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Privacy Notice

This Privacy Notice explains when and why we collect personal information about you, how we use it and the conditions under which we may disclose it to others. Your personal data is defined as any information that can directly or indirectly identify you. This notice also explains how we keep your data safe and secure and includes information you need to know about your rights and how to exercise them. If you have any questions regarding our Privacy Notice and our use of your personal data, or you would like to exercise any of your rights, please get in touch via the following information:

Email us at: [email protected]

Call us at: 01494 783453

Write to us at: Unit 16B, Chiltern Court, Asheridge Road, Chesham, HP5 2PX

  1. Who are we?

We are The Inland Waterways Association and for the purposes of UK Data Protection Law, we are registered with Companies House, under Company Number 612245. We are a national charity (number 212342) dedicated to protecting and restoring Britain’s inland waterways.

  1. Personal data collected, how and why we collect it, and on what lawful basis

Please click on the relevant appendices below

  1. Your Rights

Under data protection laws in the UK, you have certain rights over the personal information that we hold about you. If you would like to exercise your rights, please get in contact with any of the details listed above. Here is a summary of the rights we think apply:

(a) Right to be Informed

You have the right to be informed as to how we use your data and under what lawful basis we carry out any processing. This Privacy Notice sets this information out.  If you have any questions, please get in touch.

(b) Right of Erasure – also known as the right to be forgotten

You may ask us to delete some or all of the information we hold about you. Sometimes, where we have a legal obligation, we cannot erase your personal data.

(c) Right to Object

You have the right to object to processing where we are using your personal information, such as where it is based on legitimate interests, or for direct marketing.

(d) Inaccurate personal information corrected

Inaccurate or incomplete information we hold about you can be corrected. The accuracy of your information is important to us, and we are working on ways to make this easier for you to review and correct the information that we hold about you. If any of your information is out of date, or if you are unsure of this, please get in touch through any of the contact details listed in this notice.

(e) Right of restriction

You have a right to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or if we are not lawfully allowed to use it.

(f) Right to Access your information

You have a right to request access to a copy of your personal information that we hold about you, along with the information on what personal information we use, why we use it, who we share it with, how long we keep it for and whenever it has been used for automated decision making. You can make a request for access free of charge, but we will require proof of your identity before releasing any information.

(g) Automated decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right to question the outcome of automated decisions that may create legal effects or create a similar significant impact on you.

(h) Portability

You can ask us to provide you, or a third party, with some of the personal information that we hold about you.

(i) Right to withdraw consent

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

  1. Transferring your information outside of the United Kingdom

Where personal data is stored outside of the UK and the European Economic Area, safeguards to protect personal data may include but are not limited to the UK Addendum used in conjunction with the European Union Standard Contractual Clauses, or UK International Data Transfer Agreement. Such safeguards will be subject to Transfer Risk Assessments.   Most of the data held by IWA is stored on servers owned by Microsoft in the USA and multiple other countries for data back-up and security reasons.

  1. Complaints procedure

If you are unhappy with the way we process your data, please get in touch by using one of the contact methods above. You can also make a complaint to the Information Commissioner’s Office which regulates the use of information in the UK. They can be contacted at:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

Website: https://ico.org.uk/global/contact-us/

  1. Changes to our Privacy Notice

This privacy notice is kept under regular review.  If we make any significant changes to the way in which we process your information, we will let you know by notice in our members magazine Waterways or via the website or our electronic newsletter Bulletin.  It was last updated on 17th February 2025.

Appendix 1 – Human Resources

Job applicants, current and former employees, contractors

How and when do we collect information about you?

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment/contract with us. In some cases, we will collect data about you from third parties, such as employment agencies or former employers when gathering references.

What types of information is collected about you and who provides it?

We keep several categories of personal data on our employees and job applicants, in order to carry out effective and efficient processes. Specifically, we may process the following types of data:

  1. personal details such as name, address, phone numbers
  2. name and contact details of your next of kin
  3. your photograph, your gender, marital status
  4. photographs and footage of the organisation’s events where you may appear
  5. information of any disability or other medical information you have disclosed
  6. right to work documentation (e.g. copy of your passport or birth certificate)
  7. information gathered via the recruitment process such as that included in a CV, cover letter or application form, references from former employers, details on your education and employment history, etc
  8. National Insurance number, bank account details and tax codes
  9. information relating to your employment with us (e.g. job title, job description, salary, terms and condition of the contract, annual leave records, appraisal and performance indication, formal and informal proceedings involving you such as letters of concern and disciplinary, disciplinary and grievance proceedings.
  10. internal and external training undertaken, includes copies of certificates and reports
  11. information on time off from work including sickness absence, family related leave, etc
  12. IT equipment use including telephones and internet access
  13. your opinions and views, as expressed during your work, in e-mails, letters, reports, etc.
  14. copy of your driving licence

We may also process special category of data which include health information, sexual orientation, race, ethnic origin, political opinion, religion, trade union membership, genetic and biometric data. We may also process criminal records information if the role involves checks with the Disclosure and Barring Service.

How is the information used?

We are required to use your personal data for various legal and practical purposes for the administration of your contract without which we would be unable to employ you or work with you. Holding your personal data enables us to meet various administrative tasks, legal and contractual obligations. We process information in relation to checks with the Disclosure and Barring Service for our safe recruitment practices.

Lawful basis for processing

We mainly use ‘contractual obligation’ as a lawful basis for processing personal data for employees, job applicants and contractors. We may also have a legal obligation in order to process and share your data, for example we need to share salary information to HMRC or use some of your data to enrol you on a pension scheme.

We may rely on our legitimate interest for processing activity such as keeping supervision and appraisal records; using your image, biographical data and videos or pictures of the organisations’ events where you may appear on our website or marketing or fundraising materials to promote the charity.

Some special categories of personal data, such as information about health or medical conditions are processed in order to carry out employment law obligations (such as those in relation to colleagues with disabilities and for health and safety purposes). We may also process other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief for the purposes of equal opportunities monitoring.

When processing criminal records (for example, in order to perform DBS check), the organisation relies on the lawful basis of legitimate interest. When processing special category of data and criminal records, we rely on additional conditions of the Data Protection Act 2018 and related legislation.

How long do we keep your data?

We only keep your data for as long as we need it for, which will be at least for the duration of your employment or contract with us though in some cases we will keep your data for a period of 6 full years after the year in which your employment or contract ended. If you’ve applied for a vacancy but your application hasn’t been successful, we will keep your data only for a maximum of 12 months, unless we have paid you any expenses to attend an interview of a similar role, in which case we may keep the records for 6 full years after the year in which the expenses were paid.

Some data retention periods are set by the law. Retention periods can vary depending on why we need your data. Please get in touch by contacting us using the details above if you want to know more about retention period.

Data is destroyed or deleted in a secure manner soon after the retention date has passed.

Confidentiality – who do we share your data with? :

Personal Data in relation to your earnings is shared with HMRC as part of our legal obligation. Personal Data may be shared with third parties for the following reasons: for the administration of payroll, pension, HR functions (for example the online holiday booking system) and administering any other employee benefits. Data may be accessible to our IT providers.  When sharing information with third parties, we have data sharing, processor agreements or contracts in place to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

Appendix 2 – Members and Volunteers

How we collect information about you? 

We may collect the following information about you when you sign up for a membership with IWA or apply to become a volunteer: name, address, email address, telephone number, date of birth, bank details and health and disability information. We may also collect criminal records information.

If you offer to undertake voluntary work with us, we may collect:

  1. name and contact details of your next of kin
  2. your photograph, your gender, marital status
  3. photographs and footage of the organisation’s events where you may appear
  4. information of any disability or other medical information you have disclosed
  5. information supplied you including a CV, details on your education and employment history, etc
  6. bank account details if we need to pay you for any expenses
  7. information relating to your voluntary work with us (e.g. job title, job description, terms and condition of the activities, any disciplinary and grievance proceedings.
  8. internal and external training undertaken, includes copies of certificates and reports
  9. IT equipment use including telephones and internet access
  10. your opinions and views, as expressed during your work, in e-mails, letters, reports, etc.
  11. copy of your driving licence.

How is your information used? 

We may use your personal information to

  • Provide appropriate services and products;
  • Carry out effective administration and operations;
  • Provide reasonable adjustments;
  • Share volunteering opportunities, projects, updates, and information on our work;
  • Safeguarding;
  • Protect yourself and the general public;
  • Recording the Association’s work for publicity and for historical records;
  • Ensure you are sufficiently trained and competent to undertake certain tasks.

Lawful basis for processing 

If you are registered with us as a member, we rely on ‘contractual obligation’ as our lawful basis for processing your personal data. If you have signed up as a volunteer with us, we rely on legitimate interest for processing your data. When we process special category of data and criminal records, the lawful basis is substantial public interest read with conditions from the Data Protection Legislation.

To process information on any allergies or other medical information, we rely on consent. To ensure provision of reasonable adjustments, we rely on substantial public interest read with support for individuals with a particular disability or medical condition.

How long do we keep your data for? 

We only keep your data for as long as we need it for.  Where any financial transactions have occurred, we will keep your data for a period of 6 full years after the year in which the financial transaction was made.  Otherwise, we will securely destroy your personal data when either you tell us to or when it becomes apparent to us that you no longer wish to receive communications or information from us.

If you have attended a work party or other event where there is a risk of an insurance claim, we may keep your information for up to three full years after the year in which the event took place, of if anyone under the age of 21 was in attendance, until that person attains the age of 21, if that period is longer.

Some data retention periods are set by the law. Retention periods can vary depending on why we need your data. Please get in touch by contacting us using the details above if you want to know more about retention period.

Data is destroyed or deleted in a secure manner soon after the retention date has passed.

Confidentiality, data sharing and safeguarding  

  • We may share your data with subcontractors or suppliers involved in providing support, such as mailing houses. These organisations act as data processors and process such data on our behalf.  Data may be accessible to our IT providers.
  • We may partner with other organisations for example to jointly host events.  On such occasions, where we need to share information we will seek your consent at the time of your application to attend the event.
  • When processing information regarding attendance at any IWA activity, we will rely on legitimate interest.
  • To comply with our duty of care and safeguarding, we may need to pass some information raising safeguarding concern with the authorities. In such circumstances, we apply vital interest and legitimate interest as our lawful basis. Data subjects’ rights and other data protection provisions may be restricted when concerning personal data processed in these circumstances. Exceptions and exemptions are applied on a case-by-case basis.

 

Appendix 3 – Fundraising and Marketing

Information we collect:

When you make a donation or support us

We may collect information provided by you via a form on our website, via telephone calls, letters of forms submitted to us, social media and other sources. The information gathered may include: name, email address, phone number, Gift Aid sign up, donation details, how you heard about the organisation, postal address.

This information allows us to process your donation, and deal with any potential enquiry. We rely on legitimate interest to process this data.  If you agree that we can claim Gift Aid on your donations, we are legally required to keep a record of the claim and your Gift Aid declaration.  If you are donating using a third party, please also refer to the privacy notice published on their website.

When you sign up to attend our events

Information is mainly provided by you via event registration forms or in person during the events by paper forms. The information gathered may include: name, email address, donation/payment details, bank account details, reasons to engage, postal address, email address contact preference, health information.

If you are attending a festival, boat rally or similar event, other information that we collect may include details of your family and pets, boats, caravans, tents or other possessions and accommodation you may be residing in, along with dietary information, next of kin, names of friends you may wish to stay near to, disability and mobility information and your preferences and views.

This information allows us to administer your sign up, process payments, and deal with any potential enquiry. We rely on the legitimate interest to process this data.

During these types of events, we may also take photographs and video recording of people attending where you may be included. This information allows us to showcase our work and have an effective external communication. We rely on our legitimate interest to process this data.  If you are signing up to an event using a third party, please also refer to the privacy notice published on their websites.

For processing information on your family and accommodation, we rely on legitimate interest. To process information on any allergies or other dietary or medical information, we rely on consent. To ensure provision of reasonable adjustments, we rely on substantial public interest read with support for individuals with a particular disability or medical condition.

When you apply for a membership with Club 500

Information is provided by you when you sign up for Club 500 with the Club Application form, such as: name, address, bank/building society details, subscription details. For processing this information, we rely on consent.

When you show interest in supporting us (e.g. through a gift in your will or a pledge) and you decide to contact us

Information is provided mainly by yourself, via online forms or phone and email conversation with us. The information gathered may include: occupation, title, details of any correspondence had with ourselves, date of birth, fundraising appeals responses, event participations with us, details of your reasons to engage with us. This information allows us deal with your enquiry and show you how to get engaged. We rely on our legitimate interest to process this data.

Marketing Communications and Newsletters

Your contact details may be used to provide you with information about our services or our fundraising opportunities via email, text, phone or post. Additionally, you may sign up to our newsletter through our website or through your membership with IWA. We will only send you fundraising and marketing communications by email and text if you have provided your consent, or if you have been involved in a commercial transaction with us. For processing your information to send you our newsletter, we rely on consent. You may opt-out of our fundraising and marketing communications at any time by clicking the unsubscribe link at the end of our e-marketing communication. Alternatively, you can let us know by using any of the contact details listed at the top of this notice.

How long do we keep your data?

We only keep your data for as long as we need it for.  Where any financial transactions have occurred, we will keep your data for a period of 6 full years after the year in which the financial transaction was made.  Otherwise, we will securely destroy your personal data when either you tell us to or when it becomes apparent to us that you no longer wish to receive communications or information from us.

Some data retention periods are set by the law. Retention periods can vary depending on why we need your data. Please get in touch by contacting us using the details above if you want to know more about retention period.

Data is destroyed or deleted in a secure manner soon after the retention date has passed.