Our policies

1. Who are we?

Avon Wildlife Trust is one of 46 Wildlife Trusts across the UK.

For over 35 years, we have been saving, protecting and standing up for wildlife and wild places, increasing people’s awareness and understanding of the natural world, and deepening people’s relationship with it.

We are passionate about protecting and restoring our local wildlife and are able to do our work thanks to our community of over 18,000 members and thousands of volunteers. We care for over 1,100 hectares of land across our 30 nature reserves including: ancient bluebell woods, nationally important wetlands, and wildflower meadows. Each year we engage over 7,000 school children with the wonder of nature and inspire them to care about its future. With our award-winning educational and community programmes, we aim to reconnect people with the nature of their doorstep. We also help protect the future of wildlife by working with landowners in the wider countryside, to reduce the decline in wildlife by creating Living Landscapes.

2. Our commitment to your privacy

At Avon Wildlife Trust we respect the privacy of our members, supporters, volunteers and visitors. Below we have outlined our policy concerning how we collect information, what we do with it and what controls you have. If you’d like to read about our Fundraising Promise, please click here.

Firstly we will never sell your personal data. Should you wish to find out more about the information we hold about you, or about our privacy policy, that cannot be found below, please contact us:

• Fundraising Team
• Telephone: 0117 9177270
• Email: mail@avonwildlifetrust.org.uk
• 17 Great George Street, Bristol, BS1 5QT

Our office hours are Monday – Thursday, 8.30am – 5pm and Fridays 8.30am – 4.30pm.

Any references to Avon Wildlife Trust, the Trust, or to ‘we’ or ‘us’ refer to:

• Avon Wildlife Trust. We are a registered charity in England and Wales, and our registered charity number is 280422 and
• Folly Farm Centre Limited, our charitable trading company; (registered company number 06538712). The company is a wholly owned subsidiary of Avon Wildlife Trust, which trades only to raise funds for our charitable organisation.

We use three key definitions to describe people mentioned in this policy. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk)

• ‘Data subject’: this is you, one of our loyal members and supporters. As the data subject, we respect your right to control your data.
• ‘Data controller’: this is us, the Avon Wildlife Trust. With your permission, we determine why and how your personal data is used (as outlined in this policy).
• ‘Data processor’: this is a person, or organisation, who processes your data on our behalf, with your permission. For example, this might be a mailing house who sends your membership magazine to you, on our behalf (due to the size of our organisation, it’s more cost-effective to outsource ad-hoc and large-scale tasks like this).

When we work with other organisations or individuals in this way, we always set up a written contract with them to protect your data. The third parties we work with at no point ‘own’ your data, so you will never hear from them independently and they will always delete your data from their systems when they have completed the task in hand. For example, the Mailing House that prints and posts our magazine for us will only be able to use the data to print the name and address of the recipient onto the envelope. We always send your data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.

3. Why do we collect your personal data?

We use your personal data to keep in touch with you.

We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so.

a) To administer your Avon Wildlife Trust membership

We collect your personal data to administer your membership, which may involve:

• Sending you your membership welcome postcard and welcome pack when you first join us
• Getting in touch with a welcome call or email when you first join us, to express our thanks, to check the data we hold for you is correct and that you have received your welcome pack
• Processing your Direct Debit donation payments, if you have set this process up with us
• Sending your membership magazine
• Sending your invitation to Avon Wildlife Trust’s Annual General Meeting (AGM)
• Sending your membership renewal letter
• Getting in touch should there ever be any issues processing your donation payment
• Getting in touch if mail is returned to us from the address we hold for administering your membership.

b) To send you items purchased from our online shop, including event bookings

We collect your personal data to send you:

• Items you have purchased from our online shop
• Information about events or courses you have booked

The ICO define the lawful basis for processing your data for these purposes as ‘contractual’.

c) To send you information about our work and ask for your opinion

We also collect your personal data so that we can send you information about our work that we feel will be of interest to you. This includes your membership welcome pack, membership magazine, fundraising appeals, events, campaigning opportunities, surveys, services, products, newsletter requests, feedback, competitions and other activities, as well as information about other carefully selected organisations that we work in partnership with (such as Vine House Farm’s bird seed catalogue). From time to time, we may also use your personal data to ask for your opinion about our work.

• Joint and family membership

If you are a ‘joint’ or a ‘family’ member of our Wildlife Trust, we will address communications to all those listed on your membership. If you wish to update this at any point, please let us know.

• Gift membership

If your Wildlife Trust membership was purchased as a gift, we will use the address provided by the purchaser to send you information about our work in the post. This may include a ‘renewal letter’, which we will send you when your membership is due to expire, to see if you would like to continue supporting our charity.

• When your membership has ended

Unless we hear from you directly, or you have already asked us not to, we will continue to communicate with you. For example to send you information about our work, update you on our successes, invite you to events, let you know about our appeals and volunteering opportunities. for up to 12 months after your membership has ended. This is just in case your support was cancelled accidentally, by for example changing your bank account details, and you wish to update your details with us.

Your personal data also helps us to get to know you better and to develop a ‘profile’ of you on our secure supporter database. This enables us to send you the information listed above in a timely and relevant way, to suit you. For example, keeping track of the donations you make to our organisation helps us to send you information about fundraising appeals that we feel you would like to hear about. Likewise, keeping a record of your wildlife interests that you may tell us about in one of our Membership Surveys, helps us to send you relevant project updates or event invitations.

As defined by the ICO, we use three different lawful bases for processing your data for ‘direct marketing’ purposes:

i) Legitimate interest

This is where we have identified a genuine and legitimate reason for contacting you, which crucially does not override your rights or interests

We use legitimate interest to send you the information listed above by post or telephone (if you are not registered with the Telephone Preference Service, and you have given us your telephone number).

ii) Opt-in consent

This is where you have given us express permission to contact you by particular communication channels.

We use opt-in consent to send you the information listed above by email, text message (SMS) or telephone (if you are registered with the Telephone Preference Service)

From May 2018 the new General Data Protection Regulation will come into force. We will continue to communicate with existing members and supporters via post, and have asked people to let us know if they would like to hear from us about events, volunteering and fundraising through email and/or telephone. This will give our members and supporters more of a choice of the messages that you receive, and how you will receive them.

You can opt-out of communications or change how we keep in touch at any time. If you wish to do so complete our update form here, or contact us using the below details.

• mail@avonwildlifetrust.org.uk
• Avon Wildlife Trust, 17 Great George Street, Bristol, BS1 5QT
• 0117 9177270

We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed as outlined above.

d) To enable you to volunteer with us

If you are an Avon Wildlife Trust volunteer, we collect your personal data so that we can keep in touch with you about, for example:

• Changes to planned volunteer work programmes that you may be taking part in
• The positive impact you have on our work, by sending you our volunteer newsletter
• Dedicated volunteer thank-you events.

4. What kind of personal data do we collect? How do we collect it?

a) Basic information

We will usually collect basic information about you, including your name, postal address, telephone number, email address and your bank account details if you are supporting us financially/making a regular donation. We do not store credit or debit card details.

Most of the time, we collect this data from you directly. Sometimes this is in person; other times, it is over the telephone, in writing or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (only where you have given permission for such information to be shared), please see below for more information.

b) Getting to know you better

We also collect information about you that helps us to get to know you better. This may include:

• your preferences of how you would like us to contact you
• ways you’ve helped us through volunteering your time
• records of donations you’ve made towards fundraising appeals (unless you have specifically asked to remain anonymous)
• information about your wildlife interests, which you tell us through our Membership Surveys
• records of events you’ve attended, or campaigns or activities that you’ve been involved in

Sometimes we will collect other information about you such as your date of birth and gender. When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission.

Once again, most of the time we collect this data from you directly. Occasionally we also obtain data from external sources. For example, we may check against Royal Mail’s National Change of Address database to ensure that the address we have listed for you is up to date. We know moving to a new house can be a busy time and appreciate that you don’t always have the chance to send us your new address. By undertaking this exercise, we can update your record without you needing to get in touch. If you do not wish for us to do so, please get in touch using the contact information at the top of the page.

Occasionally, we may collect information about certain supporters (e.g. particularly well known or influential people) from public sources such as such as Companies House, news or other media. We may also collect some demographic data generated through geodemographic hooks such as CACI Acorn. We don’t do this to everyone, and this is the exception rather than the rule.

• Fundraising Team
• Telephone: 0117 9177270
• Email: mail@avonwildlifetrust.org.uk
• 17 Great George Street, Bristol, BS1 5QT

Our office hours are Monday – Thursday, 8.30am – 5pm and Fridays 8.30am – 4.30pm.

Other ways in which we collect personal data to get to know you better include:

        i) Our website

Our website uses ‘cookies’ to help provide you with the best experience we can. Cookies are small text files that are placed on your computer, tablet, mobile phone or other mobile device when you browse websites.

Our cookies help us:

• Make sure our website works 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

For more information on our Cookies Policy, please see below.

c) Sensitive personal data

We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and members. However, there are some situations where this will occur.

When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission. In these situations, we collect the data from you directly.

If you are a volunteer then we may collect extra information about you, for example:

• References
• Criminal records checks
• Details of emergency contacts
• Medical conditions

We may also collect sensitive personal data if you have an accident on one of our reserves. This information will be retained for legal reasons, for safeguarding purposes and to protect us (including in the event of an insurance or legal claim). If this does occur, we’ll take extra care to ensure your privacy rights are protected.

d) Children and young people

In line with data protection law, we will not collect, store or process your personal details if you are under 13 years of age; unless we have the express permission from your parent or guardian to do so.

If we have the permission of your parent or guardian, and you are a Wildlife Watch member, we will capture your date of birth at the point of joining. This is so that we can send you information that we feel is suitable to your age.

For further information, please see our Safeguarding Policy Statement.

5. How do we store your data?

a) Security

All of the personal data we process is processed by our staff in the UK. However, for the purposes of IT hosting and maintenance your information may be situated outside of the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

b) Payment security

All electronic Avon Wildlife Trust forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.

If you use a credit card to donate, make a membership donation or purchase something online we will pass your credit card details securely to our payment providers (Stripe or WorldPay). Other payment methods (e.g. PayPal, ApplePay, Rapidata etc) are handled in a similar manner.

Avon Wildlife Trust complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details.

Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.

c) CCTV

Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and Avon Wildlife Trust. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review CCTV will be recorded over.

Avon Wildlife Trust complies with the Information Commissioner’s Office CCTV Code of Practice, and we put up notices, so you know when CCTV is in use.

d) Data retention policy

We will only use and store information for as long as it required for the purposes it was collected for. We continually review what information we hold, and delete what is no longer required.

We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).

We continually review what information we hold and delete what is no longer required. We never store payment card information.

6. Your rights

We respect your right to control your data. Your rights include:

a) The right to be informed
This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this policy, please contact us.

b) The right of access
If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request

https://ico.org.uk/your-data-matters/your-right-of-access/ we will respond within one month.

c) The right to rectification
If we have captured information about you that is inaccurate or incomplete, we will update it.

d) The right to erase
You can ask us to remove or randomise your personal details from our records.

e) The right to restrict processing
You can ask us to stop using your personal data.

f) The right to data portability
You can ask to obtain your personal data from us for your own purposes.

g) The right to object
You can ask to be excluded from marketing activity.

h) Rights in relation to automated decision making and profiling
We respect your right not to be subject to a decision that is based on automated processing.

For more information on your individual rights, please see the Information Commissioner’s Office.

7. Making a complaint

Avon Wildlife Trust want to exceed your expectation in everything we do. However, we know that there may be times when we do not meet our own high standards. When this happens, we want to hear about it, in order to deal with the situation as quickly as possible and put measures in place to stop it happening again.

We take complaints very seriously and we treat them as an opportunity to develop our approach. This is why we are always very grateful to hear from people who are willing to take the time to help us improve.

Our policy is:

• To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.
• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
• To make sure everyone in our organisation knows what to do if a complaint is received.
• To make sure all complaints are investigated fairly and in a timely way.
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
• To learn from complaints and feedback to help us to improve what we do.

Confidentiality
All complaint information will be handled sensitively, in line with relevant data protection requirements.

Responsibility
Overall responsibility for this policy and its implementation lies with Jane Davis, Director of Finance & Resources.

For further information on how to make a complaint, please click here.

Information Commissioner’s Office
For further assistance with complaints regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.

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

Telephone: 0303 123 1113
Email: casework@ico.org.uk

8. Leaving our website

We are not responsible for the privacy practices or the content of any other websites linked to our website. If you have followed a link from our website to another website you may be supplying information to a third party.

9. Get in touch

Should you wish to find out more about the information we hold about you, or about our privacy policy, please contact us:

• Fundraising Team
• Telephone: 0117 9177270
• Email: mail@avonwildlifetrust.org.uk
• 17 Great George Street, Bristol, BS2 5QT

Our office hours are Monday – Thursday, 8.30am – 5pm and Fridays 8.30am – 4.30pm.

We update this policy periodically.

Last updated: 18 May 2018

Cookies policy

First party cookies

This site uses cookies in several places – we’ve listed each of them below with more details about why we use them and how long they will last.

Cookies set by this website

Name	Purpose	Typical content	Expires
SESSxxxID	Authentication session to prevent having to login multiple times in one browser session. This is only set if you authenticate via the site. This may happen if you purchase items from the shop or make use of our commenting	A unique id that ties the current session to a database settings table	One week
has_js	This helps the website understand browser Javascript functionality	An on/off flag that denotes whether or not the browser supports Javascript	On site exit
Online forms	NO_CACHE	This cookie is essential for our webforms to operate. It is set only for those people using the form, and prevents the browser from storing the information you enter.This cookie is deleted when you close your browser.	NA
Cookie_agreed	This cookie collects information about whether or not the user has agreed to cookies.	Yes/No	100 days

 

Third party cookies

We use a number of suppliers who may also set cookies on their websites’ on its behalf. This site does not control the dissemination of these cookies. You should check the third party websites for more information about these.

Provider	Name	Purpose	More info
Google Analytics	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.	Google Privacy policy
Add this	_atuvc xtc uid uvc uit psc	These cookies are created by the AddThis social sharing site. AddThis does collect some information such as which web page you came from, which type of browser you are using, and your general geographic location. If you use the AddThis tool to share content they aggregate data about what pages are shared, when, and how. They also assign your web browser a unique identifier. This ID doesn't, and can't, say anything about you, it's a random series of numbers and letters used to distinguish users from each other.	Add this Privacy Quick Summary Add This Privacy Policy Add This Data Collection Opt-Out
FontDeck		Fontdeck sets a single session cookie for each font requested. Each cookie contains (nothing but) a random string used solely as part of our caching and font security measures. The cookies are removed as soon the browser is closed (or the session otherwise ends). They contain no personal information and are not used for gathering analytics or tracking at a personal or aggregate level. Their sole purpose is to check whether we should serve the webfont from cache or not.	FontDeck Privacy Policy
Wufoo	wildlifetrusts40	This is a session ID cookie used identify unique visitors completing forms on our site. If you have your browser set to reject cookies the forms may not work correctly.	Wufoo Privacy Policy

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

YouTube cookies

We embed videos from YouTube. This may set cookies on your computer, particularly if you are logged into a Google or YouTube account. To find out more, please visit YouTube’s embedding videos information page.

Last reviewed: 18 May 2018

Avon Wildlife Trust and its subsidiaries acknowledge their duty of care to safeguard and promote the welfare of children and adults at risk and is committed to ensuring its safeguarding practices reflects statutory responsibilities; government guidance and best practice within the Royal Society of Wildlife Trusts.

The policy recognises that the welfare and interests of children, young people and adults at risk are paramount in all circumstances. It aims to ensure that regardless of age, gender, religion or beliefs, ethnicity, disability, sexual orientation or socioeconomic background, all children, young people and adults at risk: -

• have a positive and enjoyable experience during participation in our activities, events, learning and engagement with nature and wildlife, in a safe, person-centred environment.
• are protected from abuse whilst participating in the activities, events, learning and engagement opportunities provided by Avon Wildlife Trust and its subsidiaries.

Avon Wildlife Trust acknowledges that some children, young people and vulnerable adults, including those with disabilities, can be at risk of neglect, abuse or exploitation and we accept the responsibility to take reasonable and appropriate steps to ensure their welfare should staff suspect or have any concerns they are victims or potentially ‘at risk’.

As part of our Safeguarding policy, Avon Wildlife Trust will: -
• promote and prioritise the safety and wellbeing of children, young people and adults at risk;
• ensure all staff understand their roles and responsibilities in respect of safeguarding and is provided with appropriate training opportunities to recognise, identify and respond to signs of abuse, neglect and other safeguarding concerns relating to children, young people and adults at risk;
• ensure appropriate action is taken in the event of incidents/concerns of abuse and support provided to the internal Nominated Safeguarding Officer, who raise or disclose the concern
• ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
• prevent the employment/deployment of unsuitable individuals through robust selection and recruitment processes and appropriate level of government Disclosure & Barring checks;
• ensure robust safeguarding arrangements and procedures are in operation and regularly reviewed.
• implement an online safeguarding policy.
• regularly review its policies and procedures, including its ‘Code of Conduct’.
• ensure staff are trained in safeguarding, with regular updates/reviews

The policy and procedures will be widely promoted and are mandatory for everyone involved in the events, activities, learning and engagement opportunities provided by Avon Wildlife Trust and its subsidiaries and will be kept under biennial review or in the following circumstances: -

• changes in legislation; government and/or Royal Society of Wildlife Trusts’ guidance
• as required by the Local Safeguarding Children Board (or Safeguarding Adults’ Board)
• due to any other significant change or event.

Ian Barrett - Chief Executive Officer

Text size

The website has been written to allow you to easily change the text size to make it either larger or smaller via your browser settings. Some browsers will allow you to magnify the whole page. To change the text size, follow the instructions below:

Internet Explorer

• Click “View” to open the View menu or press “Alt” and “V”
• Select the “Text Size” option or select by pressing “X”
• Choose your preferred text size using your mouse or use the up and down arrow keys
• Click to select the text size or press “Enter”
• The text size should change to reflect your choice

Firefox

• Click “View” to open the View menu
• Select the “Text Size” option
• Select “Increase” or “Decrease”
• The text on our site should change to reflect your choice

Safari

• Click “View” to open the View menu
• Click on “Make Text Bigger” or “Make Text Smaller” or to use the keyboard shortcuts select
• “Apple” and “+” (plus) or “Apple” and “-” (minus)
• The text size on our site should change to reflect your choice
• If your mouse has a scrolling wheel in the middle of the right and left click buttons, you can hold down the “Ctrl” key on the keyboard and scroll it up and down, the text size will increase and decrease. This works in both Internet Explorer and Firefox

Accessibility in Windows

Windows also has a number of computer settings you can select to make your enjoyment of our website better. Go to Start > Settings > Control Panel > Accessibility Options. You can select options to alter your keyboard, display and mouse settings.

Code

Our website has been developed to best practice coding conventions corresponding with the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI) Web Content Accessibility Guidelines 1.0 (WCAG 1.0) guidelines.

The website templates have been successfully validated to XHTML 1.0 strict.

JavaScript

Where JavaScript is used, we have provided a working alternative for visitors who have JavaScript turned off.

We are committed to delivering a high standard of service to anyone who engages with our work

 

How to make a complaint

We are keen to hear from anyone who believes we have fallen short of the high standards we set ourselves. Please provide your feedback by clicking on the relevant link below. Alternatively you can call us on 0117 917 7270 or write to us at the following address: Avon Wildlife Trust. 17 Great George Street, Bristol BS1 5QT.

We aim get back to you about your feedback within 10 working days of receiving it. Whilst we expect to be able to resolve most complaints within that timeframe, if we need to conduct a more in-depth investigation, we will aim to provide you with a full response within 20 working days. If we are unable to meet that deadline due to exceptional circumstances, we will of course let you know. 

If you are not happy with the response you receive, you can escalate your concerns to Jane Davis our designated complaints co-ordinator, who will consider the matter in more detail.

How to make a complaint about our fundraising

 

Stage 1: Avon Wildlife Trust tries to resolve the complaint

Any complaints can be raised with Avon Wildlife Trust or The Fundraising Regulator. Please click here to complete our complaints form so that we are able to help you in the best way suited to your complaint.

Make a complaint

Submit the complaint with Avon Wildlife Trust using our online form by clicking here (or in writing by post, by email, or by phone) within three months of the incident occurring. We will provide you with a copy of the Avon Wildlife Trust complaints procedure and the Fundraising Promise within 14 days.

Complaint is made

We will acknowledge the complaint in writing within 14 days.

Record the complaint

Avon Wildlife Trust will keep a record of the complaint for at least 24 months from the date the complaint was made and will make the record available for inspection by the Fundraising Regulator if required.

When the investigation is completed

We will tell you of the outcome of the investigation in writing within 28 days of acknowledgement of receipt of the complaint.

If the outcome is not seen as satisfactory

You can escalate the complaint by raising you concerns with The Fundraising Regulator within two months of receiving Avon Wildlife Trust's final response.

Stage 2: The Fundraising Regulator tries to resolve the complaint

If the complaint is not satisfactorily resolved, then it can be passed to the Fundraising Regulator. They will investigate the complaint and work with Avon Wildlife Trust and yourself to try to resolve the problem.

Once the Fundraising Regulator has received the complaint, they will contact us to inform us of the complaint and to gather information from us regarding the issue. Avon Wildlife Trust will provide the Fundraising Regulator with any fundraising materials as necessary and will cooperate fully and comply with any remedy proposed by the Fundraising Regulator.

The Regulator will investigate the complaint and try to resolve it with all parties concerned within 30 days.

Stage 3: The Fundraising Regulator upholds or rejects a complaint

If you are still not satisfied with the outcome you can ask the Fundraising Regulator to adjudicate. The Fundraising Regulator will review the complaint and report their conclusion within 60 days. The Regulator has the discretion to specify that either no further action is appropriate or to censure Avon Wildlife Trust and prescribe one or more sanctions. The Fundraising Regulator will try to pursue the case to a satisfactory conclusion for both parties.

Introduction

Our fundraising activities contact members of the public and individual supporters through a variety of communication channels, including in person, mail, email, social media, text and telephone.

As a charity we protect the dignity of vulnerable people who choose to donate or raise funds for Avon Wildlife Trust.

Fundraising should be a positive experience for our supporters.  It is inevitable though that through our fundraising activities we will come into contact with people who are vulnerable and some of these may not be able to make informed decisions about their giving.  This can happen either through our own communications or through the agencies who work on our behalf.

This document outlines how, in undertaking fundraising activities, we protect vulnerable people, how these people can be identified and what action to take if we suspect someone is vulnerable.

Our guiding principles

We are members of the Fundraising Regulator and the Institute of Fundraising and this is what we promise our supporters:

• We will always be respectful.  This means being mindful of and sensitive to any particular need that a donor may have. It also means striving to respect the wishes and preferences of the donor.
• We will treat our donors fairly. This includes not discriminating against any group or individual based on their appearance or health conditions.
• We will respond appropriately to the individual needs of our donors.  Our fundraisers will adapt their tone, language and communication technique to suit the needs and requirements of the donor.
• We will always respect people’s privacy and encourage supporters to let us know how they want to be contacted.
• We also ensure it is easy for supporters to opt-out of receiving future communications if they wish.
• We comply with data protection law.  We will always protect personal data; we will not sell personal details to any other organisation.
• We will ensure that fundraisers, volunteers and fundraising contractors working with us to raise funds, comply with the fundraising code of practice and these principles.
• We will not put undue pressure on individuals to make a gift.
• We are clear in our communications about who we are, what we do and how donations will be used.
• We have a supporter care team who are dedicated to looking after our supporters.
• We will be open and honest.  We tell the truth, do not exaggerate and we answer all reasonable questions about our fundraising activities and costs.
• We are accountable for our fundraising activities.  We have a complaints procedure, a copy of which is available on our website or available on request.  If we cannot resolve a complaint, we accept the authority of the Fundraising Regulator to make a final adjudication.

The Fundraising Regulator Code of Fundraising Practice

We always abide by the Fundraising Regulator’s code of fundraising practice.  The general principles state:

• Fundraisers MUST take all reasonable steps to treat a donor fairly, enabling them to make an informed decision about any donation. This MUST include taking into account the needs of any potential donor who may be in a vulnerable circumstance or require additional care and support to make an informed decision.
• Fundraisers MUST NOT exploit the credulity, lack of knowledge, apparent need for care and support or vulnerable circumstance of any donor at any point in time.
• If a fundraiser knows or has reasonable grounds for believing that an individual lacks capacity to make a decision to donate, a donation MUST NOT be taken.
• A donation given by someone who lacked capacity at the time of donating MUST be returned.

Face-to-face fundraising

Our face-to-face fundraising activities follow the standards of the Fundraising Regulator’s street fundraising rule book, which contains recommendations on how fundraisers must protect vulnerable people and members of the public from behaviour which is an unreasonable intrusion on a person’s privacy, is unreasonably persistent and which places undue pressure on a person to give money.

The rule book also stipulates that fundraisers MUST NOT sign up any person at any time who they may have reasonable grounds for believing, in the course of their engagement with the individual, that they are in vulnerable circumstances which mean they are unable to make an informed decision to donate. These may include, but are not limited to:

• physical and mental medical conditions
• disability
• learning difficulties
• times of stress or anxiety (e.g. bereavement, redundancy)
• financial vulnerability (where a gift from a donor may impact on their ability to sufficiently care for themselves or leave them in financial hardship)
• Proficiency in English
• Influence of alcohol or drugs
• Fundraisers must not sign up any person under 18 years of age.

Fundraising agencies

We have agreements in place with third party fundraising agencies (such as South West Wildlife Fundraising Limited and Quality Telephone Services) who fundraise on behalf of Avon Wildlife Trust to ensure adherence to the Code of Fundraising Practice and the Charities Act 2016.  These agreements stipulate conformity with the law and best fundraising practices and include requirements to protect vulnerable people.

These agreements also stipulate the reporting of any complaints made by the public relating to the fundraising activities.

Vulnerability

By vulnerable people we mean those whose circumstances put them at enhanced risk of being vulnerable to neglect or abuse and so might be lacking the ability to make a decision.*  There are a number of factors which can contribute to vulnerability and may indicate whether someone may be incapable of making a decision.  These include*:

• A particularly frail person
• An individual with a mental disorder, including dementia or a personality disorder
• Someone with a significant and impairing physical or sensory disability
• An individual with a learning disability
• Someone with a severe physical illness
• A homeless person

In addition, for fundraising activities, we define an individual as vulnerable in the case of the following factors:

• An individual who is experiencing financial vulnerability
• An individual with a severely reduced understanding of English

Where an individual is considered vulnerable we will flag their record on our database as ‘Do not contact’ and they will never be contacted again.

With face-to-face fundraising, if a fundraiser comes across someone who they feel might be vulnerable, they will not ask them to donate to Avon Wildlife Trust.

* British Medical Association – Safeguarding Vulnerable Adults.

Identifying a vulnerable contact

There are several indicators which can help to identify vulnerable adults by different communication channels.

Communicating by telephone or face to face

Indicators that a person may have a mental health issue, such as dementia:

• Asking irrelevant and unrelated questions
• Responding in an irrational way to simple questions
• Asking for questions or information to be repeated
• Taking a long time to respond or finding it difficult to respond
• Repeating questions they have asked
• Wandering off the subject
• Displaying signs of forgetfulness

Indicators of physical difficulties:

• Unable to hear or understand what is being said
• Unable to read and understand the information provided to them
• Displaying signs of ill health e.g. breathlessness or discontent

Written communications

We can at times identify vulnerable adults through written communications:

• A supporter who has emailed or written to us to tell us they are vulnerable
• The supporter’s family member or carer has indicated that they are vulnerable
• Someone whose handwriting is particularly shaky and hard to read.  This is an indicator that the supporter is frail and to be cautious, we mark them as ‘do not contact’

Family members / carers

If we are alerted to a supporter being vulnerable by a family member or carer we will ask what kind of communication, if any, is acceptable.  Our database is then updated to reflect their wishes.

Fundraising training

All Avon Wildlife Trust staff and volunteers involved in fundraising should receive a copy of this policy and should sign to show that they understand its content and agree to adhere to its stipulations.  The Fundraising, Membership and Communications team will be trained by the Director of Fundraising & Marketing at team meetings. Any new fundraising staff and volunteers should receive training as part of their induction.

Is age an indicator of vulnerability?

No.  Age does not indicate whether a person is vulnerable or not.  There are many older people who are active and leading comfortable lifestyles.  So we cannot make a judgement based on age.  Equally a much younger supporter could be in a vulnerable position.  Vulnerability should be assessed on the person’s circumstances.

If someone is identified as being under the age of 18, then in a face-to-face situation, any fundraising discussions should stop and no donation should be taken.   If we have personal data on our database of someone who we discover is under 18, we must remove them from all fundraising appeals and calls.

Responding to the needs of a vulnerable contact

Be patient and do not rush the conversation.  It’s better to have a longer call or conversation than to cut this short and leave the supporter confused or agitated in any way.

Ask if the individual would prefer another method of communication, e.g. offer to have some information sent in the post, or via email, so they have time to take in the information.

Ask if they need to speak with anyone else before making a decision.

Check their understanding of what they have agreed to, e.g. ask them to repeat back what they have agreed to.

All of the above will help to make sure that the individual comes first and give them time to make an informed decision, if they are capable of doing this.  If it becomes apparent that the person lacks capacity to make a decision then all fundraising must stop.

Further information

Fundraising Team
• Telephone: 0117 9177270
• Email: mail@avonwildlifetrust.org.uk
• 17 Great George Street, Bristol, BS1 5QT