The Battle of Britain Memorial Trust CIO (including The Battle of Britain Memorial Trust and The Battle of Britain Memorial Ltd) (“The Trust”) will respect the confidentiality of any personal data shared with it, or that it obtains from other organisations, to keep it safe, and will make every effort to protect personal privacy.
The Trust operates in an honest and open manner and will always be clear how, when and why it collects and processes information and will not do anything with personal information that individuals would not reasonably expect.
Developing a better understanding of persons in contact with The Trust is important, and personal data allows us make better decisions and fundraise more efficiently to help it maintain and sustain the National Memorial to the Few and the activities associated with it.
The Trust is adopting an ‘opt-in’ communication policy. This means that we will only send communications to those that have explicitly stated that they are happy for us to do so via their preferred channels, be that by email, SMS, phone or post.
The Trust’s communications include information about how you can help support it through your membership, volunteering, or fundraising. If you would like to receive such communications but have not opted in, please contact us by email at firstname.lastname@example.org
The only way The Trust can maintain its activities is to fundraise and individuals giving it permission to send details of our fundraising activities is vital to its sustained survival.
The Trust collects information in the following ways:
When given to it DIRECTLY
There are many ways that individuals may give The Trust personal information. For example, when joining Friends of the Few, our support organisation, beginning to volunteer, making a donation, purchasing products or communicating with The Trust. Sometimes information is collected by an organisation working for or with us but The Trust remains responsible for such data at all times.
When given to it INDIRECTLY
When individuals give permission to OTHER ORGANISATIONS to share or it is available publicly
To improve our communications and services, The Trust may carry out data profiling and add data from other parties to records – individuals can opt out of this at any time by contacting The Trust.
The information obtained from other organisations may depend on individual privacy settings or the responses given to them and so individuals should regularly check them. This information comes from the following sources:
Third party organisations
Individuals may have provided permission for a company or other organisation to share data with third parties, including charities. This could be when buying a product or service, registering for an online competition or signing up with a comparison site.
Depending on personal settings or the privacy policies for social media and messaging services such as (but not limited to) Facebook, WhatsApp, LinkedIn or Twitter, individuals might give us permission to access information from such accounts or services
Information available publicly
This may include information found in places such as Companies House and information that has been published in articles/ newspapers.
Collected when individuals use The Trust’s WEBSITES OR APPS
Like most websites, The Trust may use “cookies” to help us make its site – and the way individuals use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone, tablet or other connected device). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. (see below)
In addition, the type of device being used to access our website or apps and the settings on that device may provide The Trust with information about the device, including what type of device it is, what specific device individuals have, what operating system is being used, what the device settings are, and why a crash has happened. Device manufacturers or operating system providers will have more details about what information your device could make available.
The type and quantity of information The Trust collects and how it may be used it depends on why individuals are providing it.
The Trust uses Google Analytics (or similar) to analyse the use of its websites by generating statistical and other information.
Details captured during a visit to our websites will include, but are not limited to, traffic data, location data, weblogs and other communication data and the resources accessed. However, all data collected is anonymous and will not identify users as an individual.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
What personal information The Trust collects and how it is used
How much personal information The Trust needs to hold depends on the relationship with individuals.
The Trust will only ever capture the minimum amount of information that is required and The Trust undertakes to keep personal information secure and only share with parties who need to know. Supporters For supporters, for example those making a donation, becoming a member of ‘Friends of the Few’, volunteering, registering to fundraise, signing up for an event or purchasing something from our shop, The Trust will usually collect:
Date of birth
Bank or credit card details
Details of the enquiry, service or product
Action taken, and if it is passed to anyone else, their details
Individual communication preferences
Where it is appropriate, The Trust may also ask for additional information. The Trust will mainly use
personal data to:
Provide individuals with the services, products or information asked for
Administer individual’s membership, volunteering activity or donation
Support fundraising, including processing Gift Aid
Keep a record of individual relationships with The Trust
Ensure The Trust knows how individuals prefer to be contacted
Understand how The Trust can improve its services, products or information
Employees & volunteers
The Trust will collect all personal information required to comply with employment legislation, including where necessary sensitive information. This may include medical information and where additionally appropriate we will perform a criminal record search. To prevent discrimination and to ensure diversity, we may request information from the employee or volunteer on religion, sexuality and ethnicity.
In order to prevent and detect crime, and to ensure the safety of our members and staff, we operate CCTV systems at the Battle of Britain Memorial site at Capel-le-Ferne, Kent. These cameras record footage in real-time and are operated and controlled by a contracted company.
Recording Telephone Calls
Telephone calls to the Memorial site are not routinely recorded.
On the rare occasions when a call might be recorded the caller will be informed that their call is being recorded and the reason why.
Direct Marketing and Data Sharing
With consent, The Trust may contact individuals to impart information about the various ways our work can be supported – without individual support The Trust cannot sustain its stated mission.
How The Trust will keep personal information safe and who has access to it
The Trust will ensure that there are appropriate physical and technical controls in place to protect personal details. For example, paper records are always locked away and our online forms are stored on protected network(s) and routinely monitored. The Trust undertakes regular reviews of who has access to information that is held to ensure that information is only accessible by appropriately trained staff, volunteers and contractors. Any external companies used to collect or process personal data on our behalf, will be subjected to checks before The Trust will work with them and a contract will be put in place which will include The Trust’s expectations and requirements regarding the management of personal data collected or have access to.
Sharing within The Trust
The Battle of Britain Memorial Trust CIO is a charity which has a trading arm, The Battle of Britain Memorial Ltd. It also embraces the historic organisation, The Battle of Britain Memorial Trust, which was superceded by the CIO.
The activities of The Battle of Britain Fighter Association were formally incorporated into the CIO on 1 January 2017
Information to The Trust may be shared with the other organisations to provide the service to you that individuals require.
Sharing with third parties
The Trust will only ever share personal data in other circumstances if we have your explicit consent. However, we may need to disclose your details if required to the police, other agencies, for example HMRC, regulatory bodies or our legal advisors.
Where The Trust will store your information
Your personal information will be hosted securely within the UK or the EU.
How long The Trust will retain personal information and how it will be kept up to date
The Trust will only keep personal information for as long as it is needed to assist with enquiries, processing of memberships or to assist with fundraising activities. There are statutory timescales on how long The Trust should keep personal information, eg gift aid transactions must be retained indefinitely, employment records for 6 years after an employee leaves. The Trust will delete information according to these statutory limits or according to guidance as issued by the Information Commissioner
Where possible, The Trust will keep personal information accurate, and where necessary, up-to-date. To assist in this task The Trust may use publicly available sources to keep individual records up to date; for example, the Post Office’s National Change of Address database and information provided to us by other organisations as described above.
The Trust would appreciate it if individuals would inform it if personal details change.
Individuals have certain legal rights and these are listed below for your convenience:-
Individuals have the right to have a copy of the information held on them by The Trust. A fee of £10 is payable for the information and unless there is a legitimate reason why you cannot make the application in writing, your request should be addressed in writing by letter or email, to The Trust contact shown below enclosing two proofs of identification
Individuals have a right to object to processing that is likely to cause, or is causing you damage or distress
Individuals have a right to prevent processing for direct marketing; simply email or call and The Trust will stop sending marketing materials
Individuals have a right to object to decisions being taken by automated means; although we can confirm we make no personal decisions using an automated process
Individuals have a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed
Individuals have a right to claim compensation for damages caused by a breach of the Act
Individuals who have given The Trust permission to process personal information, can withdraw consent at any time. In certain situations, these rights may not apply, for example: if you are a valid member of Friends of the Few we may have to write to you about your membership even if you asked The Trust previously not to, but The Trust would not send direct marketing.
If individuals are unhappy with how The Trust has processed personal information, they have the right to lodge a complaint with the Office of the Information Commissioner, (see below).
Changes to this Policy
Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. They are small text files that are placed on computers by websites that individuals visit.
The Trust does not store any personal data in the cookies that we may use, and stores the information anonymously to assist it in the running of the site, and also for monitoring the activity and traffic both to and through our website. The Trust uses Google Analytics cookies to do this.
Hon Secretary and Data Protection Officer
The Battle of Britain Memorial Trust CIO PO Box 337
Kent ME6 9AA
Tel: (Memorial Site) 01303 249292
Email: email@example.com Registered Charity 1169005
The Battle of Britain Memorial Trust Registered Charity 803258
The Battle of Britain Memorial Ltd Reg No. 08638616 (Trading Company)
The Deputy Data Protection Officer is:
The Site Manager
Battle of Britain Memorial New Dover Road Capel-le-Ferne
Kent CT18 7JJ
If individuals are unhappy with how The Trust has processed their personal information, please firstly contact the Data Protection Officer listed above. Individuals who are still unhappy may contact:
Information Commissioner’s Office
Helpline: 0303 123 1113 (local rate) or +44 1625 545 745