Privacy and CookiesPolicy

Data protection

The World Association of Girl Guides and Girl Scouts (WAGGGS) is a data controller registered with the UK Information Commissioner’s Office (registration number: Z092177).

Keeping your personal information safe is very important to us. We are committed to complying with privacy and data protection laws and being transparent about how we use personal data.

We have policies, procedures and training in place to help our employees and volunteers understand their data protection responsibilities and follow the data protection principles.

We have a nominated member of staff who serves as our Data Protection Lead. If you have any questions regarding our Privacy Policy, please email dataprotection@wagggs.org

This privacy policy relates to our use of any personal information about you.

How we collect personal information

We collect and use personal information about individuals at our member organisations, supporters, employees, job applicants and volunteers for different purposes.

We may collect information about you from different sources, for example:

– From you directly when you:

• Register for one of our programmes, events or meetings
• Participate in a campaign
• Donate to us
• Visit one of our World Centres
• Complete a survey
• Make an online purchase at our shop
• Undertake one of our eLearning courses
• Apply to volunteer with us
• Apply for a grant from us
• Sign up via our website to hear news from us

– From other people who think that you may be interested in supporting WAGGGS
– From the public domain when we think you may be interested in supporting WAGGGS
– From you when you make an application to work for us, or from third parties such as your previous or current employers so we can verify details about you

The personal information that we use

We only collect personal information that we genuinely need.

This may include:

• Contact details such as name address, email address and phone numbers
• Name of your parent or guardian (if you are under 18)
• Nationality
• Date of birth and gender
• Qualifications
• Interests
• Dietary requirements where this is required for catering
• Medical information in some circumstances
• Credit card details and any purchases you have made
• Photographs and video recordings

In respect of job applicants, we may also collect:

• Your bank account details, tax and residency status
• References from previous employers or educational institutions
• Contact details for your family members and next of kin
• Information concerning your health and medical conditions
• Information about your race, ethnicity and sexual orientation
• Details of criminal convictions

Young people

We are committed to safeguarding the welfare of all children and young people involved in our organisation. If you are under 13, we will always ask for consent from a parent or guardian to collect information about you and to continue to contact you. We may also collect the name and contact details of your parent or guardian, where appropriate.

Our legal basis for processing personal information

We may process personal information because it is necessary for the performance of a contract to which you are a party (or to take steps at your request prior to entering a contract). For example, we may process your personal information because you have made a purchase from our online shop or made a room booking at one of our World Centres.

We may collect and use your personal data if it is necessary for our legitimate interest and so long as its use is fair, balanced and does not unduly impact your rights. For example, to send you information about our programmes or if you wish to participate in one of our campaigns.

We may collect and use your personal information with your consent. For example, to send you marketing emails, to take and use your photograph, to collect relevant medical information. You can withdraw consent for this at any time.

We may also collect and use personal information as required to fulfil our legal obligations as a registered charity and employer.

Usually we will only process sensitive personal data if we have your explicit consent. In extreme situations, we may share your personal details with the emergency services if we believe it is in your ‘vital interests’ to do so. For example, if someone is taken ill during one of our events.

How we use personal information

We will only use your personal information for the purpose which it was provided to us for and in ways that you would reasonably expect.

MEMBER ORGANISATIONS

We will use the personal information of some individuals at our member organisation for communication purposes. We will email and post you information about events, courses, our services and other items of interest, as part of your membership. If you would like to opt out or unsubscribe from receiving some of this information, then please contact your relationship manager in the first instance. Our legal basis for using your personal information in this way is for the performance of a contract.

VOLUNTEERS

We will process your personal information if you choose to volunteer with us working directly with girls in your country, supporting adults working with them, fundraise for us, or to be part of a WAGGGS committee or volunteer at one of our World Centres. We will keep a record of your contact details, experience and qualifications. Our legal basis for using your information in this way is for our legitimate interest. It may also be necessary to run Disclosure & Barring Service (DBS) and other checks to identify any activities we need to be aware of; we will seek your consent before doing so.

PROGRAMMES AND EVENTS

If you register for one of our programmes or events, we will use the information you provide to us to process your registration and enable you to attend. This may include sharing some of your information with our member organisations and volunteers that are involved in running an event or programme. Our legal basis for using your personal information in this way is for the performance of a contract.

We may also share your medical information if necessary with the member organisation and volunteers if you choose to provide that to us. If you choose to provide us with your personal data (including, but not limited to, dietary and/or accessibility requirements), we may share them with third parties that we use to provide services at our events. We will collect and use your medical and dietary information with your consent.

CAMPAIGNS

If you choose to participate in one of our campaigns, we will use the information you provide to us as expected for that campaign. Our legal basis for using your personal information for campaigning is for the legitimate interest of WAGGGS and to fulfil our objective to influence people to take decisions that will improve our lives and the lives of others. Any further email communications to you about the campaign will include an unsubscribe function to enable you to inform us that you no longer wish to opt out of that particular campaign.

ADVOCACY

We will collect personal information from you if you choose to participate in one of our advocacy events, such as the United Nations (UN) climate change conference or the UN Commission on the Status of Women. We need this information to organise your involvement. Our legal basis for using your personal information for this purpose, is for the legitimate interest of WAGGGS and to fulfil our advocacy objective of influencing people to take decisions that will improve our lives and the lives of others.

CASE STUDIES

We only use your personal information in case studies when you have consented for us to do so. We will make it clear to you how we might use your information and who we may share it with; again, we will only do so with your permission. Our legal basis for using your personal information in case studies is your consent.

PHOTOGRAPHS AND RECORDINGS

We use photographs and recordings to promote WAGGGS and the work that we do. This might be to advertise our programmes and events, and to support our campaigning and advocacy work. We take photographs and recordings of people attending our programmes and meetings. We also take photographs and recordings of people to agree to be the subject of one of our case studies. We always obtain permission from the individual to take and use their image and explain how we intend to use it. Our legal basis for using personal information for this purpose is consent.

SURVEYS

If you choose to take part in one of our surveys, we will use the personal information that you provide to process the results of the survey and undertake analysis. We will not share the personal information that you provide in a survey with any other organisations. Survey results will be anonymised before being shared or published.

GRANTS

If you apply for one of our grants, we will use your information provided to us to process your application, and if appropriate, administer and manage the grant. Our legal basis for using your personal information for this purpose is to fulfil our legitimate interest as a grant-giving organisation.

LEGACIES

If you kindly make a legacy pledge to us, we will use your personal information to manage your legacy. Our legal basis for using your personal information for this purpose is to fulfil our legitimate interest and fundraising objective. This will include sharing some of your information with solicitors.

DONATIONS

If you kindly donate to us, we will use your personal information to collect your donation and maintain a record of our supporters. Our legal basis for using your personal information for this purpose is to fulfil our legitimate interest and to raise funds for our work.

WORLD CENTRES

If you make a booking to stay as a programme or independent guest at one of our World Centres located in Mexico, Switzerland, India, the United Kingdom and across Africa, we will collect and use your personal information to facilitate your visit. Our legal basis for using your personal information for this purpose is for the performance of a contract.

KEEPING IN TOUCH

If you opt in to our mailing list we will use the information that you provide to email you information about our events, courses, campaigns and other items of interest. You can opt out or unsubscribe from receiving this information at any time if you wish. Our legal basis for using your personal information in this way is your consent.

TRAINING COURSES

If you sign up to one of our e-learning training courses, we will use the information that you provide to us to process your registration and provide the course to you. Our legal basis for using your personal information in this way is for the performance of a contract.

PURCHASES

If you choose to make a purchase from our online shop, we will use your information you provide to fulfil your purchase. Our legal basis for using your personal information for this purpose is for the performance of a contract.

We use WorldPay to process payments.

We will share relevant information with our order fulfilment house to deliver your purchase. We may occasionally also use your contact information to email you information about similar products that you might be interested in. You can choose to unsubscribe from receiving these communications at any time.

EMPLOYEE AND VOLUNTEER RECRUITMENT

If you provide us with information about yourself, such as a resume or curriculum vitae, in connection with a job or volunteer application or enquiry, we may use this information to process your enquiry. We will not store this information for any purpose other than that relating to your application. Our legal basis for using your information in this way is for our legitimate interest.

EMPLOYEE ADMINISTRATION

We will process personal information of our employees to fulfil our contract with them. This includes payroll processing and the provision of training. We are required by law to share some financial information with the HM Revenue & Customs (HMRC). We may also need to share some personal information with other organisations, for example solicitors, pension providers. We process employee personal information to fulfil our contracts with our employees and meet our legal obligations as an employer.

PROCESSING EXPENSES

We will use your personal information including your bank account details to process expense claims. Our legal basis for using your information for this is for the performance of a contract.

GOVERNANCE

We process relevant personal information about existing and potential trustee and committee members for governance purposes, including elections. This might include undertaking DBS and other checks to identify any criminal and other activity we need to be aware of to ensure that we select appropriate trustees and committee members. Our legal basis for this processing is to meet our legal obligations with the Charity Commission and Companies House and other relevant regulatory bodies in other territories.

SAFEGUARDING

When necessary, we process relevant personal information about individuals at our member organisations, volunteers, and employees for safeguarding purposes. This might include undertaking DBS and other checks to identify any criminal and other activity we need to be aware of and casework. It may be necessary to share some personal information with relevant authorities such as the police. Our legal basis for this processing is to meet our legal obligations.

COMPLAINTS

If a complaint is raised with us, we will process the personal information that is provided to us to manage and resolve the complaint. Our legal basis for using personal information for this purpose is legitimate interest.

Cookies and aggregate information

Cookie Statement

General information regarding cookies in this policy is provided in line with guidance from the Information Commissioner’s Office (ICO). Specific information regarding how the World Association of Girl Guides and Girl Scouts (WAGGGS) uses cookies on our website in order to ensure that our site is easy to use is also provided below.

Section A – general information about cookies and how to control them

WHAT ARE COOKIES?

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, e.g. remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.

Cookies can be either ‘first party cookies’ – i.e. the files are placed on your device by the website you are using or ‘third party cookies’. Third party cookies are issued by web services other than the website you are looking at the time, and can allow those web services to track you as you browse from site to site. Facebook and Google do this routinely, as do a number of other advertising networks.

The rules on cookies are covered by the Privacy and Electronic Communications Regulations. The Regulations also cover similar technologies for storing information, e.g. Flash cookies. The Regulations was revised in 2011, and the ICO is responsible for enforcing these rules.

HOW DO THE COOKIE REGULATIONS AFFECT ME?

You will come across information about cookies on our website and you will be given choices about how cookies are used.

Like all organisations that operate websites, WAGGS is responsible for providing clear information about the way in which we use cookies, and ensuring that all users are able to make the right choices, in line with their preferences.

HOW CAN I CONTROL MY COOKIES?

Browser controls: you can use your web browser to:

• delete all cookies
• block all cookies
• allow all cookies
• block third-party cookies
• clear all cookies when you close the browser
• open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the internet without storing local data
• install add-ons and plug-ins to extend browser functionality

Where to find additional information about controlling cookies:

• Internet Explorer cookies information
• Chrome cookies information
• Firefox cookies information
• Safari cookies information
• Opera cookies information

Useful additional sources of information:

• A number of websites provide detailed information on cookies, including org and AllAboutCookies.org
• The Internet Advertising Bureau website, Your Online Choices, allows you to install opt-out cookies across different advertising networks
• Google has developed a browser add-on to allow users to opt-out of Google Analytics across all websites which use this product
• New technologies such as Mozilla’s Do Not Track allow you to tell websites not to track you
• Internet Explorer has a feature called Tracking Protection Lists that allows you to import a list of websites you want to block.

REPORT YOUR COOKIE CONCERNS TO THE INFORMATION COMMISSIONER’S OFFICE

The Information Commissioner’s Office is asking people to report any cookie concerns, in order to help them to find out how organisations are complying with the cookie law. Rather than replying to each person individually, they plan to publish information about numbers and types of concerns reported, and those who have reported concerns know what they are doing about them.

Section B – use of cookies by WAGGGS

At WAGGGS, we ensure that all data collection, processing and storage is in line with the 6 data protection principles of the GDPR. Further information regarding how we ensure that we comply with all the provisions of GDPR and the Data Protection Act 2018 are available in our Data Protection Policy, which is also published on our websites.

The first principle of the GDPR includes a requirement for transparency in the processing of any and all personal data (which includes online identifiers). As explained above, cookies are small files of letters and numbers that are downloaded on to your computer when you visit a website. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The difference between ‘first’ and ‘third’ party cookies is also explained above.

We use the following sorts of cookies on all of our websites in order to make them easy to use:

• 4 cookies used to mark acceptance of cookie notice terms (cn_accepted), used to protect the site from malicious form posting (csrftoken), used to make editing the website consistent (heroku-session-affinity), used to make website editors work consistent (sessionid) – these expire at the end of the session.
• 3 Google Analytics cookies (i.e. _gat Anonymised Analytics, _ga Anonymised Analytics, _gid Anonymised Analytics) which anonymously track how many times pages are requested, how long they are viewed, and how many users are requesting them; Google Analytics is a web analytics service provided by Google, which uses cookies to help us analyse how visitors use the site in the aggregate. The longest these cookies are retained for is 2 years. It does not collect personally identifiable information, and does not track your movements between different websites.
• 2 cookies which are essential to ensure that the website continues to function as it should throughout the ‘session’ (or time that the user spends visiting it), which do not expire.
• 2 further cookies – one of which prevents the cookie notice reappearing once it has been closed by the user, which never expires, and the other of which Google uses to remember user preferences, which expires after 6 months.
• Twitter and Facebook – use the following Twitter: ga, twitter_sess, en_cn, guest_id, personalization_id, rweb_optin, syndication_guest_id. Facebook: fr.

Finally, as outlined above, the use of cookies ensures that the website operates smoothly, and that it is easy for users to navigate. Should you with to set your browser to ‘block all cookies’, the operation of the websites may be compromise

Sharing personal information

We will only share your personal information where we are required to fulfil our contract with you, or legitimate interest, where we have your consent, or we are required to do so by law.

We may share your personal information with third party organisations who will process it on our behalf, for example a mailing house, our website administrator or printers.

We may also share your information with our bank to process a payment; our professional advisers (such as our legal advisers) where it is necessary to obtain their advice; our pension provider; and our IT support and data storage providers.

Where required, we will process personal information to comply with our legal obligations. In this respect we may use your personal data to comply with subject access requests; tax legislation; for the prevention and detection of crime; and to assist the police and other competent authorities with investigations including criminal and safeguarding investigations.

Transferring personal data outside of the European Economic Area (EEA)

We may need to collect or send some personal information outside of the EEA, for example for programmes, events, meetings and World Centre bookings. If we transfer personal information to countries or jurisdictions which do not have a similar standard of data protection law in place, we will inform you in advance of the need to transfer the information.

Your rights

If you no longer wish to receive communications from us, please contact dataprotection@wagggs.org. You can also unsubscribe at any time to emails that we may send to you about our work and that we think will be of interest to you.

You also have the right to:

• Request a copy of the information we hold about you. Requests should be addressed to dataprotection@wagggs.org. We will respond within 30 days of receiving your written request.
• Tell us to change or correct your personal information if it is incomplete or inaccurate. Please contact us at dataprotection@wagggs.org
• Ask us to restrict our processing of your personal data or to delete your personal data if there is no compelling reason for us to continue using or holding this information. Please contact us at dataprotection@wagggs.org
• Receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you, so that you can send it to another organisation. Please contact us at dataprotection@wagggs.org
• Object, on grounds relating to your specific situation, to any of our processing activities where you feel this has a disproportionate impact on you. Please contact us at dataprotection@wagggs.org

Please note that we may be entitled to refuse requests where exceptions apply: for example, if we have reason to believe that the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Privacy Policy.

How long we keep your personal information

We will hold your personal information for as long as is necessary. We will not retain your personal information if it is no longer required. In some circumstances, we may legally be required to retain your personal information, for example for finance, employment or audit purposes.

Changes to this policy

This Privacy Policy may change from time to time. Please visit this webpage periodically to keep up-to-date with the changes in our Privacy Policy.

The Information Commissioner’s Office

If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal information in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.