This policy covers the Old Royal Naval College and its subsidiaries “we” in relation to the collection and use of the information you give us.
Who we are
By the Old Royal Naval College and our subsidiaries “we” mean:
The Greenwich Foundation for The Old Royal Naval College, registered charity number 1062519
The Greenwich Trading Company, registered company number 3340541
The Greenwich Trading Company carries out the following commercial activities: functions and banqueting, catering and retailing. As a wholly owned subsidiary, the Trading Company is subject to the Greenwich Foundation’s policies and procedures.
The Old Royal Naval College was established in 1997 as a charity to conserve the magnificent Baroque buildings and grounds for present and future generations and to provide opportunities for wide and diverse audiences to enjoy and share its significance.
For the purposes of the General Data Protection Regulations (GDPR) and any subsequent UK legislation covering data protection The Greenwich Foundation and/or the Greenwich Trading Company are the data controller(s) of your personal information.
Our address is Foundation House, 2 Cutty Sark Gardens, London SE10 9LW.
What type of personal information we collect
The type and amount of information we collect depends on why you are providing it. Some examples are as follows:
- your full name and your title and/or gender;
- birth date or alternatively a relevant age range;
- postal address;
- telephone number(s);
- email address;
- records of your correspondence with us;
- bank or credit card details (if you purchase something from us or donate to us);
- donation and gift aid details (if you donate to us);
- dietary, accessibility, and mobility information;
- CCTV footage of those visiting our premises and grounds.
- Photographs and digital images of individuals
But we may also collect, hold and process other personal data where it is appropriate and relevant, for example:
- details of why you have decided to support/contact us and how you may have heard about us and the work that we do;
- details of how you would like to be involved and what you intend to do with the information we provide;
- personal data about you that will enable us to be more precise in what we send you or how we approach you; and
- for purely business-related reasons, including managing relationships with third party and partner organisations.
- We will only process sensitive personal data also known as special categories of data (eg. in relation to your health), with your explicit consent, for reasons where necessary for the establishment, exercise or defence of legal claims.
How and why we use this personal data?
We will use your personal data to:
- provide you with the information, product or service you have requested from us, including such things as buying tickets to our tours, specific events that we run, merchandise from our shop, responding to your enquiries and requests, attending educational activities and events, and to tell you about our work and our fundraising;
- provide you with other information which we feel may interest you. This may include newsletters, updates, information in relation to fundraising campaigns, voluntary surveys or questionnaires for you to complete, details of relevant volunteering opportunities, and details of any promotions and competitions we are running. We may also send you details of events we think you may be interested in attending;
- administer all aspects of being a Patron or your membership of Angels and the Art Club;
- analyse and understand how people use our websites and digital products so we can improve and personalise the experience for users and reflect your preferences and previous interactions;
- keep a record of our relationship with you;
- improve how we communicate with you, how we fundraise, and how we operate more generally; keep in contact with you in the ways that you have requested or agreed to;
- personalise our services and communications to you (for example, to ensure your age, location and previous involvement with us will be taken into account);
- provide you with information about carefully selected third party events, products, campaigns and competitions, where we are permitted to do so;
- notify you about changes to our services;
- administer and process payments you make for products, services and charitable donations made to any of our entities;
- verify your identity where required to use some of our services and benefits;
- comply with applicable laws and regulations and requests from statutory agencies including for such purposes as health and safety; the detection and prevention of crime and safeguarding; and
- carry out any obligations or provide you with any other services, functionality or content which you specifically request or agree to.
The Old Royal Naval College does not use personal data for automated decision-making. However, we may use profiling techniques in certain circumstances for the purpose of evaluating personal data to provide you with more targeted advertising and for the purpose of segmenting our database of visitors and supporters so that we can communicate with you in the most relevant way possible.
Charitable giving is very important to our ability to achieve our charitable purposes. We carry out a wide variety of marketing activities to seek individuals’ support for our work, ranging from appeals for small one-off donations, to large fundraising initiatives for specific projects, such as building renovations.
We want to ensure that we are contacting you with tailored and appropriate communications, and ensure we direct our resources and fundraising activities as efficiently and effectively as we can. We also want to communicate with you from time to time to thank you for your support and tell you what we have achieved with the help of your donation.
Research and profiling using information in the public domain
Throughout our history the Old Royal Naval College has relied on gifts of all sizes to support both our recurrent costs and for new buildings or projects. In order that our fundraising is appropriate, respectful, efficient and effective, we tailor our approaches to different people in different ways. We use information you have given us, sometimes together with data we collect from publicly available sources, to help us decide how best to do this.
For a small number of people, we may undertake research using publicly available information relating to philanthropic activities, wealth and capacity to give, to create a profile of interests and preferences. This helps us understand the background of the people who we believe may be willing to attend events and enter into a dialogue with us to learn more about supporting our work and organisation. Ultimately it helps us to ensure that proactive requests for gifts are directed to only those who we believe may be able and willing to give. This information is collected from public sources such as news articles, Companies House, the Charity Commission.
If we do collect such information about you, we will inform you within one month of collecting this information to provide you with an opportunity to opt out of your data being used for these purposes. You can also opt out by emailing us on [email protected].
We also have an obligation to ensure we are undertaking appropriate due diligence on potential donors, in accordance with guidelines set out by the Charity Commission and the Fundraising Regulator, and we may collect information from the public domain information for this purpose too.
Lawful bases we rely on to use your personal data
The legal bases that we rely on for processing your personal data are:
You have provided your consent to us using your personal data for a specific purpose
We will ask for your consent to use your personal data to send you marketing emails and SMS.
You always have the right to withdraw your consent at any time.
It is necessary in connection with the performance of a contract with you
Sometimes it is necessary to process your personal data so that we can enter into contractual relationships with you. For example, if you purchase something from our online shop, or become an Angel or member of the Art Club (our membership schemes) or a Patron of the Old Royal Naval College, we will require your personal data to enable us to perform our agreement.
It is necessary for compliance with a legal obligation to which we are subject
This would include where we have to retain certain records, for example, to manage health and safety, for the detection and prevention of crime, safeguarding obligations, for maintaining suppression lists to ensure we comply with marketing laws, for tax reasons (such as those related to gift aid donations) and undertaking due diligence before accepting certain donations or entering into certain relationships.
It is within our legitimate interests
Applicable law allows personal data to be collected and used if it is reasonably necessary for our legitimate interests or a third party’s legitimate interests (as long as the processing is fair, balanced and does not unduly impact individuals’ rights).
We will rely on this ground to process your personal data when it is not practical or appropriate to ask for your consent, and where we are confident that this will not impact your rights. This may include where we undertake research on individuals including before we proactively contact them, as set out in Research and profiling section above.
Our legitimate interests include raising funds for a wide range of activities to support our charitable objectives. We also have a legitimate interest in publicity and income generation, campaigning and fundraising in order to support these objectives and undertaking due diligence to establish the provenance of donations that are made, or may be made, to us.
We will also rely on our legitimate interests for the proper administration of the Old Royal Naval College, and to manage our operations (for example, maintaining appropriate records and databases, for the detection and prevention of crime and safeguarding all those who access our premises and facilities).
When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
How we collect personal data
We may collect information from you whenever you contact us or have any involvement with us, for example when you:
- visit our website (see our Cookies policy below)
- donate to us or fundraise for us
- enquire about our activities
- apply for our services or a job
- sign up to receive news about our activities
- create or update a booking or supplier account
- post content onto our website/social media sites
- volunteer for us in any capacity including becoming a Trustee
- take part in our events
- contact us in any way including online, email, phone, SMS, social media or post
We collect information about you:
When you give it to us directly:
You may provide your details when you ask us for information or make a booking or donation, apply to be a member of staff or volunteer, attend an event or contact us for any other reason.
When a third party provides us with your personal data:
When you use our website and/or our free Wi-Fi service:
We may collect personal data about you when you use our website and free Wi-Fi. Whenever you input personal data into our website (for example, if you become a member or renew a membership online or otherwise support us through our website, book a visit online), we will collect the personal data that you give to us.
Free Wi-Fi access is available at the Painted Hall via the Painted Hall Wi-Fi network (Blackbx). If you access the free Wi-Fi network, you will be asked to agree to the Old Royal Naval College’s Wi-Fi terms and conditions of use, which provide information about how your data will be used.
We use “cookies” to identify you when you visit our websites and digital products. Amongst other things this helps us to understand our website users and may enable us to improve the website experience for you and/or other users.
Communications and marketing
We may contact you by post and telephone, and, where you have provided consent, by e-mail, to let you know about our events and activities retail offers and promotions, or about our work more generally; and to request donations and provide you with information about and the opportunity to participate in our fundraising activities. We provide the opportunity for you to opt-out from receiving our marketing communications every time we contact you.
You can opt-out from receiving our marketing communications, or update your contact preferences at any time by emailing: [email protected]
Social media targeting
If you are a social media user, we will use certain social media tools as part of our relationship with you. These tools include such things as Facebook and Instagram Custom/Lookalike Audiences, Google Customer Match/Similar Audiences, Twitter Tailored/Lookalike Audiences.
Through using these tools, we will provide some of your data to the social media platform / organisation to allow them to identify your social media profile with them. The social media platform / organisation will then show you relevant advertisements relating to the Old Royal Naval College which we think you will be interested in seeing on your newsfeed.
We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies.
The personal data we collect from you may be shared outside the European Economic Area (“EEA”) only with the American Friends of the Old Royal Naval College. The American Friends of the Old Royal Naval College is a 501(c)3 charity formed on 6 May 2015. Its principle activity is to fundraise for the Old Royal Naval College in the UK. Where your personal data is transferred outside the EEA, we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your personal data.
We may collect and manage personal data about children in some circumstances, such as where children participate in activities at our site (such as educational and learning activities).
Where consent is required to process children’s personal data and the child is under 16 years, where appropriate we shall seek consent from a parent or guardian, or shall ensure such consent is in place before any data is shared with us. We shall only hold personal data about children that is absolutely necessary for the purpose of the event/programme that they are applying for or participating in.
How we keep your information safe
We understand the importance of security of your personal information and take appropriate steps to safeguard it.
Our server is kept secure, all computers and relevant software are password protected. The number of staff users of personal data is as kept as small as possible.
We always ensure only authorised persons have access to your information, which means only our staff, volunteers and contractors, and that everyone who has access is appropriately trained to manage your information.
No data transmission over the internet can however be guaranteed to be 100% secure. So while we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.
Keeping your information up to date
We really appreciate it if you let us know if your contact details change. You can do so by contacting us at [email protected]
You have the right to request details of the processing activities that we carry out with your personal information through making a Subject Access Request using the Data Subject Request Form. Such requests have to be made in writing. To make a request contact us at [email protected].
You also have the following rights:
- the right to request rectification of information that is inaccurate or out of date;
- the right to erasure of your information (known as the “right to be forgotten”);
- the right to restrict the way in which we are dealing with and using your information; and
All of these rights are subject to certain safeguards and limits or exemptions.
Old Royal Naval College tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of the Old Royal Naval College’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
Complaints and enquiries about, or suggestions for improvements to, our data protection processes should be sent to us using the contact details provided below.
You are also entitled to make a complaint to the Information Commissioner’s Office. For further information see the Information Commissioner’s guidance.
We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected. We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries.
In some cases, we are also obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep records of contractual or financial matters).
Whilst the specific time periods vary depending on the circumstances, in general we will not keep records that include personal data for more than 10 years after a particular matter or exchange has concluded. If you ask us to stop contacting you with marketing or fundraising materials, we will keep a record of your contact details and limited information needed to ensure we comply with your request.
Where we rely on your consent to contact you for direct marketing purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. We may periodically ask you to renew your consent.
This policy may be changed from time to time. If we make any significant changes we will advertise this on our website or contact you directly with the information.
Do please check this policy each time you consider giving your personal information to us.
How to contact us
Greenwich Foundation for the Old Royal Naval College
2 Cutty Sark Gardens