Human Rights Policy
Human Rights Policy
Wilderness Ltd trading as Wilderness Agency
Registered in England & Wales number 9041900
We are committed to respecting human rights in all aspects of our operations. We believe that we have a responsibility to ensure that human rights are understood and observed in the areas that we work, including those of suppliers and those who are based outside our main country of operation.
We support the principles set out in the following international standards:
- UN Declaration of Human Rights
- UN Guiding Principles on Business and Human Rights
- The International Labour Organization’s Fundamental Conventions
- United Nations Declaration on the Rights of Indigenous Peoples
This policy applies to all personnel of Wilderness Agency, including all directors,
officers, employees (whether employed on a temporary, fixed term, permanent or part-time basis), workers and contractors. It is expected that our suppliers and clients comply with the law as a minimum and should do their utmost to comply with the principles of this policy.
This policy is intended to protect Wilderness, our members, personnel and business partners; please read it carefully. Given its importance, any breach of this policy may result in an investigation under Wilderness’ Discipline and Grievance policy (if applicable) and may result in disciplinary or (if you are not an employee) other enforcement action being taken against you. Employees should consult the Disciplinary policy (available in the Employee Handbook) for more information.
We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights. Our aim is to help increase the enjoyment of human rights within the communities in which we operate.
At Wilderness, it is every employee’s responsibility to maintain a work environment that reflects respect for human rights and is free from all discrimination and harassment.
If any employee believes that someone, either a Wilderness, or one of our suppliers or a contractor is violating this Human Rights Policy and/or the law, they are asked to report it immediately to their manager, the Operations team or through the Whistle-blower process.
We expect our suppliers and contractors to also have in place processes to enable their own staff to report any concerns.
We have identified the following main areas of responsibility:
Equality and Diversity: Our commitment is to provide a safe and inclusive working environment where all people are treated fairly and with respect. We have a specific policy which sets out our commitment and the responsibilities of management and staff.
We require our suppliers and contractors to comply with any local legislation which applies to equality and diversity as well as adhering to our behaviours and values, supporting us in the delivery of our commitment.
Freedom of Association and Collective Bargaining: We respect the right of our employees to join or not to join a trade union and as such they are free to join an organisation of their choice to represent them in line with local legislation. We require our suppliers and contractors to respect their employees’ right to freedom of association. If operating in the UK or anywhere else where local rights to collective bargaining exist we require suppliers and contractors to allow this.
Labour rights: We provide fair working conditions for our employees including terms and conditions of employment, remuneration, working hours, resting time, holiday entitlements, maternity/paternity leave and benefits; we comply with all applicable legislation. We have specific policies which set out our commitment and the responsibilities of management and staff. We require our suppliers and contractors to comply with all applicable local legislation as well as adhering to our behaviours and values, supporting us in the delivery of our commitment.
Wages: Wilderness is committed to ensuring that their direct employees are not paid lower than required by law. We require our suppliers to comply with all applicable legislation or, if there is no applicable local law in the country in which they operate, ensure that their pay will not be less than the level paid generally within that industry.
Forced Labour (Slavery): Wilderness has a policy of zero-tolerance towards acts of modern slavery which are unlawful and are a violation of fundamental human rights. We require our suppliers and contractors to comply with all applicable local legislation as well as adhering to our behaviours and values, supporting us in the delivery of our commitment.
Safe and Healthy Workplace: We are committed to delivering high standards of health and safety management and aim to continually improve our performance, always seeking to reduce risk. We believe in always doing the right thing and in doing it safely, without unnecessary risk to people’s health and will comply with all relevant legislation. We require our suppliers and contractors to comply with all applicable legislation as well as adhering to our behaviours and values, supporting us in the delivery of our commitment.
Child Labour: Wilderness complies with all relevant legislation regarding this; we will not employ young persons under the age of 18 in a hazardous role or at night. We do not
tolerate the use of child labour and require that our suppliers do not to use children in their operations (including in their value chain).
UNDRIP: We fully support and commit to the United Nations Declaration on the Rights of Indigenous Peoples.
This policy will be monitored through regular auditing and/or workplace inspections as appropriate. Supplier on-boarding assessments will ensure human rights are adequately respected and their ongoing audit and/or review (as appropriate) will ensure continued compliance with this policy.
The effectiveness of this policy will be measured through supplier data as well as any relevant reports made to Wilderness via the whistle-blower process.
This policy does not form part of any employee’s contract of employment and may be amended at any time.
Wilderness will review this policy on a scheduled basis and may, at any time, withdraw this policy or publish replacement or revised versions of this policy to reflect developments in the business, or changes to legislation or procedures.
Printed copies of this document are uncontrolled copies of a controlled document. The current version of the policy can be found on our website.
The Operations Team is responsible for reviewing and maintaining this policy, and ensuring it remains current.
All operations and departments within the Company are responsible for implementing the policy.
Supplier – This term refers to any business or company employed by Wilderness to deliver a service, carry out work within the Wilderness’ undertaking, provide products / goods / materials to Wilderness.
Legislation – Acts, Regulations and Orders for the jurisdiction/country in which Wilderness or supplier is operating from.
Customer – This term refers to anyone who has a transactional relationship with the Wilderness for a service provision.
4.1.1 The right to be informed about Our collection and use of personal data; Our Site is owned and operated by Wilderness, a limited company
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data do we collect?
Depending upon your use of Our Site and and our company, We may collect some or all of the following personal and non-personal data:
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
5.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How do we use your data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Personalising and tailoring your experience on Our Site;
6.2.3 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4 Personalising and tailoring Our services for you;
6.2.5 Replying to emails from you;
6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link included in marketing emails or contacting our Data Protection Officer.
6.2.7 Market research;
6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for six months.
7. How and where do we store your data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored in the UK.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Computers and documents that hold your personal data are password protected.
8. Do we share your data?
8.1 We may share your data with other companies in Our Group including, Pitchside and Pack and our clients.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What happens is our business changes?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How can you control your data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes.
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your right to withhold information.
11.1 You may access certain areas of Our Site without providing any data at all.
12. How can you access your data?
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com.
13.3 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for analysing the use of Our site. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
13.4 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.5 Our Site uses analytics services provided by Google Website analytics that refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.6 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.7 The analytics service(s) used by Our Site use(s) the various Cookies.
13.8 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.9 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting us.