Warwick Triratna Group: Privacy & Cookie Policies

Privacy & Data Protection

1. OVERVIEW

The Warwick Triratna Group (‘The Group’) needs to collect and use certain types of information about the individuals and organisations who come into contact with it in order to operate. These can include friends, mitras, order members, Trustees, suppliers, volunteers, potential participants, and other people with whom the group has a relationship, or regularly needs to contact.

This policy explains how this data should be collected, stored and used, whether on paper, stored in a computer database, or recorded on other material in order to meet The Group’s data protection standards and, specifically, to comply with the law under the General Data Protection Regulation (GDPR 2018).

2. PURPOSE OF THIS POLICY

This policy ensures that the Group:

• Protects the rights of its members, supporters, suppliers and other stakeholders.
• Processes data lawfully, fairly and in a transparent manner.
• Collects data that are specific and limited to legitimate purposes and not further processed .in a manner that is incompatible with those purposes.
• Complies with UK data protection law and follows good practice.
• Is protected from the risks of a data breach.
• Processes data in a manner that ensures the security of personal data and protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.

3. ROLES AND RESPONSIBILITIES

This applies to all those handling data on behalf of the Group, e.g. the leadership team, other group volunteers, Trustees and members or the Triratna Buddhist Order, and other volunteers working with the Triratna Buddhist Community.
It applies to all data that The Group holds relating to individuals, including but not limited to:

• Names
• Email addresses
• Postal addresses
• Phone numbers
• Dates of birth
• Website access records and email preferences
• Payment details and purchase history
• Donation details and donation history
• Any other relevant personal information held (e.g. financial)

The Group is the Data Controller, which means that it determines for what purposes personal information is held and for what it will be used. For the purposes of this policy, [email protected] is the first point of contact for the Data Controller.

4. DATA PROTECTION PRINCIPLES

(i) We fairly & lawfully process personal data.

• The Group will only collect data where lawful and where necessary for legitimate purposes. In accordance with the GDPR, data will be processed on the lawful bases of Consent, Legitimate Interest, Necessary for contract or legal obligation.
• Where consent is required, the Group will ensure that individuals have given clear consent for the use of their personal data for a specific purpose that has been explained in clear, plain language that is easy to understand.
• The Group will ensure that consent is given by positively opting in and can be withdrawn at any time, without detriment, by contacting the Data Controller.
• The Group will keep a record of when and how it obtained consent from an individual and a record of exactly what it was told at the time.
• Personal data will be processed under the lawful basis of Contract where it is necessary to do so for transactions related specifically to events and other chargeable activities, including but not limited to, payment processing, providing information regarding Group activities, event and class information.
• The Group may require personal data to be processed under the basis of Legitimate Interest. An assessment will be undertaken to ensure that this is necessary, would be reasonably expected by the data subject, will not create an adverse impact on the data subject, and that we have put safeguards in place to protect data subjects from any potential harm. Any related communication will state the purpose of the procedure and will ensure that consent can be withdrawn for a specific reason, without detriment, by contacting the Data Controller. 
• Friends’ details will be collected when they first engage with the Group and will be used as a form of Contract. Other data may subsequently be collected, including payment and donation history.
• Friends’ details will be used to communicate event and other activities of The Group where there is a legitimate interest to do so. Where consent is required, this will be secured on an “opt in” basis, clearly explaining why the data are required and for what they will be used.
• Names of volunteers will be collected when they take up a position and will be used solely to enable communication related to their role, unless prior consent is otherwise given by the data subject.
• Further information, including personal financial information and criminal records information may be collected in specific circumstances where lawful and necessary (e.g. in order to process payment to the person or in order to carry out a DBS check).
• The name, contact details and other details of an individual who is not a volunteer with the Group may be collected at any time, such as booking for an event or showing interest in the organisation. The Group will communicate with the data subject about its related activities, and/or for Direct Marketing related to the Group’s work with the subject’s consent as required.
• Whenever The Group uses a 3rd party as a processor, a written contract is put in place.

(ii) We only collect and use data for specified and lawful purposes.

• When collecting data, The Group will ensure the data subject is notified about what data are required and for what purposes they will be processed.
• We will never use data for any purpose other than that stated or that can be considered reasonably related to that purpose.

(iii) We ensure any data collected are relevant and not excessive.

• The Group will not collect or store more data than the minimum required for the intended purpose.

(iv) We ensure data are accurate and up-to-date

• The Group will ask volunteers regularly to check and update their data. Any individual will be able to update their data at any point by contacting the Data Controller.

(v) We ensure data are not kept longer than necessary

• The Group will keep data on individuals for no longer than 36 months after its involvement with the individual has ceased, unless there is a legal requirement to keep records, or for statistical and archival purposes.

(vi) We process data in accordance with individuals’ rights

• The following requests can be made in writing to the Data Controller:
  • Volunteers and supporters can request to see any data stored on or about them. Any such request will be actioned within 30 days of the request being made.
  • Volunteers and supporters can request that any inaccurate data held on them are updated. Any such request will be actioned within 14 days of the request being made.
  • Volunteers and supporters can request to stop receiving any marketing communications. Any such request will be actioned within one month of the request being made.
  • Volunteers and supporters can object to any storage or use of data that might cause them substantial distress of damage, or any automated decisions made based on their data, including the right to erasure, subject to any legal reason that the Group may have to retain the data. Any such objection will be considered by the Team and a decision communicated within 30 days of the request being made.

(vii) We keep personal data secure.

• The Group will ensure that:
  • Data held by us are kept secure.
  • Electronically-held data will be held within a password-protected and secure environment.
  • Physically-held data (e.g. membership forms and examination entries) will be stored in a secure location.
  • Access to data will only be given to relevant volunteers where it is clearly necessary for the Group’s operation. The Data Controller will decide in what situations this is applicable and will keep a master list of who has access to relevant data.

(ix) Direct Marketing

• The Group will regularly send information regarding events, areas of legitimate interest and activities to consenting supporting. This includes, but is not restricted to, contacting them to promote events, updating them about Group news, fundraising and other Group interests. Whenever data is collected for this purpose, the Group will provide:
  • A clear and specific explanation of for what the data will be used
  • A method for users to show their active consent to continue receiving these communications (e.g. a ‘tick box’)
• Data thus collected will only ever be used in the way described and will never be used to market 3rd-party products unless prior explicit consent has been obtained.
• Every marketing communication will contain a method through which a recipient can withdraw their consent from subsequent such communications (e.g. an ‘unsubscribe’ link in an email). Opt-out requests such as this will be processed within one month.

Cookies

The Warwick Triratna Group uses cookies and similar tools across this website to improve its performance and enhance your user experience. This policy explains how we do that.

What are cookies?

Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.

There are many functions cookies serve. For example, they can help us to remember your preferences, analyse how well our website is performing, or ensure that user functions such as examination bookings work properly.

Certain cookies relating to Member services necessarily contain personal information. However, most cookies don’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites, or a user’s general location.

What sort of cookies does the College use?

Generally, our cookies perform up to three different functions:

1. Essential cookies
Some cookies are essential for the operation of our website. If a user opts to disable these cookies, the user may not be able to access all of the functions of this website.

2. Performance Cookies
We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high-quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages.

3. Functionality Cookies
We use functionality cookies to allow us to remember your preferences and to enable the delivery of specific services.

Does anyone else use cookies on the Warwick Triratna website?
We do not allow advertisers or other third parties to place cookies via the Group website. The only exception is that like many companies, we use Google Analytics to help us monitor our website traffic and improve its performance over time so that we can improve the services it provides and its relevance for visitors.

Can a website user block cookies?
As we’ve explained above, cookies help you to get the most out of our websites. By continuing to access our site, you are consenting to our use of cookies.
However, if you do wish to disable our cookies then please follow the instructions for your browser at http://www.allaboutcookies.org/manage-cookies/
Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly

Do we track whether users open our emails?
Our emails do not include any tracking software or code to allow us to monitor who opens or clicks.

More Information
More detail on how businesses use cookies is available at www.allaboutcookies.org.