Legitimate interest

Introduction

As from 25 May 2018, under the General Data Protection Regulation, WWT Consulting (Wildfowl and Wetlands Trust (Consulting) Ltd) will rely on legitimate interest as per GDPR Article 6(1)(f) for some of its processing of personal data.

This permits the organisation to contact its clients, contacts and collaborators by post. Individuals are free to opt out of postal contact at any time.

Clear information about how individuals can opt out of contact or change their contact preferences is prominent on WWT Consulting’s website and printed materials with a data capture element.

An up to date privacy statement is available on WWT Consulting’s website www.wwtconsulting.co.uk

WWT Consulting is a successful environmental consultancy. We believe that the individuals whose information we hold on our database are fully aware of the nature of their relationship with us and the mutually beneficial reasons for remaining in contact.

Our detailed rationale for claiming legitimate interest is as follows:

The purposes for which we will use individuals’ personal information

  • Sending information regarding the projects we have been working on
  • Sending marketing information regarding the services we offer
  • Sending information regarding potential collaboration opportunities

 
Without these contact opportunities, WWT Consulting’s income generation potential is put at risk, endangering the long term survival of the organisation:

  • We rely heavily on establishing and maintaining good relationships with clients and collaborators to identify projects so require direct communication with them

 
Articles 47 and 48 of the GDPR say that direct marketing activity is a legitimate interest; in particular, in the context of a relevant and appropriate relationship between the organisation (WWT Consulting) and the individual (the recipient), there would be a reasonable expectation that postal details are used for these purposes.

The legitimate interests of third parties

In order to deliver the direct marketing described above, WWT Consulting may provide individuals’ personal contact details to mailing and fulfilment houses, supplied from our own secure database.

We may also occasionally brief suppliers to carry out analysis, sometimes using personal data and at other times anonymised data, to help determine market trends and opportunities around environmental consultancy. This insight enables us to provide the best possible service to our clients.

We make every effort to ensure the data we send to suppliers is secure at every point of transfer and during all the stages of data processing. Our reputable suppliers are required to provide their security protocols on demand. Personal data will always be held securely and is securely deleted by our suppliers as soon as each mailing activity has been completed.

Necessity for the data processing of personal information

WWT Consulting’s business is dependent on mail for delivering information about WWT Consulting’s work and services. Without post-based communication, WWT Consulting’s ability to continue to generate income from project work would be compromised.

Rights and freedoms of the individual

WWT Consulting will do the following with the personal information it holds. None of these activities infringe the rights or freedoms of individuals under the terms of the GDPR:

  • Securely transfer data to third party suppliers for the purposes of producing personalised direct mail materials (see above)
  • Send both generic and personalised content by post – and, where the individual has given explicit permission, by e-mail
  • Retain the individuals’ data for as long as the active relationship lasts with WWT Consulting, for marketing, business analysis and administration purposes
  • Retain the individuals’ data for a period after the relationship has ceased, for the same purposes. This will be for a maximum of 12 years after the last recorded activity by the individual. This period meets WWT Consulting’s statutory obligation to retain information for contracts signed as deeds.
  • We will only record and store personal data with the knowledge of the individual
  • We will not send promotional or marketing information to children
  • We may use external data sources to enhance the personal data we store as permitted by Article 22 of the GDPR
  • We will not use marketing data obtained from a third party without proof of third party consent for mailing having been obtained by the data owner

Nature of personal information held by WWT Consulting and processed in reliance on legitimate interests

  • Title, full name, address, postcode
  • E-mail address
  • Phone number

Primary relationships

The individuals whose details WWT Consulting holds fall into these primary categories. They may be active or lapsed. WWT Consulting claims legitimate interest as outlined above for the purposes of communications, via post, to connect with previous clients for income generation purposes.

Former employees’ and former volunteers’ data will be dealt with according to the requirements of GDPR:

  • Clients
  • Contacts
  • Collaborators
  • Suppliers/contractors

 

Please direct any queries regarding this statement to WWT Consulting.

Email: info@wwtconsulting.co.uk

Phone: 01453 891222