Privacy policy

Watts Gallery Trust is committed to protecting your privacy and being transparent about how we use your data. We will only use the information that we collect about you lawfully. This page, together with our website terms and conditions, tells you about how we collect, use and store your personal information.

This privacy notice was last updated on 31 October 2022.

This policy provides information on:

  • Who we are
  • The data we collect about you
  • Why we collect your data
  • How we use your personal data
  • Data sharing
  • How we protect your personal data
  • Your legal rights
  • How to contact us

Who we are

Watts Gallery Trust is a registered charity (number 313612) and company Limited by Guarantee (company number 6147572). Our registered address is Down Lane, Compton, Guildford, Surrey GU3 1DQ.

You can also contact us by phone +44 (0)1483 810235 or via the website.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect, use, store and transfer different kinds of personal data about you.
The type of information we collect depends on where and when it is gathered.

  • Identity Data includes prefix, first name, maiden name, last name, username or similar identifier, name of partner/spouse, marital status, title, date of birth, photograph and gender. For donations we also collect any other details provided by the donor for the purposes of crediting and contacting them for their support (this may include names of associated trusts, etc.)
  • Contact Data includes billing address, delivery address, city or places of residence, email address and telephone numbers.
  • Financial Data includes bank account and payment card details. Please note, we will not hold payment information for any longer than it takes to process your transaction.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data includes your username and password, purchases or orders made by you on the online shop, your interests, preferences, previous interactions with Watts Gallery Trust (particularly ticket purchases and event attendance), feedback and survey responses.
  • Technical Data includes internet protocol (IP) address and your login data. A public IP address is a unique number which allows a computer, group of computers or other internet connected device to browse the internet. The log file records the time and date of your visit, the pages that were requested, the referring website (if provided), your internet browser type and version, operating system and platform and other technology on the devices you use to access this website. This information is collected to help diagnose and manage the website, to audit the geographical make-up of users, and to establish how they have arrived at the website.
  • Cookies: for further information about Cookies and how Watts Gallery Trust uses them, please see our Cookies page.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may collect and store personal information about you when you get in contact with us e.g. by mail, email or over the phone. For example, when you make a donation, contact us with an enquiry or to request information, register for an event or activities, use our website or social media channels, or apply for a job or volunteering opportunity. If you use our services or make an enquiry about using them, we will collect personal information usually face to face or over the phone and we may also receive information about you from third parties for a specific purpose – but only if you have given them permission to share your information.

We also collect anonymised statistical information via Google Analytics, and the analytical tools of our Third Party platforms (e.g. Audience Agency) and Social Media accounts. This information may include:

  • the areas of the website you visit
  • the amount of time you spend on the site
  • whether you are new to the site, or have visited it before
  • how you came to our website – for example, through an email link or a search engine
  • the type of computer, browser, network location and internet connection you use.

We do this by using cookies; you can learn more about cookies in our cookies notice.

Watts Gallery Trust may also use publicly available information to identify people who express an interest in giving major gifts to organisations like Watts Gallery Trust, or who may be interested in a high-profile public association with Watts Gallery Trust. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies' House. Where an individual enters into such a relationship with Watts Gallery Trust, they will have a nominated account manager who will agree with the individual any sensitivities they may have with regard to any personal information which Watts Gallery Trust may hold on them. Watts Gallery Trust will not retain data relating to major supporters unless the individual provides their consent, which will be sought at the earliest practical opportunity.

Why we collect your data

The law requires us to ensure we have a lawful basis for processing your personal data. We only use your personal data when we believe it is lawful to do so.

We need to collect personal details so we can respond appropriately to your contact with us. For example, to make sure we can process your donation, thank you for your support or send you the information you have requested.

We collect statistical information on our website, social media and emails to see how they are being used in order to improve our communications. For those who use our services, such as the Art for All Learning Programme, we need to collect your personal information to ensure we can provide you with the best support and to help improve our services for others.

In relation to any marketing or promotional messages from us, you can always opt out of receiving these by emailing us.

How we use your personal data

Watts Gallery Trust will only use your information lawfully and personal details will only be used to provide you with information you would reasonably expect or have agreed to.


We use your personal data for administrative purposes including:

  • fulfilling orders for tickets, goods or services (online, over the phone or in person)
  • processing enquiries and requests for information
  • managing feedback, comments and complaints we receive
  • receiving donations (for example, Gift Aid instructions)
  • maintaining databases of our members and other supporters
  • processing membership subscriptions
  • managing custody of our collection including our intellectual property rights
  • carrying out due diligence to meet our compliance duties
  • helping us respect your choices and preferences
  • recruitment and staff management including pay, tax and pensions administration
  • management of suppliers of goods and services
  • managing your visit to Watts Gallery – Artists' Village (for example, health and safety, security, lost property and incident management)


We use your personal data to communicate with you in order to promote our activities and events and to help with fundraising. This includes keeping you up to date with our exhibitions, events and products in our shops, and to send you general information about fundraising, Membership and other ways you may be able to support us or benefit from Watts Gallery – Artists' Village.

Research and profiling

We carry out research and analysis on our visitors, members and other supporters to determine the success of our public offer and programmes and other activities in the public interest and to help us provide you with a better experience (for example so that you only receive communications about areas of our activities or research you're mostly likely to be interested in).

We may evaluate, categorise and profile your personal data in order to tailor materials, services and communications (including targeted advertising) to your needs and your preferences and to help us to understand our audiences. For example, we may keep track of the amount, frequency and value of your support. This information helps us to ensure communications are relevant, timely and in the best interest of our charitable purposes.

Legitimate Interest

We may contact you about things which we feel are of interest to you or which, based on what we know about you, are in the interests of our charitable objectives to let you know about. This will from time to time include marketing and fundraising, but at any stage you can tell us that you do not wish to receive such information and we will stop contacting you with it.

Such a legitimate interest will constitute a lawful ground for contacting you about our services and activities, subject to your rights and any applicable e-privacy rules on electronic communications. Some examples are:

  • if you purchase a ticket to an exhibition then marketing other similar exhibitions to you would be a legitimate interest
  • if you purchase a ticket to an exhibition or event, under a legitimate interest we may email you a short online survey allowing you to give us your feedback. These surveys are completely voluntary, the data collected is anonymous and the results are regularly used to assess our charitable objectives.
  • if you make a purchase from the shop online then marketing other shop products to you would be a legitimate interest
  • if you have previously supported an appeal for funding then other appeals would be a legitimate interest
  • if you are a frequent ticket buyer then marketing membership of the Friends to you would be a legitimate interest
  • if you are an active Friend then marketing one of our higher-level Patron membership schemes to you would be a legitimate interest
  • if you are a major donor approaching Watts Gallery Trust, then carrying out basic due diligence would be a legitimate interest (and may be legally required of us)

We reserve the right to bring other legitimate interests to your attention in the future.

Do you have to provide personal data?

If we need to collect personal data by law, or under the terms of a contract we have with you, and you choose not to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to deliver an item to you, or to sell you a ticket to an exhibition). In this case, we may be unable to process a transaction and/or may have to cancel something you have requested from us – but we will notify you if this is the case at the time.

Data sharing

We will not sell or share your personal information with other organisations who can contact you except where we are required to by law.

We may only pass on data to specific suppliers or professional agents working on our behalf. We only do this where there are agreements in place over how your data will be used and the third parties have no right to use or store your data for any other purpose than that specified by us.

Examples of such service providers/suppliers include:

  • our mailing house who sends out the Watts Magazine to members
  • our ticketing service provider
  • our email distribution service provider
  • our analytics partner
  • our third-party advertisers such as Facebook who help us target our advertising communications. For example, if we are running a social media advertising campaign, we may provide some pseudonymised data to the third-party site which leverages information such as demographics, interests, and behaviours for matching purposes. This enables us to profile and identify new users likely to be interested in our content.

From time to time, we run competitions or events with other organisations. When we do this, any relevant further details relating to any personal data you submit will be included in the competition or event terms and conditions.

How we protect your personal data

We take all appropriate measures to ensure any personal information is kept secure. Personal information stored electronically is kept on secured servers with limited access from appropriate staff.

On our website the payment and events booking pages are via our accounts with Digitickets and payment processing by Card (Worldpay). Our online shop payments are processed by Shopify, and donations are processed via Stripe. These forms use encryption to ensure that the information is encrypted. SSL is a more secure form of transmission to send data across the internet.

Please note that while we have taken every appropriate measure to secure your data, transmission of information over the internet is never 100% secure so while we take all possible precautions, we cannot 100% guarantee the security of any information you submit to us via our website.

We do not keep the card payment details of any donations from our website or if you make a donation with a credit or debit card via post or phone. We process these payments via our WorldPay or SagePay accounts and do not keep a record of your card details which make the payment.

What we do keep a record of is how much you donated, the date it was donated, your name and contact details so we can send you a receipt and make sure we have your correct donation amount, in case you have an enquiry about your donations at a later date and to claim gift aid if you have given us a Gift Aid declaration.

Data retention

We will hold your personal information on our systems for as long as is necessary for the relevant activity, including for the purposes of satisfying any legal, accounting or reporting requirements. We will not keep more information than we need.

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. For example, we will keep a record of donations for at least seven years.

If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

In some circumstances you can ask us to delete your data: see Request for erasure in Your Legal Rights section of this page for further information.

Legacy income is vital to the running of the charity. We may keep data you provide to us indefinitely, to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyse the source of legacy income we receive.

Your legal rights

You have a number of legal rights in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which, if applicable, will be shared with you at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation that makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use, or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time of your request.

These don't apply in all circumstances, as there are also legal exemptions which may apply, depending on why we have collected the data, and the legal basis on which we are holding the data. We will be happy to explain if you have questions about this.

You can contact us at if you wish to:

  • make a formal request for information we hold about you
  • make changes to the data we hold about you
  • opt out of being contacted for marketing purposes (you can also opt out of our marketing
  • messages by using the unsubscribe link that appears on each of them)
  • request us to erase the data we hold about you
  • ask questions or raise concerns about this privacy notice.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How to contact us

Data Protection requests and enquiries

Please email with any data protection requests or enquiries, including requests to exercise your data protection rights (such as access, erasure or objection to processing).

Data Protection Officer

Watts Gallery Trust has appointed an independent Data Protection Officer. The DPO is available to advise and assist members of the public, and members of Watts Gallery Trust staff, in the exercise of their rights, for example by escalating an existing data protection request.


You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK Data Protection Authority ( We would appreciate the chance to deal with your concerns before you approach the ICO so please contact first.

Please address requests and questions about this, any other question about this Privacy Policy or complaints, to the Data Protection Officer, Watts Gallery Trust, Down Lane, Compton, Guildford, Surrey GU3 1DQ.