In this policy, Surfers Against Sewage, or SAS, or ‘we’, ‘us’ or ‘our’ are all references to Surfers Against Sewage, which is a registered charity in England and Wales 1145877. A non-profit making company limited by guarantee. Registered in England No. 2920815 at Unit 2, Wheal Kitty Workshops, St. Agnes TR5 0RD.

This Privacy Policy (sometimes referred to as a Privacy Notice), together with our website terms and conditions, tells you about how we collect, use and protect your personal information. It relates to personal data we collect through your use of this website, microsites or our SSRS app, and personal information that you provide to us by telephone, in written correspondence (including letter and email), by SMS and in person.

If you have any queries about our Privacy Policy, please get in touch with us:

• By telephone: 01872 553001
• By email: [email protected]

• Or by freepost: RTKJ – JHYA – JYLC, Jacey Russell, Privacy Officer, SAS, Unit 2, Wheal Kitty, Workshops, St. Agnes, TR5 0RD

We’re committed to protecting and respecting your personal data and privacy, and being transparent about what we do with your information, no matter how you interact with us. That’s whether you want to work with us, volunteer or advocate for us, donate, use our services, want information or training, or want to learn more about what we do.

We won’t do anything with your data that you wouldn’t reasonably expect and we’re committed to using your personal information in accordance with our responsibilities. We’re required to provide you with the information in this Privacy Policy under applicable laws which include:

• The UK General Data Protection Regulation (UK GDPR) (the retained EU law version of the EU GDPR ((EU) 2016/679) which replaced the Data Protection Act 1998, from 25 May 2018)
• The Privacy and Electronic Communications (EC Directive) Regulations 2003

How and when we collect information about you

When you interact with us and directly give us information we may collect and store information about you.

Examples of this are:

• To become an SAS member
• To participate in a raffle or appeal
• To participate in community & events activities, e.g. runs, swims, marathons etc.
• When you sign up to support one of our campaigns
• If you’re involved in SAS educational programmes
• When you report a pollution incident, or submit a sickness report form
• When you sign up to our e-newsletter to receive information about fundraising, campaigns, our shop and volunteering activities
• To become one of our Regional Rep volunteers
• To organise a clean on behalf of SAS (Lead Volunteer)
• To work with your local community through our Plastic Free Communities Programme
• To participate in a clean (clean volunteer)
• To receive updates on water quality through our Safer Seas & Rivers Service app
• When you provide permission to other organisations to share it with us (see below for further information)
• When we collect it as you use our websites or app
• From publicly available sources (where possible) to keep your information up to date (e.g. the Post Office’s National Change of Address database)

When you interact with us on social media platforms such as Facebook, WhatsApp, X or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform.

We combine the information from these sources with the information you provide to us directly.

When providing permission for third party organisations to share your data you should check their Privacy Policies carefully to understand fully how they will process your data.

What information do we collect?

We collect various personal information such as name, postal address, telephone number, email address, date of birth (where appropriate), information about your interests and hobbies etc.

We collect this information only in connection with specific activities, such as campaign updates, newsletter requests, registration or membership requests, product purchases, feedback, donations (regular and one off), competition entries, information you provide in public forums on our sites and applications and sign ups to community activations.

The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our sites. However, if you choose to withhold requested information, we may not be able to provide you with certain services.

Data protection law recognises that certain types of personal information are more sensitive. This is known as ‘sensitive’ or ‘special category’ personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person’s sex life or sexual orientation.

Sensitive information will only be collected where necessary, for example, we may need to collect health information from you when you register for a challenge event or to deliver a community service as a volunteer or member of staff. Clear notices will be provided at the time we collect this information, stating what information is needed, and why.

With your explicit consent, we may also collect sensitive personal information if you choose to tell us about your experiences relating to our services for use in a case study.

The types of data we collect are:

• Identity Data – includes first name, last name, title, date of birth, age, life stage, gender and images
• Contact Data – includes billing address, delivery address, email address and telephone/mobile number
• Financial Data – includes bank account, payment card details, direct debit details and wealth quartile
• Employment – includes relationship with previous, current or future employer and their details
• Transaction Data – includes details about previous donations made and interactions regarding our services/resources
• Technical Data – includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, microsites and emails we send you.
• Profile Data – includes your membership/donor number/unique ID, your interests, preferences, feedback and survey responses
• Usage Data – includes information about how you use our website, microsites and app, and services and resources
• Marketing and Communications Data – includes your preferences in receiving marketing from us and your communication preferences
• Health Data – includes details of water quality related illnesses, photos and impact of illness
• Education Data – includes details of school attended and qualifications attained

Please note that we may also collect and/or process other personal data from time to time.

We may collect the following special categories of personal data about you – race or ethnicity, health, religious or philosophical beliefs, sex life and sexual orientation. We may collect criminal record data in relation to due diligence checks. Finally, we may use different methods to collect data about you including direct interactions, automated technologies or interactions and third parties or publicly available sources (e.g. Royal Mail postal redirection service).

We’ll use your personal information for the following purposes:

• Donation processing – We’ll process personal information you provide in order to administer any one-off or on-going donations you make, to maintain your membership and to claim Gift Aid
• Responding to a request – If you contact us with a query, we may use your personal information to provide you with a response
• Volunteering, events and community projects – We’ll process your details for the use of contacting you about volunteering, events or community projects that you are involved in or are interested in taking part in. In the future, we may also contact you to see if you would like to take part again. If you have taken part as a volunteer, have run an event or have run a community project, we may also contact you for fundraising and marketing purposes in line with this Privacy Notice
• Fundraising or direct marketing – We’ll only send you marketing information by email or SMS if you have given us specific consent to do so (see below for further details on marketing). If you withdraw your consent and then subsequently opt in to receive marketing information again, then your preferences may be updated.  We use legitimate interest to contact Surfers Against Sewage supporters with regards to telephone and mailings, unless you have expressly told us by opt-out that you do not want to be contacted. If you do not want to be contacted for marketing or fundraising purposes you can opt out at any time by contacting us:

• • by telephone: 01872 553001
  • by email: [email protected]
  • or by freepost: RTKJ – JHYA – JYLC, Jacey Russell, Surfers Against Sewage, Unit 2, Wheal Kitty, Workshops, St. Agnes, TR5 0RD
• Monitoring and Evaluating – We may use your information in order to improve current and future delivery of our services
• Processing an application to work with us – We may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and to respond to you
• Transactional purposes – We’ll need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, processing your Ocean Network membership
• Providing and developing our website – We may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further
• Administration – We may use your personal information to record and deal with a complaint, to record a request not to receive further marketing information, to record what our volunteers have done for us, and for other essential, internal record keeping purposes
• Prevention of crime – We may process your personal information to prevent crime and to keep our people and the public safe
• Protecting your vital interests – We may process your personal information where we reasonably think that there is a risk of serious harm or abuse to you or someone else
• Market research and surveys – We may invite you to participate in surveys or market research to help us improve our website, fundraising, services and strategic development. Participation is always voluntary and no individuals will be identified as a result of this research, unless you consent to us publishing your feedback
• Legal, regulatory and tax compliance – Where required we are subject to a legal obligation, we may process your personal information to fulfil that obligation, to develop our products, services, systems and relationships with you. When we are legally required to hold certain personal information to fulfil statutory obligations, e.g. the collection of Gift Aid
• Profiling and analysis – We may occasionally, and for the purposes of understanding our supporter base better, use your personal information to conduct profiling of our supporters or potential supporters, high net value individuals and legacy pledgers. This will help us to target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to such use of your personal information for profiling at any time by contacting us using the details set out at the end of this Privacy Notice

Our profiling and analysis activities can be broken into five categories:

1. Data matching – We may combine the personal information you have given us with data obtained from external sources, such as the Office for National Statistics, to infer the likely social, demographic and financial characteristics, so we can tailor our communications, marketing and services to better meet your needs or the needs of others like you based on the insight we gain from the profile we build. We will not use the results of this data matching activity in a way that intrudes on your privacy or your previously expressed privacy preferences.

1. Segmenting – We conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that campaigns or mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who may fall within a certain segment of supporters.
2. Major donor analysis – We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources such as Google; Companies House; published biographies and publicly available LinkedIn profiles. The type of information we collect can include:
   1. career overview
   2. gift capacity
   3. areas of interest
   4. history of giving to us and others
   5. how the individual is connected with us and others
   6. public information on any philanthropic activities.
3. High value event planning – We may also use profiling to produce short biographies of people who are due to meet with our leadership or attend an event that we may be hosting. This helps our people to understand more about those we engage with, and their interests or connection to us
4. Ethical screening and minimising risk – As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity

This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering.

We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it.

We may also ethically screen supporters to minimise risk of creating an association with an individual or group that conflicts with the standards we’ve set out in our overarching ethical policy.

Marketing

We may use your identity, contact, technical usage and profile data to form a view on what we think you may want or need, or what may be of interest to you, this is how we decide which area of our work may be most relevant to you. We call this marketing.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Who do we share your information with?

We’ll only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us. However, in some cases we will share your information with third parties for the following reasons:

• Third party suppliers – We may need to share your information with data hosting providers or service providers who help us to deliver our services, projects, or fundraising activities and appeals. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.
• Where legally required – We’ll comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else.

We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.

Lawful basis for processing

We only process your data where we have identified a valid lawful basis to do so. These are as follows:

Consent – In most cases we will only process your data when you have provided us with your consent, unless we have identified a legitimate interest, or to fulfil a contractual or legal obligation (see below for all three cases).

There is also more information below regrading email consent and telephone and mail.

Legitimate Interest – If we contact you on the basis of legitimate interest, Surfers Against Sewage will always complete a legitimate interest impact assessment (LIA).  This will be shared and reviewed by senior management. Examples of how we may contact you under legitimate interest for mail or telephone direct marketing campaigns are: –

• Welcoming you to Surfers Against Sewage
• Asking you to complete a Gift Aid declaration
• Thanking you for your support
• Asking if you would consider increasing your regular support or membership
• Asking if you may consider leaving a gift in your will to Surfers Against Sewage
• Finding out why you left Surfers Against Sewage
• Contacting you about renewing your membership or support
• Contacting you about appeals or campaigns that we need financial support for
• If you have stopped supporting us financially, asking if you may re-join or support us with a donation

Contractual Obligation – Where processing is necessary to comply with our obligations arising out of a contract, for example fulfilling a direct debit instruction.

Legal Obligation – Where processing is necessary to comply with the law, for example safeguarding.

If at any time you want to alter your preferences or request that we stop communicating with you please let us know by calling us on 01872 553001 or sending an email to [email protected].

Consent by email

On our website and when we collect any personal information, you will be given the option to opt-in to receive communications from us by email. Where you agree, we may send you information about our events, campaigning, membership, volunteering, products, fundraising and other activities. By providing personal data to us you consent to its use as described in this Privacy Policy.

By entering one of our competitions, volunteering, taking part in an event and/or a community-based project such as a clean, plastic free communities, SAS education, you will generally be agreeing to receive mailings or emails from Surfers Against Sewage for direct marketing and agreeing to this privacy policy.

Telephone and mail

For mailing and telephone based direct marketing campaigns, we may contact you by telephone and mailing campaigns under legitimate interest. We will not contact you if you are registered with the Telephone Preference Service (TPS) or Mail Preference Service (MPS) unless you have given us opt in consent that you are happy to receive calls or mailings from us.

You may still receive other types of telephone calls or mails from us as long as they are not for marketing purposes and are admin-based, such as checking your direct debit mandate or Gift Aid status.

We do outsource some of the telephone calling we carry out as well as mailing programs, but we’ll only ever use carefully selected organisations which operate in a sympathetic manner to Surfers Against Sewage.

If you’re under 16

If you are aged under 16, please ensure you obtain your parent/guardian’s consent before sending any personal information to any website or to Surfers Against Sewage.

We do have activities for those under 16, so we may ask your age when contacting you. Prior to taking part in these activities, please ensure you speak to your parent or guardian.

Please note that we will not knowingly accept online donations, raffle ticket requests or orders for goods or services from persons aged under 16 years.

We encourage you to be aware of the activities in which your children are participating, both offline and online. If your children voluntarily disclose information, this may encourage unsolicited messages. We suggest that you discourage your child from providing any information without your consent.

How we protect your information

We use technical and organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.

We undertake regular reviews of those who have access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partners. We do this in accordance with industry standards and do not store the details on our website.

However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.

Vulnerable circumstances

We understand that additional care may be needed when we collect and process the personal information of vulnerable supporters and volunteers. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.

How long will we keep your information?

We’ll keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction).

If you request that we stop processing your personal information for the purpose of marketing we may in some instances need to add your details to a suppression file to enable us to comply with your request not to be contacted.

If you have participated in an event or challenge, been a volunteer, taken part in a project, we may keep and use your information to contact you for up to six years in line with this privacy policy.

In respect of other personal information, we’ll retain it for no longer than necessary for the purposes for which it was collected, taking into account guidance issued by the Information Commissioner’s Office.

International transfers of information

We may, on occasion, decide to use the services of a supplier outside the European Economic Area (EEA), which means that your personal information is transferred, processed and stored outside the EEA. You should be aware that, in general, legal protection for personal information in countries outside the EEA may not be equivalent to the level of protection provided in the EEA.

However, we take steps to put in place suitable safeguards to protect your personal information when processed by the supplier such as entering into the European Commission approved standard contractual clauses. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.

Your rights to your personal information

Data protection legislation gives you the right to request access to personal information about you which is processed by Surfers Against Sewage and to have any inaccuracies corrected.

You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information.

If you wish to exercise these rights, please email [email protected]. You will also need to provide copies of two separate identification documents, such as a passport, driving licence, or utility bill.

Please also provide any additional information that is relevant to the nature of your contact with us, as this will help us to locate your records.

You can send the documents via post to: Privacy Officer, Surfers Against Sewage, Unit 2, Wheal Kitty, Workshops, St. Agnes, TR5 0RD

Alternatively, email a copy of the form along with scans or photos of your two forms of identification to [email protected]

We’ll respond within 28 days, on receipt of your written request and copies of your identification documents. We reserve the right to charge a fee to process the request.

Storing your information

Information which you submit to us is sent to computers located in the United Kingdom, specifically SAS, Unit 2, Wheal Kitty Workshops, St. Agnes, TR5 0RD. This is necessary in order to process the information and to send you the information you have requested.

Information submitted by you may be transferred by us to other reputable third party organisations as referred to in this Policy. This will be done in accordance with guidance issued by the Information Commissioner’s Office.

Any personal information you supply to us will not be retained for longer than necessary.

Other websites

Our websites contain hyperlinks to many other websites. This Privacy Policy only applies to our websites so when you link to other websites you should read their own privacy policies.

In purchasing goods or services from any of the companies to which any Surfers Against Sewage sites link, you are forming a contract with the company(s) concerned (agreeing to their terms and conditions), not Surfers Against Sewage.

Using our social media pages

While this statement covers our privacy practices and how we’ll use any information collected from our websites and social media pages, it doesn’t cover how providers of social media websites will use your information.

You should read the social media site’s privacy policies before adding any content to our social media pages. Make use of the social media site privacy settings and reporting mechanisms to control the way that your information is handled.

Posting content on our websites and social media pages

Remember that the internet provides instant worldwide access. Any information that you provide will be worldwide instantly.

We don’t moderate our websites. So, if you post comments about other people it’s not only your privacy that is at stake. Protect your friends’ privacy and reputations. Be careful about uploading any content that may show you or your friends in compromising situations and be aware that other users may abuse the content you have provided.

Please don’t provide information about yourself or other people unless you’re sure you and they are happy to have it made public. In particular, don’t provide any information about others without their consent where that information might identify them, such as:-

• Names
• Tagged photos
• Location

Under no circumstances make public other people’s home addresses, email addresses or contact numbers.

Scientific data

If you supply Surfers Against Sewage with scientific or environmental records e.g. as part of a citizen science or volunteer project, they will be carefully stored by us and/or our project partners. Such records may include, for example, amount of litter removed from a beach clean, location, dates and litter photographs. Scientific data sharing helps to further research, education and our national understanding of biodiversity and conservation issues. Hence anonymised scientific data may also be shared with third parties such as academic researchers and students.

In some circumstances such scientific data (but no personal information) may be sold, but the income will be directly used to support the running cost of our data-gathering projects. By submitting your scientific or environmental records you are indicating agreement with our approach.

Security

We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. Whilst we can’t ensure or guarantee that loss, misuse or alteration of information won’t occur, we’ll use standard industry methods to prevent this.

Unfortunately, the transmission of information across the internet isn’t completely secure and whilst we do our best to try to protect the security of your information, we can’t ensure or guarantee that loss, misuse or alteration of information won’t occur whilst you or we are transferring this information.

Where you or we have provided a password enabling you to access parts of our websites or use our services, it’s your responsibility to keep this password confidential. Please don’t share your password with anyone.

How to make a complaint or raise a concern

If you would like more information, or have any questions about this Privacy Notice, to make a formal complaint about our approach to data protection or raise privacy concerns please contact us:

• By telephone: 01872 553001
• Or by email: [email protected]
• Or by post: Jacey, Privacy Officer, SAS, Unit 2, Wheal Kitty Workshops, St. Agnes, TR5 0RD

If you would like to make a complaint in relation to how we’ve handled your personal information, please follow our complaints procedure which is available by contacting us via the contact details above. If you are not happy with the response you receive, then you can raise your concern with:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Alternatively, you can visit their website.

We are registered with the Information Commissioner’s Office as a Data Controller under number ZA337514.

Changes to our Privacy Policy

Our Privacy Policy may change from time to time, so please check this page occasionally to see if we’ve included any updates or changes, and that you are happy with them.

(Last updated: 20/02/2024)

Cookie Policy

Cookies and how they benefit you

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

• Make our website work as you’d expect;
• Remember your settings during and between visits;
• Improve the speed/security of the site;
• Allow you to share pages with social networks like Facebook;
• Continuously improve our website for you;
• Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do).

Granting us permission to use cookies

If the settings on your browser that you are using to view this website are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below, however doing so will likely mean that our site will not work as you would expect.

How long do cookies last?

When a web server sends a cookie, it asks your browser to keep that particular cookie until a certain date and time. These dates can be:

• Some date in the future – Might be a few minutes or a few hours from now (to track something like your shopping cart in an online store).The cookie might expire many years in the future, to keep track of your browser for a long time;
• When you close your browser – Called a session cookie, the next time you start your browser these will have vanished;
• Some date in the past – This is how the server asks a browser to remove a previously-stored cookie.

Our own cookies

We use cookies to make our website work including:

• Remembering if you have accepted our terms and conditions;
• Allowing you to add comments to our site;
• Remembering if we’ve already asked you certain questions (e.g. you declined to use our app or take our survey).

There is no way to prevent these cookies being set other than to not use our site.

Site improvement cookies

These are called “performance cookies” on the cookie banner.

We regularly test new designs or site features on our sites. We may do this by showing slightly different versions of our websites to different people and anonymously monitoring how our site visitors respond to these different versions. Ultimately this helps us to offer you a better website experience.

Anonymous visitor statistics cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using, how long they spend on the site, what page they look at, etc. This helps us to continuously improve our website. These analytics programs also tell us, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before, helping us to develop our services for you. Our site uses the following analytics programmes:

• Google Analytics

Advertising or Targeting cookies

These types of cookies are used to deliver adverts which will be more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Targeting or advertising cookies will often be linked to site functionality provided by the other organisation.

We use ‘Advertising’ cookies on Surfers Against Sewage websites to:

• Link to social networks, like Facebook, who may use information to provide targeted advertising to you on other websites;
• Identify that you have visited a Surfers Against Sewage website, to show you relevant adverts from us;
• Provide advertising networks with information on your visit so that they can present you with adverts that you may be interested in.

Third party functions

Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Our site includes the following third party functions which use cookies:

• YouTube

Disabling these cookies will likely break the functions offered by these third parties.

Turning Cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so, however, will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites.

It may be that your concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.