General
The Jubilee Sailing Trust wants to protect the privacy of visitors to our website. Please read the following policy; it provides an overview of how we protect your privacy during your visit and it will help you to understand how we use your personal data.
We may change our privacy policy at any time without giving you notice, so please check it each time you visit our website.
About us
The Jubilee Sailing Trust is a registered charity in England and Wales (no. 277810) and Jubilee Sailing Trust (Tenacious) Limited a company registered by guarantee (no. 04019273 England). VAT number GB755104742.
Why JST holds and processes personal data
- To administer its voyages and manage the specific requirements of those who travel on its voyages
- To process donations
- To claim Gift Aid on donations
- To confirm receipt of donations, to thank donors and to provide details of how donations may be or have been used
- To enable JST to maintain a record of beneficiaries’ and supporters’ relationships with the organisation
- For analysis leading to the production of management information relating to income generation and supporter development
- In relation to correspondence entered into with JST by any offline or online channel
- To send JST’s supporters information about the organisation’s work, fundraising activities and appeals where the organisation has obtained consent or is otherwise allowed to, e.g. by claiming legitimate interest based on existing relationships. Please see our Legitimate Interest statement for more information.
- To keep JST’s beneficiaries’ and supporters’ data up to date
- To implement any instructions JST receives from its beneficiaries and supporters with regard to withdrawing consent to send information
Individuals can update or withdraw their consent at any time, for individual channels of communication, or for all channels, by contacting JST on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
All JST’s supporter e-mails contain an Unsubscribe link.
In the event that JST needs to contact or enter into correspondence with supporters regarding administrative issues that do not fall into the GDPR definition of ‘direct marketing’, the use of an e-mail address or telephone number provided by the individual is permissible for the specific purpose of resolving the issue.
What information do we collect and how do we use it?
We collect information from you in two ways; directly through information that you provide to us on various pages and forms on www.jst.org.uk or on paper and secondly indirectly through our website’s technology.
Website
When you log onto our website we register your Internet Protocol (IP) – this enables us to send and receive information to and from you over the internet. We also collect data on visitor patterns by using cookies. Cookies are small files of information which save and retrieve information about your visit to www.jst.org.uk – for example how you entered the site, how you navigated through the site and what information was of interest. The cookies identify you merely as a number, no individual is identified. Cookies do not damage your system; they cannot read data off your hard disk or read cookie files created by other sites. We also analyse this information to determine the most effective parts of our site and where we need to improve it which over time will help us tailor www.jst.org.uk to make it more user friendly and effective. All research is compiled on an aggregated and anonymous basis. (If you are uncomfortable about cookie use, remember that you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser.)
Our website contains links to other websites, but this Privacy Policy applies only to personal data collected via the Jubilee Sailing Trust website. We are not responsible for the privacy practices of other sites. Please be aware when you leave our website, and read the privacy policy of other sites that collect or use personal data.
Personal information
We collect the personal and contact information that you provide when you register with us, book a voyage, make an enquiry, make a donation or purchase goods.
We use your information to fulfil your voyage booking, process payments or donations and to provide you with material that you have requested.
We may also use your personal data to tell you about how we use the donations we receive and other ways you can support us.
We may also use data for other purposes, which we will describe to you at the point we collect the information.
We manage all personal data on a secure server and store it on a secure database, taking appropriate steps to maintain the levels of security required of us by law.
For the purposes of a voyage booking we may also request sensitive personal data about your physical and mental health to ensure that we provide the correct accommodation (for example if you use a wheelchair) and have a crew on each voyage that is balanced between able-bodied and disabled crew members so that we achieve our mission of integration. We may also use this information to better communicate with you using an appropriate format.
Unfortunately, no data transmission over the internet can be guaranteed as 100% secure so where the booking process does include sensitive personal data you may prefer to print off a form and send the completed copy in the post to the Jubilee Sailing Trust head office.
Direct Marketing to beneficiaries and supporters
We claim legitimate interest as per the General Data Protection Regulation (2018) and the Data Protection Act (2018) to contact our beneficiaries and supporters by mail. Please see our legitimate interest statement for more information.
We will not contact you with marketing messages by e-mail, phone or SMS unless you have given us permission to do so.
You can ask us to stop using your personal data for direct marketing purposes at any time by contacting us on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
Individual contacts in business to business marketing and corporate relationships
JST is claiming legitimate interest to keep in touch, using their business addresses, with named individual business to business and corporate partnership contacts with whom the organisation already had a relationship prior to the introduction of the General Data Protection Regulation on 25 May 2018.
For new relationships in these categories created with named individuals after 25 May 2018, consent for future contact is sought and managed in compliance with the General Data Protection Regulation.
To whom might we disclose your personal data?
We may pass your personal information to anyone who needs the information in order to fulfil your voyage booking (for example our doctors) or for the processing of any payment or donation.
Except as set out above, we will not disclose your personal information unless we are obliged to do so or allowed to do so, by law, or where we need to do so in order to run our business (for instance where we outsource services or other people process data for us).
Is my data held securely?
JST ensures there are appropriate controls in place to protect personal details provided to the organisation. Online forms are encrypted and the organisation’s database is held on secure servers.
JST’s database is only accessible by approved staff, contractors and suppliers and paper-based information is stored securely as required by GDPR.
Will we share your information with outside parties?
We never sell or swap personal information and will share it only with people who need it in order to fulfil an event or voyage booking, process a payment or donation, or process data.
Suppliers
We sometimes use external companies to process personal data on our behalf, for example to produce direct marketing materials or help us manage our voyages.
In these circumstances, with reference to GDPR, JST is the Data Controller and these suppliers are Data Processors.
The security practices of supplier companies are checked before JST appoints them and then on a regular basis. We put contracts in place that set out our expectations and requirements, especially regarding how suppliers securely store and process the personal data provided by us.
Third party marketing
We will not, under any circumstances, share personal data with any third party organisations for their use or sell it to them for their own marketing purposes, and individuals will not receive marketing communications from any other companies, charities or other organisations as a result of providing their details.
Legal requests
We will comply with legal requests where disclosure is required or permitted by law and a written request is received, for example, to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime.
What are my legal rights?
Subject access
Individuals have the right to request at any time the information JST holds about them, as subject access requests. Such requests should be submitted by e-mailing privacy@jst.org.uk. Please provide as much information as possible.
Depending on the nature of the request, we may seek a form of identification to verify the identity of the person making it. The information will be supplied within 30 calendar days of the request or the verification, whichever is the later.
Rectification
If individuals believe the information JST holds about them is incorrect or incomplete, they have the right to ask the organisation to correct it. JST must respond within one month of the request being received. Requests can be made by contacting JST on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
Objection
Individuals have the right to ask JST to stop processing their personal data. In this situation, we can continue to store the data to ensure the request can be respected in the future, but all processing must cease, unless there is a legal purpose. Requests can be made by contacting JST on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
Portability
Where they have given consent to us processing their data, individuals have the right to ask JST to provide their personal details to another organisation via commonly used open format such as a CSV file. Requests can be made by contacting JST on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
Erasure
Individuals have a right to have personal data erased and to prevent processing by JST in the following circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
- When the individual withdraws consent
- When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing
- The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
- The personal data has to be erased in order to comply with a legal obligation
- The personal data is processed in relation to the offer of services to a child.
We can refuse to comply with a request for erasure where the personal data is processed for legal reasons or other scenarios that may be in the public interest as specified by the ICO. Erasure requests can be made by contacting JST on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
Compensation
If individuals believe they have suffered damage because JST has behaved in breach of Data Protection law, they are entitled to claim compensation. This right can only be enforced through the courts.
The law allows us to defend a claim for compensation on the basis that the organisation took all reasonable care in the circumstances to avoid the breach, that is, by complying with Data Protection legislation when processing data.
Querying automated decisions
Individuals can ask JST not to make automated decisions based on their personal data; expect to be advised and asked for permission if the organisation plans to use automated processes to make such decisions; and challenge the results of automated decisions they believe them to be inaccurate.
Questions and requests regarding automated decisions can be submitted by contacting JST on +44 (0) 2380 449108 or e-mailing privacy@jst.org.uk.
What if I have some comments or questions about JST’s Privacy Policy?
Any questions about this Privacy Policy should be addressed as follows:
- Write to: Jubilee Sailing Trust, Enterprise House, Ocean Village, Southampton, SO14 3XB
- Email: privacy@jst.org.uk
- Phone: +44 (0) 2380 449108
The UK’s data protection authority is the Information Commissioner’s Office (ICO). The ICO’s website is www.ico.org.uk .The organisation can be contacted at: https://ico.org.uk/global/contact-us/
Changes to JST’s Privacy Policy
This Privacy Policy may be updated from time to time. The latest version will always be available at jst.org.uk. If changes are made to JST’s Privacy Policy in the future, a prominent notice will be posted at jst.org.uk.