Privacy Notice – Investigations
- In order to support our charitable aims and objectives the League collects and processes certain information about individuals. The League collects data from a variety of sources supplied through Animal Crimewatch and through wider research.
- The League is committed to ensuring the secure and safe management of personal data held by the charity in relation to individuals that we investigate for animal cruelty in the name of ‘sport’ and in support of our campaigns. The Leagues experienced professional investigative team have a responsibility to ensure compliance with the terms of this policy, and to manage individuals’ data in accordance with the procedures outlined in this policy.
- This Policy sets out the League’s obligations in processing that data, and the purpose of this policy is to set out the procedures for the management of such data as part of our investigation process.
- Reporting of suspected wildlife crime relevant to our charitable objectives are investigated in line with the expectations of the UK judicial processes. In addition to GDPR we have obligations to other competing legislation which can only be achieved using a lawful purpose of legitimate interest.
Who are we as a charitable organisation?
The League Against Cruel Sports is a Non-Government Organisation [NGO] animal welfare charity fully committed towards its purpose of protecting animals from cruelty in the name of ‘sport’ sometimes called bloodsports. In support of this the League has an intelligence and investigations function which includes a supporter funded Animal Crimewatch, which is a function available for anyone to report animal crime and matters relating to our campaigns. Those people providing information to the League through Animal Crimewatch are invited to provide their names and contact details.
It is a legal requirement that our charity processes data correctly; we must collect, handle and store personal data in accordance with the relevant legislation. The relevant legislation in relation to the processing of data is:
- The General Data Protection Regulation (EU) 2016/679 (“the GDPR”);
- The Privacy and Electronic Communications (EC Directive) Regulations 2003 (as may be amended by the proposed Regulation on Privacy and Electronic Communications); and
- Any legislation that, in respect of the United Kingdom, replaces, or enacts into United Kingdom domestic law, the General Data Protection Regulation (EU) 2016/679, the proposed Regulation on Privacy and Electronic Communications or any other law relating to data protection, the processing of personal data and privacy as a consequence of the United Kingdom leaving the European Union
The Charity holds a variety of data relating to individuals (herein also referred to as data subjects) who have been brought to our attention, which is known as ‘personal data’. The personal data held and processed by the Charity is detailed within this privacy notice under Privacy and Data Policy. “Personal Data” is that from which a living individual can be identified either by that data alone, or in conjunction with other data held by the Charity.
In exceptional circumstances the information we gather during our investigations and intelligence collection may hold some that is sensitive in nature (i.e. relates to or reveals a data subject’s racial or ethnic origin, religious beliefs, political opinions, relates to health or sexual orientation). This “Special Category Personal Data” or “Sensitive Personal Data” is handled in line with GDPR requirements
Processing of personal data
The Charity is permitted to process personal data provided it is doing so for one of the following grounds:
- Processing with the consent of the data subject;
- Processing is necessary for the performance of a contract between the Charity and the data subject or for entering into a contract with the data subject;
- Processing is necessary for the Charities compliance with a legal obligation;
- Processing is necessary to protect the vital interests of the data subject or another person;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of the Charities official authority; or
- Processing is necessary for the purposes of legitimate interests.
The League has a charitable purpose to campaign towards ending cruelty to animals in the name of ‘sport’. The League has an intelligence and investigation function to support the charities objective by systematically collecting information, for the purpose of supporting the investigation team, developing intelligence and sharing with law enforcement and other suitable NGO’s details of persons suspected of committing animal related crimes or in support of League campaigns. The League, therefore, actively collects information on individuals who are suspected of being involved with or participating in such cruel animal sports.
Privacy and data policy
- The League is a registered Charity and is also registered with the Information Commissioner in accordance with Data Protection legislation.
- The League recognises that information security is a key element of data protection according to article 32 of the GDPR and takes appropriate measures to secure personal data (both electronic and manual) and protect it from loss or unauthorised disclosure or damage.
- The League is the data controller of the personal data we process and therefore is responsible for ensuring our systems, processes, suppliers and staff comply with data protection laws in relation to the information we handle.
The League adheres to the following data protection laws, but the main relevant laws are:
The General Data Protection Regulation 2016/679 (“GDPR”);
The Data Protection Act 2018 (the “DPA”)
Personal data will be stored securely and will not be stored outside the EEA.
The Data Protection legislation gives you the right to access information held about you.
Your right of access can be exercised in accordance with the legislation. You also have the following rights which can be exercised in accordance with the legislation:
- Right to be informed;
- Right to access your data;
- Right to rectify any information you believe is incorrect;
- Right to erase your data;
- Right to restrict processing of your data;
- Right to object to processing;
- Right to withdraw your consent if that is the basis of processing;
These rights may only be exercised in so far as the application of the rights is not likely to prejudice the prevention or detection of crime and/or the apprehension or prosecution of offenders.
You also have the right to complain to the Information Commissioners Office Further information on these rights is available from the Information Commissioners website.
How we protect your information
When you fill in our Animal Crimewatch Report Form or contact us through any other means for the purpose of informing us of suspected animal cruelty, any personal data or contact information provided and held by the League, will be held securely.
When reports are received to our Animal Crimewatch we will collect personal data. For example:
- We will ask for your details and contact information using our lawful purpose of legitimate interest.
- Location of the reported crime;
- Information about the animal crime and those involved or campaign related information
- How this information is known
- We may also receive personal data from third parties when sharing information through information sharing agreements or other legal sharing processes
If the information provided does not fall within our campaigns or charitable purpose, we will not record that information, but we may contact you to signpost you to a more suitable organisation.
Your personal data / contact details will only be passed onto a relevant investigation authorities (e.g Police, CPS) as part of a judicial process directly relevant to the information provided.
We collect and process personal data in relation to subjects under investigation or suspected of animal cruelty in the name of sport or as part of our wider campaigns.
What information do we collect?
Our Animal Crimewatch, intelligence and investigations team will lawfully and ethically collect, process and where legally justified, share personal data in support of our campaigns for the following purposes:
- Prevention and detection of wildlife and animal crime
- Develop information on those suspected of wildlife and animal crime
- In support of our campaigns
Whilst undertaking investigations for suspected animal cruelty in the name of ‘sport’, and as part of our campaign related investigations, the League will collect a variety of personal data from a number of different sources.
Who do we process data about?
We collect personal data using the lawful purpose of Legitimate Interest on:
- Personal data (name and contact details of those contacting us)
- Personal data relating to those reported to us
- Personal data to support our charitable objectives.
How do we use information?
The personal data collected will be used to assist our campaign objectives of ending cruelty to animals in the name of ‘sport’ through developing and pursuing criminal investigations, or through media expose.
Who we share information with
As we have no regulatory powers, there are occasions when we need to work collaboratively with those who can enforce the law when we present evidence of animal cruelty. In these cases, we may share personal data we have collected to fulfill legal obligations and/or in order to prevent and detect crime.
When required, personal data collected in our investigations may on occasions be shared with:
- Law enforcement (Police / National Crime Agency / National Wildlife Crime Unit)
- Other NGO’s (Animal Welfare Charities)
- Other public authorities (e.g SIA/Modern Slavery/Food Crime Unit)
- Contracted investigation services when supporting our investigations.
- When required to comply with legal obligations.
Where possible, we also enter in Information Sharing Agreements (ISA) and memorandum of Understandings (MOU’s). These are designed to outline the purposes and justifications for sharing information (personal data) on a more formal level. These agreements are subject to annual review.
Other processing we may need to carry out
Additional processing of data may be necessary as part of our investigations into reports received of animal cruelty in the name of ‘sport’. In this case, we may be requested or obliged by law enforcement, other NGOs, public authorities or a regulatory body, to provide details of the individuals and people who are being investigated.
How long we keep Investigation Data for?
Personal data collected through our investigations and intelligence process will be reviewed after six years and either deleted or retained for a further five years (if assessed as being still relevant)
This policy is dated: 21/09/2020 and is subject to updates from time to time.