collect information about how you interact with our newsletter, including links you’ve clicked on.
3.2 Donors and members. When you make a donation to National Trails UK, or become a member of National Trails UK, we collect and process a range of information about you. The data we process is that which you provide, for example, via your gift form or gift agreement, membership form, or an online donation platform. Examples of categories of personal data which we may hold are:
     3.2.1 Contact details – for example, your name, postal/ email address and telephone number.
     3.2.2 Financial details that you have provided to us - for example, card and bank details;
     3.2.3 Biographical details – for example, your date of birth;
     3.2.4 Education details – for example, institutions attended, the courses you completed and dates of study;
     3.2.5 Professional details – for example, employer, occupation and work address;
     3.2.6 Philanthropic details – for example, your history of donations, of both time (for example, volunteering) and money, your areas of philanthropic interest and your publicly known philanthropy.
3.3 Prospective donors. We will collect publicly available information in relation to prospective donors for the purposes described in 2.3.6. This includes:
     3.3.1 Individuals who have donated to National Trails UK in the past;
     3.3.2 Individuals who have indicated that they may make a gift in future;
     3.3.3 Individuals who have been identified as prospective donors to National Trails UK.
     3.3.4 Individuals who have a strong connection to an organisation which has supported National Trails UK, or which has the potential to support National Trails UK.
3.4 Event attendees. If you accept an invitation to, and/or attend, a public event hosted by or on behalf of National Trails UK, we will process and store the following information:
     3.4.1 Any preferences provided by you for a specific purpose such as access requirements or other adjustments and dietary preferences;
     3.4.2 Photographs taken at events (unless you request not to be photographed);
     3.4.3 A record of your attendance and correspondence in relation to the event;
     3.4.4 If you have given consent, we will let you know about future events you may be interested in.
3.5 Individuals on behalf of organisations. If we are in communications with you regarding an organisational partnership or membership with National Trails UK, we will collect the following details for administration purposes:
     3.5.1 Your work email address and phone number, if provided by you or otherwise publicly available (so we have contact details within your organisation)
     3.5.2 Communications history (so we have a record of conversations, emails, meetings and telephone calls relating to the partnership).
     3.5.3 We will not solicit you for a personal gift unless you have given us your consent to do so.
3.6 Special Categories of Data. We may process information which reveals special categories of data such as your racial or ethnic origin, political opinions and data concerning your health.
     3.6.1 We will only process special categories of data, or information revealing special categories of data, if it has been provided to us by you or is available from trusted sources within the public domain.
     3.6.2 Most special categories of data will not be processed deliberately or explicitly, and will only be inferred through other data that is collected. This is particularly the case for data we collect for fundraising purposes.
     3.6.3 We will collect special categories of data for research purposes, particularly research that aims to evaluate and improve Equity, Diversity and Inclusion on the National Trails. We will carry out a Data Protection Impact Assessment when undertaking research that involves the collection of special category data.


4. Legal grounds for processing

4.1. We consider the processing of your personal data for the purposes outlined in section 2 to be necessary:
     4.1.1. For the pursuit of National Trails UK’s legitimate interests in growing our donor and membership base, in support of our charitable mission;
     4.1.2. Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, to provide you with subscriptions you have ordered or membership benefits to which you are entitled;
     4.1.3. To enable National Trails UK to comply with its legal obligations, for example for compliance with anti-money laundering rules and Gift Aid requirements;
     4.1.4. When collecting special category data, particularly when conducting research, we will identify a lawful basis for professing under Article 6 of the UK GDPR as well as a separate condition for processing under Article 9;
     4.1.5. For the performance of tasks carried out in the public interest or in the exercise of our official authority.
4.2. In adherence to the Privacy and Electronic Communications Regulations (PECR) we will not send you any direct marketing communications by electronic means without your explicit consent.


5. Storing your personal data

5.1 National Trails UK will store the personal data we have collected about you under the above terms. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice and our Data Protection Policy. Data that you have provided will be stored:
     5.1.1 On our secure SharePoint environment. This runs on Microsoft Azure Cloud, which is UK hosted (UK West and UK South);
     5.1.2 On our secure Database, Beacon CRM. You can view Beacon CRM’s security information here: https://www.beaconcrm.org/trust
     5.1.3 Any hard-copies of personal information, such as the information provided on paper donation forms, Gift Aid forms and membership forms, will be kept XXX
     5.1.4 On trusted third party servers as outlined in Section 7 below.
5.2 We aim to keep your data up to date and welcome any updates to your details or corrections to any inaccuracies you may wish to provide.
5.3 We will remove your data from our databases upon request unless we have a legal requirement to continue storing it.
5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


6. How long your data is kept

6.1 The length of the data retention period varies according to the nature of the information that is being held. You can request a copy of National Trails UK’s Record Retention Schedule for more information.


7. Disclosure of your information to third parties

7.1 Authorised personnel within National Trails UK will be able to access the information you provide to us on a need-to-know basis. We may also disclose your data to other third parties who act for us for the purposes set out below or for purposes approved by you, but always with appropriate non-disclosure and data protection agreements in place. We will never sell your data. Third parties include:
     7.1.1 Email Platform. In future, we may use a third-party provider to deliver our e-newsletter. If this is the case, when you sign up to our e-newsletter then your data will be stored on the email provider’s servers.
     7.1.2 Contracted Agencies. We may employ other companies and individuals to perform functions on our behalf. Examples include:
          i. Financial software for processing online payments;
          ii. Printing houses for publication printing and mailing;
          iii. Digital agencies for hosting the website;
          iv. Prospect research agencies. We may sometimes use trusted third parties, such as Factary, to review publicly held information to give an indication of the financial giving capacity of individuals. The contracted agencies have access to personal information needed to perform their functions, but may not use it for other purposes, and must delete it as soon as the function is complete.
          v. Research agencies. We may sometimes use trusted third parties to conduct research in to the National Trails.
     7.1.3 Fraud Prevention. Personal information provided by you may occasionally be shared with other organisations for the prevention of fraud. Third parties may include solicitors, agents appointed by us (for example, debt recovery and tracing agents) and the Courts.
     7.1.4 Approved Volunteers. Upon the signing of a non-disclosure agreement, approved volunteers may be given access to your Data. This access will be for a specific purpose, and for a time-limited period only, and will be monitored at all times by authorised National Trails UK staff. Sensitive personal data will not, under any circumstances, be shared with volunteers.
     7.1.5 We will not otherwise share, sell or distribute any of the information you provide to us without your consent, unless required or permitted to do so by law.


8. Use of cookies

8.1 Like all websites, our website uses cookies to help provide you with the best experience we can. Cookies are small text files that are placed      on your device when you browse websites. Our cookies help us:
     i. Make our website function as you'd expect, including making improvements
     ii. Remember the settings you have selected during and between visits
     iii. Improve the speed and security of the site
     iv. Allow you to share our website pages on your own social networking platforms
8.2 We do NOT use cookies to:
     i. Collect any personally identifiable information (without your express permission)
     ii. Collect any sensitive information (without your express permission)
     iii. Pass personally identifiable data to third parties
     iv. Pay sales commissions
8.3 Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
8.4 To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
8.5 You can learn more about all the cookies we use below:
     8.5.1 Cookie provider: National Trails UK.
               Purpose:
               Cookies:


9. Your rights

9.1 As a data subject, you have a number of lawful rights. You can:
     9.1.1 Access and obtain a copy of your data on request;
     9.1.2 Require the organisation to change incorrect or incomplete data;
     9.1.3 require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
     9.1.4 Object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.
9.2 If you would like to exercise any of these rights, please contact our Data Protection Officer via email at polly@nationaltrails.uk
9.3 If you believe that the organisation has not complied with your data protection rights, you can make a complaint to us by emailing our Data Protection Officer at EMAIL or writing to us at National Trails UK, c/o Unit 11, Residence 2 Royal William Yard, PL1 3RP. You can also complain directly to the Information Commissioner’s Office if you are unhappy with how we have used your data. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,  SK9 5AF. You can visit the ICO website at https://www.ico.org.uk.


10. Updating this Privacy Notice

10.1 We keep our Privacy Notices under regular review. Any changes will be published so that it is clear what information we collect and how we use it at all times and, where appropriate, we may notify you by email.