Transparency & Community Care

Privacy Policy

This policy explains how The Wartime Vessels Association collects, uses, and safeguards information in accordance with UK GDPR and the Data Protection Act 2018. It follows the same custodial care we show for wartime vessels—respectful, accountable, and transparent.

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WVA (Wartime Vessels Association) is a trading name of The Wartime Maritime Memorial Association C.I.C.

Policy register Privacy & Data Protection Policy

Controller

Wartime Maritime Memorial Association C.I.C.

Company number 16863284

Scope

Membership, grants, archives, education, and web interactions.

Contact

hq@wartimevessels.org
The Innovation Centre, Brunswick Street, Nelson, Lancashire, BB9 0PQ, United Kingdom

Who we are

The Wartime Maritime Memorial Association C.I.C. is a Community Interest Company Limited by Guarantee.

We operate a community benefit lock mandated for CICs, reinvest every surplus, and act as the data controller for information gathered through this website as well as through membership, grant, educational, archival, and event activities.

Personal data we collect

We collect and process the following information when you engage with the Association:

  • Account and membership details such as name, email, phone number, chosen membership type, motivations, and vessel details supplied when joining or applying for director roles.
  • Contact enquiries including your name, email, subject, and message content when you submit the contact form.
  • Grant and stewardship information covering vessel names, service history, project summaries, materials needed, requested amounts, compliance confirmations, and steward reports.
  • Boat registries and crew including vessel specifications (build year, construction material, dimensions, websites), owner notes, images, and crew contact details.
  • Education & skills programmes such as sea skills activity completions, evidence text or files, assessor details, Duke of Edinburgh IDs, and progress dates.
  • Ship reports & research including URLs you submit, payload data required to generate reports, and status updates.
  • News contributions such as article drafts, categories, and publication metadata if you submit or share stories.
  • Digital interactions such as IP addresses, device/browser information, and analytics data gathered through essential cookies to keep the site secure and performant.

We do not intentionally collect data relating to children under 13. If such data is provided, we remove it promptly.

Lawful basis for processing

We rely on the following lawful bases under UK GDPR:

  • Consent – for marketing communications, publishing stories or images, and including you in the Living Custodian Network or heritage archives.
  • Contract – to administer membership services, manage grant applications, deliver educational programmes, or process event bookings.
  • Legal obligation – to meet company law, CIC regulations, safeguarding duties, and financial reporting requirements.
  • Legitimate interests – to maintain archives, protect heritage vessels, improve programmes, and further our community benefit objectives while balancing your rights.

How we use your data

  • Respond to enquiries, volunteer offers, and historical research requests.
  • Administer memberships, grants, events, seamanship profiles, and the Small Craft Plank Grant Scheme.
  • Maintain memorial rolls, vessel registries, oral history archives, evidence of skills completion, and statutory registers.
  • Share news, fundraising opportunities, and heritage updates when you opt in.
  • Validate submissions, prevent fraud, and ensure the security and performance of our digital platforms.
  • Support responsible search engine indexing (including Google) to improve how our public content is discovered.

Statutory records & Articles compliance

Our Articles require us to keep members’ registers, minutes, records of resolutions, and annual accounts for at least ten years.

When you become a member or act as a Director, we record your name, contact details, class of membership, declarations of interest, and relevant insurance or indemnity information. These records are stored securely, used only for lawful corporate purposes such as issuing meeting notices, and retained no longer than necessary. Sensitive personal information is never published in public minutes.

Sharing your information

We do not sell personal data. We may share information with carefully selected service providers (such as email newsletter platforms, web hosts, form processing, file storage, or event partners) who process data on our behalf under written agreements.

Key service partners include:

  • Amazon Web Services (AWS) – our digital infrastructure provider for hosting, storage, backups, and secure delivery of our online services.
  • The Duke of Edinburgh’s Award (DofE) – for the administration and management of DofE activity records, evidence, and progress tracking where you participate in award programmes.
  • Google – for reCAPTCHA spam prevention and analytics tools that help us understand website usage and maintain service security.
  • Falconis Solutions Limited – for membership systems support and infrastructure services.

Data may also be shared with regulators or law enforcement where required by UK law, or with partner organisations when you have provided explicit consent.

Whenever data leaves the UK we use appropriate safeguards, such as UK-approved standard contractual clauses.

Cookies & analytics

We use essential cookies to keep the site running, maintain session security, and remember your preferences.

Where optional analytics or performance tools are enabled, we gather anonymised or pseudonymised usage data (including Google analytics services) to understand how the site is used and to improve accessibility. You can manage cookies through your browser settings, though blocking essential cookies may affect site functionality.

We use cookies to enhance browsing security, keep sessions running, and understand website usage through analytics. The table below outlines the cookies currently in use on this website.

Cookie Domain Description Duration Type
XSRF-TOKEN www.wartimevessels.org This cookie enhances visitor browsing security by preventing cross-site request forgery. 2 hours Necessary
wartime-maritime-memorial-association-session www.wartimevessels.org   2 hours Other
_ga_* .wartimevessels.org Google Analytics sets this cookie to store and count page views. 1 year 1 month 4 days Analytics
_ga .wartimevessels.org The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. 1 year 1 month 4 days Analytics
rc::a google.com This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks. never Necessary
rc::c google.com This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks. session Necessary

Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to meet regulatory or insurance requirements, and to maintain an accurate historical record where you have consented.

  • Membership and director records: held for the life of the relationship and at least ten years in line with CIC and company law obligations.
  • Grant documentation and financial records: retained for at least seven years for audit and reporting.
  • Education and sea skills evidence: retained for programme delivery and verification, then reviewed annually.
  • Contact enquiries and routine correspondence: retained for up to two years unless needed longer to resolve issues.
  • Heritage archives, vessel registries, and published stories: retained indefinitely when you have consented to archival use.

How we protect your data

We use encryption, access controls, regular backups, and least-privilege principles to protect information. Third-party processors must meet our security standards.

While no system is completely secure, we regularly review safeguards and respond promptly to incidents.

Your rights

Under UK GDPR you have the right to:

  • Access the personal data we hold about you.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your data where there is no lawful reason for us to continue processing it.
  • Restrict or object to processing in certain circumstances, including direct marketing.
  • Request data portability for information you provided to us.
  • Withdraw consent at any time when processing is based on consent.

To exercise these rights, email hq@wartimevessels.org with details of your request.

Questions or concerns

If you have concerns about how your information is handled, please contact the Data Protection Lead at hq@wartimevessels.org or write to us at The Innovation Centre, Brunswick Street, Nelson, Lancashire, BB9 0PQ, United Kingdom. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

Updates to this policy

We may update this notice to reflect changes in our activities or legal requirements.

The “last updated” date will change accordingly, and significant updates will be communicated through our website or by email where appropriate.

Duke of Edinburgh (DofE) Privacy Notice

Updated May 2022

Last updated: May 2022 (adapted for WVA use)

This notice applies to young people participating in Wartime Vessels Association (WVA) activities that are delivered or evidenced as part of the Duke of Edinburgh’s Award (DofE), including Skills, Volunteering and related educational activities.

If you take part in a WVA activity linked to DofE, we will receive, use and share certain information about you. This notice explains what information is used, why it is needed, and how it is handled. If anything is unclear, you may wish to discuss this notice with a parent, carer or another trusted adult.

About us

The Wartime Vessels Association (WVA) is a UK-based Community Interest Company that provides maritime heritage education, youth programmes and skills-based learning linked to wartime service at sea. For DofE-related activities, WVA acts as a data controller for the personal data it collects and processes.

Contact: privacy@wartimevessels.org

Information about you is also called your “personal data”

Personal data is information that relates to you as an individual. This may include:

  • Your name, email address and contact details
  • Your age and, where relevant, school or organisation
  • Records of activities completed, assessments or evidence submitted
  • Communications with us
  • Images, audio or video created as part of learning activities (where permitted)

In limited circumstances, we may also process special category personal data, such as information about health or additional needs, but only where necessary to support participation or safeguarding, and always with appropriate care and protection.

What personal data is processed, why and how?

Why? How? What? Source Legal ground
To review your application for the activity or programme
  • Our systems receive your online registration or sign-up
  • We assess eligibility and suitability for the activity
  • We contact you (or your parent/carer where appropriate) to confirm participation
Name, contact details, age range, school/organisation (if provided), participation details You (and where relevant, a supervising adult or school) Necessary for participation (contract) and our legitimate interests in operating the programme
To assist participation and safeguarding
  • Provide learning materials and support
  • Respond to queries
  • Identify reasonable adjustments and safeguarding measures where needed
Contact details, support requests, any necessary welfare information You Legitimate interests; legal obligations; and where required, vital interests for safeguarding
To review assessments and evidence submissions
  • Receive evidence you submit (text, images, files)
  • Provide comments and guidance (where offered)
Participation records, evidence content, assessor notes (if applicable) You Necessary for participation and programme delivery
To submit completion to Duke of Edinburgh (DofE)
  • Confirmation via the DofE platform (as applicable)
  • Enable verification and certification
Name, DofE identifiers (if provided), completion status, dates and section details Our records (and the DofE platform where used) Legitimate interests and performance of arrangements supporting DofE verification
Why? How? What? Source Legal ground
Send you marketing about WVA programmes
  • By email (and only where appropriate)
Contact details; preferences/interests (where provided) Our records Consent (where required)
Recognise you when you return to our website
  • Use cookies and similar technologies for security and functionality
  • Optional analytics (if enabled) to understand site usage
Technical data about your device and browser Our systems Essential cookies (necessary); optional cookies only with consent
Share information with your parent, carer, school or supervising adult
  • We may speak to a responsible adult where appropriate
  • We may confirm completion status when needed for oversight or support
Relevant participation data, shared only where appropriate Our records Legitimate interests and safeguarding obligations
Administrative purposes and compliance with the law
  • Secure storage, record keeping, troubleshooting and security monitoring
  • Managing service providers and preventing fraud
  • Resolving complaints or disputes
  • Complying with lawful requests from public authorities
Necessary personal data for administration and compliance Our records Legal obligations and legitimate interests

Most information that we ask of you will be necessary for these purposes. We rely on the information provided by you as correct, but please let us know if this is not the case.

International transfer of your information

In most cases, your personal data stays in the UK. However, there may be occasions where we use a service located abroad where your information is then stored. In these cases, we put appropriate safeguards in place, including contractual protections.

How do we keep your personal data safe?

WVA uses technical and organisational measures to protect personal data, including access controls, secure systems and data minimisation. Only those who need access to information for their role are permitted to see it.

How long do we keep your personal data?

Personal data relating to DofE participation is normally retained for up to six years after completion, in line with legal and organisational requirements. You may request earlier deletion where appropriate.

Your data protection rights

You can ask us to:

  • Provide a copy of your information
  • Correct information you think is wrong
  • Delete information where there is no lawful reason to keep it
  • Restrict or object to certain uses of your information
  • Provide your information to another organisation where applicable

Requests can be made by emailing privacy@wartimevessels.org. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection.

Updates

If we make any changes to this notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date above.

We value your privacy

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