The Wellington Trust .

The Wellington Trust (the Trust) is located at Wellington, Temple Stairs, Victoria Embankment, London, WC2R 2PN and telephone 0330 133 2844 and we are providing this Privacy Policy to explain our data collection, use and storage of any personal data which we process. The Wellington Trust is responsible for the personal data which comes into its care. The Wellington Trust is a charity number 1109066 and the Trust’s registration number with the ICO is ZA273 3731.

The Wellington Trust’s Company number is 5343257 and the VAT number is 868015021.

The Wellington Trust is committed to protecting your privacy and provides a powerful and safe online experience. This statement of privacy applies to the Wellington Trust’s website and to our processing activities in general. The conditions of processing of personal data and the purposes for which personal data may be collected, stored and used are described in this Privacy Policy. By using the Trust’s website, you signify that you are happy with the data protection practices described in this statement.

The UK GDPR provides rights to individuals regarding the collection, storage and use of their personal data. This Privacy Policy and our subsequent processing activity relating to personal data, take account of any new requirements under this revised legislation. Also covered in this Privacy Policy are the requirements of the Privacy and Electronic Communications Regulations 2003 (PECR) as updated.

Who is the Data Controller?

The Wellington Trust.

Data Controllers contact details

The Manager, The Wellington Trust, Wellington, Temple Stairs, Victoria Embankment, London, WC2R 2PN. Telephone 0330 133 2844.

Responsible person

The Chairman, The Wellington Trust,

What is personal data?

Personal data means any information which relates to a living individual who can be identified, directly or indirectly, by reference to an identifier such as their name, email address and other personal details.

What categories of personal data may we process and retain?

  • Your name, postal address, email and telephone numbers.
  • Your post nominals
  • Your Membership status for the Friends of the Wellington
  • Your gender
  • Your areas of interest
  • Your possible contribution to the Trust
  • Your Board status
  • Your service on committees
  • Your membership of other organisations
  • Your civic appointments
  • Your attendance at events
  • Any photographs taken
  • Your interest in sponsorship
  • Your membership fees, donations or other financial contributions.
  • Any Standing Orders or Direct Debits.
  • Other information which, from time to time, you give to us, including your guests’ information for events.

Why do we process and how do we use your personal data?

We process personal data for the following purposes:

  • To process your application to become a Friend of the Wellington
  • To process your attendance at lectures and other events
  • To process your information as it relates to the Board, committees or other business of the Trust
  • To invite you to events – in person or online
  • To facilitate your ability to network with other members of the Trust
  • To respond to enquiries or requests that you send us
  • To inform you about our work and mission, including the charitable work of the Trust.
  • To send you marketing and fundraising information where we have lawful grounds
  • Staff and member administration including payroll administration, tax calculations and payments
  • Sickness, parental, volunteering and other types of leave
  • Training
  • To monitor compliance with our policies and procedures
  • Recruitment
  • Other processes related to the above

Your rights under UK GDPR.

  • Data Subject Access Requests. You have the right to access the personal information we may hold about you. On receipt of such a request we will endeavour to respond to you as soon as possible but at least within one calendar month. You must provide us with 2 forms of personal identity to ensure that we disclose to you only the information which is relevant to you personally. You will not have to pay a fee to access your information, however, should your requests be clearly unfounded, repetitive or excessive, we may refuse to comply with your request in these circumstances.
  • Rectification. You have the right to request that we amend any personal information that may be incorrect or require updating.
  • Erasure. You have the right to request that we delete any personal information pertaining to you.
  • Data Portability. You have the right to data portability, primarily designed to make it easier for you to switch between service providers. This is unlikely to be relevant to your relationship with the Trust.
  • The right to restrict processing. Individuals have the right to ‘block’ or suppress processing of personal data. If you decide to do this, we will continue to store the data, but not further process it until we have agreed a solution to the issue you have raised.

Do we collect any special categories of data?

We do not collect any special categories of personal data as defined by UK GDPR, except potentially if you are a staff member.

Special categories of data are defined in the regulations as:“racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”.

Is data collected from third party or public domain sources?

We may collect your personal data from you, a member of staff, a member of the Trust, a supporter of The Trust, face-to-face, or from a public source where we believe that you will be interested in what we do. Where we collect personal data from a third party or public domain source, we provide a means for you to opt-out or unsubscribe on every message we send you.

What are our grounds for lawful processing?

We will use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances.

  • Where we need to perform a contract, we are about to or have entered into with you, such as your admission as a Friend of the Wellington or the supply of services to the Trust.
  • Where we have your consent
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Legitimate Interests

Where we use Legitimate Interests as a lawful means of processing your personal data, we make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data. We do not knowingly use your personal data for activities where our interests are overridden by the impact on you.

How to stop receiving communications?

You may contact the Manager and make specific requests on how you wish to change the use of your personal data.

Surveys or Marketing Research.

We may contact you from time to time to seek your views via a short survey to inform our strategic direction, your thoughts about our work and other matters. You always have the choice about whether to take part in our research.

Is data processed outside of the European Economic Area?

We do not knowingly process personal data outside the EEA.

Is data shared with 3rd parties and if so, who?

We may have to share your personal data with the parties and for the purposes set out below. External 3rd parties are all based in the United Kingdom.

Service Providers acting as processors who provide IT and system administration services:

  1. Website developers
  2. Email service providers
  3. Secure system advisers

Professional advisers acting as processors:

  1. Bankers
  2. Pension Actuaries
  3. HR advisers
  4. Accountants
  5. Auditors
  6. Bookkeepers
  7. PAYE processors
  8. Lawyers
  9. Insurance
  10. Other professional advisors
  11. The Board and Management Committee
  12. The Honourable Company of Master Mariners, whose livery hall is on board Wellington.
  13. HM Revenue & Customs, regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.

Marketing, events and publishing:

  1. Printers
  2. Event organisers
  3. Research organisations
  4. Catering and venue organisations
  5. PR and Marketing Agencies
  6. Email broadcasters
  7. Social Media broadcasters
  8. Other marketing specialists

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we disclose personal data, we have a data processing agreement in place as required by the legislation to ensure the security of any personal data that each processor or sub-processor is processing.

Automated Decision Making and Profiling

The Trust does not employ any automated decision-making or conduct profiling.

Cookie Policy

Our website uses simple cookies that:

  • Allow us to measure website traffic volumes and better understand how our visitors use the website via Google Analytics.
  • Enable the simple viewing and sharing of our announcements via electronic and social media.
  • We also use a cookie that itself remembers your cookie preferences – an essential cookie.

These cookies entail no personal data, and our website will disable all non-essential cookies until consent is granted and allows you to enable or disable these cookies on login.

Third party cookies are set by someone other than the owner of the website you are visiting. Our website may contain content from other sites who may set their own cookies, i.e. Twitter, Facebook, Instagram or LinkedIn. We have no control over third party cookies, but you can turn them off yourself in your own browser settings. For further information please see

Data security – how we protect your data.

We follow appropriate security procedures in the collection, storage and use of your information so as to prevent unauthorised access by third parties.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an authorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We process data at our registered office, with access restrictions in place for our data processors within the UK. Our IT specialist retains our data at a different location equally protected behind the appropriate firewalls and other security devices.

However, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your information except to the extent that we are required to accept such responsibility under UK GDPR and the Privacy and Electronic Communications Regulations 2003, as updated. Once we have received your information we will use security procedures and features to prevent unauthorised access of it.

External links not covered by this policy

Please remember that when you use any link to go from our website to another website or you request a service from a third party, this policy no longer applies.

Your browsing and interaction on any other website or your dealings with any other third party service provider is subject to that website or third party service provider’s own rules and policies. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This policy applies solely to information collected by us through our website or services and does not apply to these third party websites and third party service providers.

Data Retention Policy

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected or for our historical archive, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy and if you need further details, please contact

What to do if you have a concern.

Please contact the Manager first and we will do our best to help you. If you are still not satisfied you may contact the regulator, the Information Commissioner’s Office by clicking here

Changes to this Privacy Policy

Amendments to this Privacy Policy are made every time something changes in the way or purpose for which we process personal data, or when the regulations or guidance are amended.

When last updated?

This Privacy Policy was updated on 19th February 2024. We will continue to keep this Privacy Policy up-to-date, so we encourage you to check back from time-to-time.