- Who are we?
- What we do
- Data protection
- Lawful processing
- What are PDSA's legitimate interests?
- Data collected
- Wealth screening & financial profiling
- Do we process sensitive personal information?
- Your credit or debit card information
- Where does the information come from?
- Data retention
- Data sharing
- Data protection rights
- Marketing preference
- Facebook marketing
- Collection of data through 'cookies'
- What to do if you're not happy
PDSA is the UK’s leading veterinary charity. Operating through a UK-wide network of 48 PDSA Pet Hospitals, in addition to the support of a number of private veterinary practices. PDSA provides free and paid-for veterinary care to the sick and injured pets of people in need and promotes responsible pet ownership.
PDSA (Registered Charity 208217/ SC037585) also operates two wholly owned trading subsidiaries, PDSA Trading Ltd (Registered Company Number 01595637), and PDSA PetAid Enterprises (Registered Company Number 04374375). These trading arms support the efficient fundraising and income-generation activities of the charity.
Please read this policy carefully, along with our Terms and Conditions and any other documents referred to in this policy, to understand how we collect, use and store your personal information.
The Data Protection Officer
Our Data Protection Officer is Shaun Williams
PDSA has been a lifeline for sick and injured pets since 1917. In that time, we’ve provided 100 million treatments to more than 20 million pets. Saving, protecting and healing pets is what we’re all about. We are dedicated to improving pet wellbeing in three very special ways – by educating owners, preventing disease and carrying out life-saving operations
The objects of the charity are:
(a) The provision of free medical or surgical treatment, or such treatment at reduced charges, to animals belonging to persons who are unable to afford the services of a veterinary surgeon
(b) The prevention of suffering of animals by the provision of preventive treatment, care and advice (whether at free, at a reduced charge, or at full charge)
(c) The education of the public in matters concerning animal health and welfare in general
(d) The advancement of animal welfare for the public benefit by any other means
PDSA takes data protection very seriously.
As you browse our website, get in touch with us, or use our services we collect information. This deepens our understanding of what you are interested in, and helps us to improve the efficiency of our veterinary services and fundraising communications.
PDSA and our trading subsidiaries will never exchange or sell your information to another organisation for their own marketing purposes. We know that this is important to you, and want to reassure you that you’re always in control of how we use your personal information in regards to marketing and fundraising activities.
We do however need to collect and use your personal information for carefully considered and legitimate business purposes, which help ensure we can run PDSA efficiently, raise funds effectively and deliver our charitable veterinary services. This policy sets out how your personal data will be used, what data we collect, our legal basis for its use, along with outlining your rights in respect of personal data.
In simple terms, your personal information may be used to help us effectively deliver our charitable veterinary services or to help us raise funds for those charitable services.
We always strive to provide a clear, honest and transparent approach regarding how and when we may collect and use your personal data. The overview below summarises the different reasons why we do this. We may not use your personal information for all of these purposes – it will depend on the nature of our relationship with you, and how you interact with our services, websites, and fundraising activities.
Examples of common activites
|1. Delivery of charitable veterinary services||Delivery of our core veterinary services will require the recording of clients’ contact details, their eligibility for our charitable services, records of pets, treatments, financial transactions, and communications. We may also use your personal information to promote other pet welfare services such as paid-for veterinary services including preventive procedures, or veterinary products. We may also need to use your personal information for the prevention of fraud, to identify any misuse of our services, or for debt recovery.|
|2. Fundraising and Marketing||Like all major charities, we have a range of fundraising and marketing activities that are designed to raise income or promote the aims and objectives of the charity. We use a range of marketing activities and channels such as direct marketing and face-to-face activity, advertising (print, broadcast and digital) and public relations for marketing, fundraising, and income generation. This may include talking to you about appeals, competitions, commercial trading activities, pet insurance, animal welfare issues, sponsorships, events or volunteering opportunities. We may also ask if you are able to Gift Aid any of your donations.|
|3. Management of Volunteers||If you are one of our fantastic volunteers, we need to use your personal information to manage your volunteering activity, deliver training, involve and update you on our projects and campaigns and to ensure your safety. This may include sending you newsletters or information about our fundraising activities so you can advise the public about our work.|
|4. Retail trading and catalogue sales||For the purpose of commercial income generation PDSA operates a network of charity shops, an e-bay store, and a range of traditional gift catalogues. PDSA Trading Ltd operates an e-commerce website. If you interact with these services, we may use your personal information for the marketing of similar offers, products, or services. PDSA, PDSA Trading Ltd, or our technical partners may also use your personal information for protection against fraud and recovery of Gift Aid on any donations.|
|5. Financial and Insurance services||PDSA offers a range of pet insurance policies that can be accessed via the PDSA website, insurance aggregators, and price comparison websites. We will use your personal information to administer your pet insurance quotes and policies, remind you when it is time to renew, in addition to sending you occasional information about our charitable work and fundraising.|
|6. Analysis, Targeting, and segmentation||In order to fund our vital work helping sick and injured pets, we have to communicate our aims and objectives and ask people for financial support. Efficiency is very important to us, as we value every single donation. Therefore, we only want to send communications that are genuinely interesting and relevant to you. Before we contact you we will make use of information you have given us, your interactions with our services, and some publicly available information to help us predict your interests, tailor and personalise our communications. PDSA uses the Mosaic postcode-based segmentation tool from Experian Ltd to help us understand the demographic make-up of geographical areas. This is used for charity shop location planning, event planning, and to allow us to tailor our communications geographically. This activity does not identify individual supporters but can be useful for deciding what postcodes receive which messages to ensure they are relevant to you.|
|7. Wealth screening & financial profiling||We may carry out research using publically available information to determine whether an individual could be a potential major donor, high net worth individual, or philanthropist that shares our passion for animal welfare or the relief of poverty. This research will help us target communications in a more focused, efficient and cost effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. Donors can ‘opt out’ of this research process at any time.|
|8. Staff administration||PDSA is one of the UK’s largest employers of veterinary surgeons and veterinary nurses in the UK. In order to fund and deliver our charitable veterinary service we employ a range of professional, technical, and support staff. We process the personal information of our employees for recruitment, staff administration, remuneration, pensions, and performance management purposes.|
PDSA needs a lawful basis to collect and use your personal data. The law allows for six legitimate ways to process people’s personal data. Only three of these are relevant to charities for the types of purposes listed above.
• Information is processed on the basis of a person’s consent
• Information is processed on the basis of a contractual relationship
• Information is processed on the basis of the “legitimate Interests” of PDSA
In extreme situations, we may share your personal details with the emergency services if our employees believe it is in your ‘vital interests’ to do so. For example, this would apply when someone is taken ill at one of our Pet Hospitals. We may also share your personal information where we are compelled by law to do so.
PDSA will ask for your consent to send you marketing and fundraising emails, and text messages. If you register as a PDSA volunteer it can be very helpful if you share information on any medical conditions that may affect your ability to perform your voluntary role. This is, of course, voluntary and we will ask for your consent. You can withdraw consent for these channels and activities at any time by contacting our friendly supporter services team.
The vast majority of our relationships with supporters and clients are voluntary and not contractual. If you have purchased a pet insurance product then you need to consider the terms and conditions of your policy, as this is a contractual relationship.
PDSA’s e-commerce website https://www.pdsapetstore.org.uk/ is operated and managed by PDSA Trading Ltd (Registration No 01595637) who use Shopify a recognised e-commerce platform to take and process your orders.
For data protection purposes Shopify are a Data Processor and will not use your personal details for their own marketing purposes. However, to help protect our customers Shopify does monitor credit card activity for risk and fraud screening. Shopify might automatically block a payment card number or IP address after a certain number of unsuccessful payment attempts in an effort to reduce fraud. For more information please refer to our e-commerce terms and conditions of service.
The law allows personal data to be legally collected and used if it is necessary for a legitimate business interest of the organisation - as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned.
There are times when it is just not practical to ask a person for consent. In many situations, the best approach for PDSA and our supporters, clients, and volunteers is to process personal data because of our legitimate interests, rather than consent. If you want to change our use of your personal data for marketing and fundraising activities, you can do so at any time by contacting our friendly supporter services team.
• Delivery of our charitable purpose as set out in the PDSA Acts (1949/1956), and our amended charitable objects (May 2015)
• Intergroup transfers between PDSA (Registered Charity 208217/ SC037585), PDSA Trading Ltd (01595637), and PDSA PetAid Enterprises (04374375)
• Reporting criminal acts and compliance with law enforcement agencies
• Internal and external audit for financial or regulatory compliance purposes
• Statutory reporting
Publicity & Income Generation
• Conventional direct marketing and other forms of marketing, publicity or advertisement
• Unsolicited commercial or non-commercial messages, including campaigns, income generation or charitable fundraising
• Personalisation used to tailor and enhance the customer experience in our digital and postal communications
• Exercise of the right to freedom of expression or information, including in the media and the arts
• Analysis, targeting, and segmentation to develop corporate strategy and improve communication efficiency
• Processing for research purposes (including marketing research)
• Researching and creating profiles on potential major donors, high net worth individuals, and philanthropists for the purpose of direct marketing.
• Employee and volunteer recording and monitoring for recruitment, safety, performance management or workforce planning purposes
• Provision and administration of staff benefits such as pensions
• Physical security, IT and network security
• Maintenance of suppression files
• Processing for historical, scientific or statistical purposes
Financial Management & Control
• Processing of financial transactions and maintaining financial controls
• Prevention of fraud, misuse of services, or money laundering
• Enforcement of legal claims including debt collection via out-of-court procedures
• Administration of supporters' estates and/or gifts in Wills where PDSA has been named as beneficiary or executor
Purely Administrative Purposes
• Responding to any solicited enquiry from any of our stakeholders
• Delivery of requested products or information packs
• Communications designed to administer existing veterinary services for an animal under active treatment e.g. appointments, consultations, treatment plans, vaccination reminders, or debt recovery
• Administration of active pet insurance policies
• Administration of Gift Aid
• Thank you communications and receipts
• Administration of existing financial transactions
• Maintaining “Do not contact lists” (suppression lists)
When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair.
We collect and use personal information such as name and address details along with other contact information such as email addresses and telephone numbers. We also collect information about the services you use, any purchases or financial transactions you make, or any marketing contact preferences you give. We maintain a record of communications we send to you and we will log any communications that you send to us. We may also ask for other information like date of birth, your interests, your pets, and reasons for your support. If you call our call centre your call may be recorded for quality and training purposes.
If you use our veterinary services, it is important that we record details of your pets, their medical conditions and treatments they receive. We also maintain a record of your eligibility for our charitable services.
If you have kindly Gift Aided your donation to PDSA, we must record the fact that you are a UK taxpayer and we have to maintain a record of the amount of Gift Aid we have claimed.
Before contacting potential major donors, high net worth individuals, and philanthropists we may want to undertake research to better understand their engagement with PDSA, and their potential interest in supporting our major projects. This research will help us target communications in a more focused, efficient and cost effective way and help us to understand what type of charitable project prospective donors may find interesting, the level of support that would be appropriate, and how to personalise our initial contact.
In researching potential major donors, high net worth individuals, and philanthropists we may consider business and family networks, publicly available information relating to: residential location, wealth and assets, career, donations to other organizations, along with their hobbies and interests. The purpose of this research is to help identify new supporters, create a profile of their interests and financial capacity, and to evaluate their ability to support our major projects.
To aid us in this research we may use information the donor has already provided and combine it with additional information from publically available sources such as Google, newspaper and magazines articles, Companies House records, charities, and any other information they have chosen to make public, for example on LinkedIn, public social media profiles, or corporate websites. We may also use additional information such as geographical information for measures of affluence where available.
In order to do this efficiently, we may also use trusted third party specialist companies such as ‘Prospecting for Gold’ and ‘Factory’ that collate and analyse information from public registers alongside statistical social-economic data to automate some of this research work.
When hosting an engagement or fundraising event, we may also produce short biographies of guests who are due to meet with our senior leaders. This helps our people to understand more about those we engage with, and their interests or connection to us. On occasion, where our Royal Patron is also attending the event, these biographies may be required by the palace for those being presented to her, or for security purposes.
Before seeking or accepting major donations we are required to conduct a minimum level of due diligence. This is in accordance with our legal and regulatory obligations and our internal risk management policies and procedures.
Under data protection law, certain categories of personal information are recognised as sensitive, including health information, race, religious beliefs, and political opinions (‘sensitive personal data’). In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide appropriate facilities, enable you to participate in an athletic event (such as a marathon) , or to help you volunteer at one of our shops or pet hospitals.
If you use your credit or debit card to donate to us, or buy something online, we pass your card details securely to our payment-processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Security Standard and don’t store the details on our website or databases.
The vast majority of personal data we hold is given to us directly by our supporters, customers, clients and volunteers in the course of them interacting with our services, websites, or fundraising activities. We may also receive your personal information when you donate to PDSA through third party services such as Just Giving, Virgin Money Giving, or BT Donate.
We may occasionally use external lead generation organisations to provide us with the contact details of people who have expressed an interest in PDSA and have agreed to receive communications from PDSA.
In some situations we may update our supporters, clients and volunteers personal information using other agencies; for example, to check we have a valid and deliverable postal address, or to check if you are on the telephone preference service or fundraising preference service.
PDSA uses the Mosaic postcode-based segmentation tool from Experian Ltd to understand the demographic make-up of geographical areas of the UK. This allows us to get a better understanding of the types of people who live in different parts of the country. This is used to help identify areas in most need for planning purposes relating to our charitable veterinary services, as well as identifying new locations for our charity shops. It also helps us to target and tailor our marketing communications to different audiences, which in turn helps to improve the efficiency of our marketing and fundraising activities.
In general terms we remove identifiable personal data from our records six years after the date of our last interaction. In most cases, this represents six years after the last financial transaction. There are a few exceptions to this rule. If a supporter has kindly left PDSA a gift in their will we will maintain our records of that pledge indefinitely to carry out legacy administration and communicate effectively with the families of people leaving us a legacy. If you are PDSA client, we will retain your records for six years after the date of your last registration.
PDSA or any of its subsidiary companies will not exchange or sell your personal information to another organisation for their own marketing purposes. However, there are legitimate situations where we may have to share your personal information with other organisations. An example could be sharing your details to reunite you with a lost animal via a microchipping service, or where we are using an external service provided via a technical supplier, email broadcaster, or mailing services provider. In these situations, the relationship between PDSA and the third party data processor will be governed by a contract and strict security requirements will be in place to protect your personal information.
Where PDSA is using your personal information on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to ask PDSA to stop using your personal information for direct marketing purposes. Simply contact our friendly customer service team and they will amend your contact preferences.
Right to be Informed – You have the right to be told how your personal information will be used. This policy document, and shorter summary statements used on our communications, are intended to be a clear and transparent description of how your data may be used.
Right of Access – You can write to the Data Protection Officer asking what information we hold on you and to request a copy of that information. Currently the Data Protection Act 1998 gives us 40 days to respond. From May 2018 we will have 30 days to comply once we are satisfied you have rights to see the requested records and we have successfully confirmed your identity.
Right of Erasure – From May 2018, you have the right to be forgotten (i.e. to have your personally identifiable data deleted). In many cases we would recommend that we supress you from future communications, rather than data deletion.
Right of Rectification – If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated.
Right to Restrict Processing – In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
Right to Data Portability – Where we are processing your personal data under your consent the law allows you to request data portability from one service provider to another. This right is largely seen as a way for people to transfer their personal data from one service provider to a competitor.
Right to Object - You have an absolute right to stop the processing of your personal data for direct marketing purposes
Right to object to automated decisions – In a situation where a data controller is using your personal data in a computerised model or algorithm to make decisions “that have a legal effect on you”, you have the right to object. This right is more applicable to mortgage or finance situations. PDSA does not undertake complex computerised decision making that produce legal effects.
We only want to send you communications that are genuinely interesting, appropriate, and relevant to you. You are in control of how we use your personal information for marketing and fundraising purposes. Simply call our friendly supporter services team on 0800 0199 166 and they can update your preferred communication channels, or give you control of the types of fundraising communications you receive. Visit our website for more details https://www.pdsa.org.uk/contact-us
We may participate in Facebook’s ‘Custom Audience’ program, which enables us to display adverts to our existing supporters when they visit Facebook. We may provide your email address, mobile number and address to Facebook, so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account.
For more information please see https://www.facebook.com/business/help/744354708981227 and Facebook’s Data Policy at https://en-gb.facebook.com/policy.php.
PDSA uses resident cookies to store data on the hard disk of your computer for the purpose of identifying you when you return to the PDSA website. If you have resident cookies disabled in your browser, you are still able to use the PDSA website. PDSA uses sessions to store data on our server, which are individually identifiable. This means that a session cookie will be stored on your machine, and will expire once your visit to the PDSA website has ended. Functionality of the PDSA website depends upon your browser accepting session cookies. PDSA tracks visitors to and on the PDSA website by using referrer tracking. PDSA uses click through and open mail tracking when sending emails. This process gives PDSA the ability to tailor future email communications.
By using our website, our social media pages (such as Facebook, Twitter, YouTube, Google+ and Instagram), subscribing to our services, donating to us and/or shopping online, you agree that, unless you have set your computer's browser to reject them, we can place cookies on your device and use that data in accordance with this policy.
In the first instance, please talk to us directly so we can help resolve any problem or query. Our friendly supporter services team can help, or you can contact our data protection officer using this email address DataProtection@PDSA.org.uk.
You can also register with the fundraising preference service (FPS). This service is run by the Fundraising Regulator and allows you to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at www.fundraisingpreference.org.uk or by calling 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days.
You also have the right to contact the Information Commissioners Office (ICO) if you have any concerns about Data Protection using their help line 0303 123 1113 or at www.ico.org.uk
Page last updated 23 April 2019