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Privacy Policy

Animal Welfare Investigations Project Limited and AWIP International Ltd (collectively referred to as “AWIP” or “Animal Welfare Investigations Project”) are committed to protecting and respecting your privacy.

This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy periodically in accordance with Data Protection legislation so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.

Any questions regarding this Policy and our privacy practices should be sent by email to info@awip.org.uk or by writing to Animal Welfare Investigations Project, Redwood House, Brotherswood Court, Almondsbury, Bristol, United Kingdom, BS32 4QW.

WHO ARE WE?

Animal Welfare Investigations Project Limited (Company no. 13760374) and AWIP International Ltd (Company no. 15522405), collectively referred to as “AWIP” or “Animal Welfare Investigations Project,” are dedicated to protecting animal welfare. The legal entities are listed below:

  • Animal Welfare Investigations Project Limited is a limited company with its registered address at Redwood House, Brotherswood Court, Almondsbury, Bristol, United Kingdom, BS32 4QW.
  • AWIP International Ltd is a limited company by guarantee with its registered address at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

This privacy policy applies to Animal Welfare Investigations Project Limited and AWIP International Ltd. Both entities are registered as data controllers with the Information Commissioner for the United Kingdom and are collectively referred to as “AWIP” or “Animal Welfare Investigations Project” in this document.

HOW DO WE COLLECT INFORMATION FROM YOU?

Animal Welfare Investigations Project collects personal information about you in several ways:

When you support us by:

  • Signing one of our petitions
  • Making a donation to AWIP
  • Engaging with our social media and digital advertising
  • Joining our volunteer and activist communities

Additionally:

  • When you apply for a job at AWIP
  • When you visit our website
  • When you contact our Supporter Care team

To comply with UK data protection rules, AWIP will always ensure we have legal justification for collecting and using your personal information.

The legal basis that we rely on will depend on the circumstances in which we collect and use your personal information. In almost all cases, our processing of your personal information will fall into one of the following categories:

  • Where you have provided your consent to allow us to use your data in a certain way.
  • Where it is necessary for us to process your data in order to comply with a legal obligation.
  • Where it is in our legitimate interests to contact you in order to raise funds and achieve our campaign objectives. Where we rely on a legitimate interest to use your information, we will always ensure that this is done in a way that is not intrusive or distressing and respects your rights.
  • Where it is necessary for us to process your data in order to carry out the performance of a contract with you.

WHAT TYPE OF INFORMATION IS COLLECTED FROM YOU?

Cookies

Like many other websites, the AWIP website uses cookies. ​‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your country preference. This helps us to improve our website and deliver a better more personalised service.

It is possible to switch off cookies by setting your browser preferences, but turning cookies off may result in a loss of functionality when using our website.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select ​“Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

HOW IS YOUR INFORMATION USED?

We may use your information to:

  • Process a donation that you have made;
  • To carry out our obligations arising from any contracts entered into by you and us;
  • Seek your views or comments on the services we provide;
  • Notify you of changes to our services;
  • Send you communications via email or post after you sign up to our mailing list. These may include information about campaigns, appeals, petitions and other fundraising activities;
  • Process a job application which you make to us.

We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

Animal Welfare Investigations Project Limited and AWIP International Ltd share your Personal Information to effectively carry out our activities and operations.

Animal Welfare Investigations Project may share your Personal Information with its sister organisation Friends of AWIP International, which is a fiscally sponsored project of Fiscal Sponsorship Allies (EIN: 85-0839183). By agreeing to these Terms and Conditions, you expressly consent to the sharing of your Personal Information in this manner.

Animal Welfare Investigations Project transfers Personal Information across borders, mainly between the United Kingdom and the United States of America. You accordingly expressly consent to the cross-border transfer of information in accordance with the terms of this Privacy Policy and for the purposes set out herein.

SHARING YOUR INFORMATION

Unless other stated within this Privacy Policy, we will not release your information to any third parties unless you have specifically agreed that we can do so or where we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

When we are involved in successful prosecutions, either directly or indirectly, we may release the identity of the convicted defendant in press statements. Additionally, we may notify local and national journalists about pending court proceedings. We do this to advance our objectives in investigating animal cruelty, to raise public awareness of animal cruelty, and to deter future offences.

If you provide us with information regarding animal cruelty, we may need to share this information with enforcement agencies such as Trading Standards, the Animal and Plant Health Agency (APHA), the police, Social Services, or other animal welfare organisations. We will only share your personal information when necessary to prevent or detect crime.

We do not share your information with third parties for marketing purposes.

Third Party Service Providers working on our behalf:

Your information is passed on to our third party service providers, agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you emails).

However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

Third Party Product Providers we work in association with:

If you make a donation online, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/​debit card transactions, as explained below.

Donations are handled by PayPal, GoCardless or Stripe (depending on how you choose to donate). These are secure payment providers, equipped to protect payments and personal data. Their privacy policies are published on their websites.

If you have any questions regarding secure transactions, please contact us at info@awip.org.uk.

When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected.

Non-sensitive details (your email address etc.) are transmitted normally over the internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

We use MailerLite as our marketing automation platform so we can send you emails about the campaign. When you sign up to join our mailing list, you acknowledge that the information you provide will be transferred to MailerLite for processing in accordance with their Privacy Policy and Terms.

We may transfer your personal information to a third party if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Occasionally other providers are used on a similar basis.

YOUR CHOICES

You have a choice about whether or not you wish to receive information from us. You can unsubscribe from mailings at any time or email info@awip.org.uk to be removed from our mailing list.

When signing a petition, declaration or writing to politician, if you leave your email address, telephone number, or postal address you agree that we may use these to contact you.

You can change your marketing preferences at any time by contacting us by email: info@awip.org.uk.

HOW YOU CAN ACCESS AND UPDATE YOUR INFORMATION

The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please email: info@awip.org.uk or write to us at: Animal Welfare Investigations Project, Redwood House, Brotherswood Court, Almondsbury, Bristol, United Kingdom, BS32 4QW.

You also have the right to ask for a copy of the information you have provided to us. Please contact us if you wish to be sent this data.

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you.

You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

PROFILING

We may analyse the personal information you give to us when you sign up to our mailing list to create a profile that may include your Parliamentary constituency, local MP and preferences so that we can contact you about specific appeals or campaigns. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.

As a fundraising organisation, we undertake in-house research and from time to time engage specialist agencies such as Prospecting for Gold to gather information about you from publicly available sources, for example, Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as LinkedIn, political and property registers and news archives. 

We may also carry out wealth screening to fast track the research using our trusted third party partners.  You will always have the right to opt out of this processing. We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This may include people connected to our current major supporters, directors or other lead volunteers. We also use publicly available sources to carry out due diligence on donors in line with the Gift Acceptance Policy and to meet money laundering regulations.

This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you.  We shall be relying on legitimate interest to conduct this research.

We may also use your name and contact details to check against sources, such as Royal Mail’s National Change of Address and the BT Operator Services Information System (OSIS) file, to ensure we have the most up to date contact details for you. We may store relevant information about you that you voluntarily share with us.

If you would prefer us not to use your data in this way, you can contact us at info@awip.org.uk.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

16 OR UNDER

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

PROCESSING PERSONAL DATA FOR RESEARCH, INVESTIGATIONS, AND SOURCE PROTECTION

Purpose of Processing

We are committed to safeguarding the welfare of animals and protecting the integrity of our organisation. As part of this commitment, we may collect, process, and publish personal data during our research and investigative activities. These activities aim to:

  • Identify and mitigate threats to animal welfare and our organisation.
  • Expose and raise awareness of individuals, groups, or entities whose actions pose risks to animals or our operations.
  • Conduct research and share findings in the public interest, particularly where they highlight systemic issues affecting animal welfare.

Legal Basis for Processing

Our processing of personal data for research and investigative purposes is based on the following lawful grounds under the UK GDPR:

  1. Legitimate Interests (Article 6(1)(f)): It is in our legitimate interests to investigate and highlight actions that harm animals or threaten our organisation’s mission. This processing is carefully balanced against the rights and freedoms of the individuals involved.
  2. Public Interest (Article 6(1)(e)): Where research addresses matters of substantial public interest, particularly related to animal welfare or public safety.
  3. Freedom of Expression and Information (Article 85, UK GDPR): Processing and publishing personal data for journalistic, academic, artistic, or literary purposes in the public interest.

Where special category data (e.g., political opinions or criminal allegations) is processed, we rely on additional conditions under the Data Protection Act 2018, including:

  • Substantial Public Interest (Schedule 1, Paragraph 10): Processing necessary to prevent or detect unlawful acts or protect individuals or the public from harm.
  • Freedom of Expression and Information (Part 5, Schedule 2): Processing required for journalistic or research purposes, particularly where it serves the public interest.

Types of Data Collected

The personal data we may collect during research and investigations includes:

  • Names, contact details, and public statements of individuals or entities under investigation.
  • Publicly available information, such as media articles, social media activity, and public records.
  • Information provided by confidential sources or obtained through investigative activities.

Protection of Sources

We take the protection of our sources seriously and implement strict measures to safeguard their confidentiality. These include:

  1. Encrypted Communications:
    All communications with sources are encrypted to prevent unauthorised access and ensure the confidentiality and integrity of the information provided.
  2. Secure Data Handling and Destruction:
    • Personal details of sources are securely stored only for as long as necessary to facilitate communication or verify information.
    • Once communication has concluded, and the information is no longer required, all personal details are securely destroyed using industry-standard practices.
    • As a result, even if someone were to request information about a source, such data would not be available for disclosure.
  3. Access Controls:
    Access to source-related information is strictly limited to authorised personnel with a legitimate need to handle it.

Legal Framework for Source Protection

Our commitment to source protection is supported by the following legal principles and legislation:

  1. Freedom of Expression and Information (Article 10, ECHR):
    As incorporated into UK law by the Human Rights Act 1998, this principle protects the confidentiality of journalistic sources to ensure the public is informed on matters of interest and concern.
  2. Data Minimisation and Retention (UK GDPR):
    • We process only the personal data necessary for communication with sources and destroy it as soon as it is no longer required.
    • This aligns with GDPR’s principle of data minimisation and ensures the least amount of personal data is retained.
  3. Public Interest (Data Protection Act 2018):
    Exemptions under the DPA allow us to protect the confidentiality of sources, particularly when disclosure would conflict with the public interest or undermine investigative activities.

Transparency and Publication

In line with GDPR’s principle of transparency:

  • We strive to provide notice to individuals where feasible and where doing so does not compromise the purpose of the research or investigation.
  • Where appropriate and lawful, we may publish findings that include personal data as part of our commitment to inform the public and advocate for animal welfare.
  • Publication is carefully reviewed to ensure compliance with defamation, data protection, and ethical standards.

Exemptions

To protect the integrity of our research and investigative activities, we may rely on the following exemptions under the UK GDPR and Data Protection Act 2018:

  1. Article 14(5)(b): Information Not Provided Where It Would Prejudice the Purpose
    We may not inform individuals about the processing of their data where providing notice would prejudice the purpose of the research or pose a security risk.
  2. Freedom of Expression and Information (Part 5, Schedule 2):
    Certain rights of individuals, including the right to access, rectify, or erase their data, may be restricted if exercising these rights would:
    • Undermine the purpose of the research or the publication of findings.
    • Conflict with our freedom of expression and public interest goals.

Data Security and Retention

We take all reasonable steps to ensure that personal data collected for research purposes is:

  • Processed securely and in accordance with our data protection policies.
  • Retained only for as long as necessary to achieve the research objectives and comply with legal obligations.
  • Regularly reviewed, with data securely destroyed or anonymised when no longer required.

Balancing Individual Rights

We carefully assess the balance between the individual’s rights and freedoms and the public interest in conducting and publishing our research. Where we rely on exemptions, we ensure that such decisions are proportionate, justified, and documented.

PROCESSING PERSONAL DATA FOR SECURITY INTELLIGENCE

Purpose of Processing

To protect the safety and security of our staff, organisation, and operations, we may collect and process personal data as part of our security intelligence activities. This processing is essential to:

  • Identify, assess, and respond to potential threats to our organisation or the animals we protect.
  • Monitor individuals or entities whose activities pose risks to our operations, reputation, or mission.
  • Safeguard the welfare of our team, contractors, and stakeholders.

Internal Security Intelligence Database

We may store personal data related to individuals or entities posing a potential threat in an Internal Security Intelligence Database. This database enables us to:

  • Record and monitor relevant security-related information.
  • Respond to threats effectively and prevent harm to our organisation, staff, or the animals under our care.
  • Support ongoing risk assessments and investigations into harmful or unlawful activities.

Legal Basis for Processing

We process personal data for security intelligence purposes under the following lawful bases as set out in the UK GDPR:

  1. Legitimate Interests (Article 6(1)(f)): It is in our legitimate interest to process data for the purpose of protecting our staff, operations, and organisation from harm or unlawful activities.
  2. Compliance with Legal Obligations (Article 6(1)(c)): In some cases, we may process personal data to fulfil our legal obligations, such as reporting certain activities to law enforcement or regulatory authorities.
  3. Vital Interests (Article 6(1)(d)): Where there is an immediate threat to life or safety, we may process data to protect individuals from harm.

Where processing involves special category data (e.g., political opinions, criminal convictions), we rely on additional conditions under the Data Protection Act 2018, including:

  • Substantial Public Interest (Schedule 1, Paragraph 10): Processing necessary to prevent or detect unlawful acts or protect individuals or the public from harm.

Types of Data Collected

The personal data we may collect for security intelligence purposes includes:

  • Names, contact details, and activities of individuals or entities identified as potential threats.
  • Publicly available information, such as social media activity, published articles, or public records.
  • Information gathered through confidential sources or investigative efforts.
  • Relevant observations or reports of threatening or unlawful behaviour.

Use of Open Source, Closed Source, and Human Intelligence

To ensure the accuracy and effectiveness of our security intelligence, we may collect information from:

  • Open Source Intelligence (OSINT): Publicly available information, such as social media platforms, news outlets, or forums.
  • Closed Sources: Information accessed through secure or restricted channels, including from organisations that agree to share your data directly or indirectly.
  • Human Intelligence (HUMINT): Information provided by confidential human intelligence sources, witnesses, or other reliable sources.

All intelligence gathered is carefully verified where possible to ensure its accuracy and relevance.

Exemptions and Non-Disclosure

We may rely on the following exemptions under the UK GDPR and the Data Protection Act 2018 to limit the disclosure of security intelligence:

  1. Article 14(5)(b): Prejudice to the Purpose
    We may withhold information about the processing of personal data where notifying the individual would prejudice the purpose of the security intelligence activity, such as by compromising an investigation or exposing vulnerabilities.
  2. Part 5, Schedule 2 (DPA 2018): Freedom of Expression and Information
    Certain data subject rights, such as the right to access or erase data, may be restricted if exercising those rights would:
    • Compromise ongoing investigations or security measures.
    • Conflict with the public interest or the safety of others.
  3. Law Enforcement and Public Safety:
    Information may be shared with law enforcement agencies or regulatory bodies if required to prevent harm or address unlawful activities. Such disclosures will be limited to the minimum necessary.

Retention and Data Security

  • Personal data stored in the Internal Security Intelligence Database is securely protected using encryption and access controls.
  • Data is retained only for as long as necessary to mitigate the identified risk or comply with legal obligations.
  • Periodic reviews are conducted to ensure that data is accurate, relevant, and no longer retained than necessary. When no longer required, data is securely deleted or anonymised.

Balancing Individual Rights

We recognise the importance of individual rights under GDPR; however, these rights may be restricted when:

  • Disclosure would interfere with or prejudice our ability to protect our organisation, staff, or the animals under our care.
  • Access to data would conflict with public interest or legal obligations.

Where appropriate, we will provide a clear explanation if any rights are restricted.

HOW WE USE YOUR DATA FOR OUR INVESTIGATIONS

To support our company objectives and in line with our Legitimate Interests, we collect and process certain information about individuals from various sources. We maintain a range of data concerning individuals (referred to as data subjects), known as ‘personal data.’

In exceptional cases, the information gathered during our investigations and intelligence collection may include sensitive data, such as details on a data subject’s racial or ethnic origin, religious beliefs, political opinions, health, or sexual orientation. This “Special Category Personal Data” or “Sensitive Personal Data” is managed in accordance with GDPR regulations.

We maintain an intelligence database and case management database to support the prevention or detection of crime, or the apprehension or prosecution of offenders. Data shared with us in relation to these purposes may be included in this database.

Personal data collected through our investigations and intelligence process will be reviewed after six years. Depending on its continued relevance, it will either be deleted or retained for an additional five years.

You have the right to access your data under GDPR. However, we may refuse to release information if we believe that doing so would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders.

REVIEW OF THIS POLICY

We keep this Policy under regular review.

COMPLAINTS

If you feel that we have not properly responded to a request you have made to us regarding our use of your personal data, or that we have not handled your data correctly, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113, or by going online to https://ico.org.uk/make-a-complaint/.