Privacy Notice

St Martin-in-the-Fields Trust

 

This policy was prepared by: Katy Shaw, Trust Director

It was approved by the Trustees on: 24 April 2018

It became operational on: 24 April 2018

Next review date: January 2020

 

St Martin-in-the-Fields Trust exists solely to secure the long term future of St Martin’s buildings, programmes and mission. To achieve our ambitions we seek and welcome charitable donations from individuals, trusts and foundations and organisations.

Our fundraising is legal, open, honest and respectful. We adhere to the Code of Fundraising Practice and are registered with the Fundraising Regulator, which sets and maintains the standards for charitable fundraising in England, Wales and Northern Ireland.

In accordance with the Data Protection Act, and from May 2018 General Data Protection Regulations (GDPR), we have reviewed our lawful basis for processing data. St Martin-in-the-Fields Trust processes data on the principles of Legitimate Interest and Consent for specific aspects of our fundraising activities. This means that the Trust is responsible for considering and protecting the rights and interests of those whose data we hold.

To ensure that our fundraising work is done effectively, we collect, store and analyse data for as long as is necessary to develop and enhance our relationship with supporters.

We will never sell an individual’s data. From time to time we do work with a trusted third party to help us gain a better understanding of our supporters and potential new supporters.

We keep our newsletters and fundraising appeals to a minimum and only contact those who want or would expect to hear from us, via their preferred channel of communication (by post or email).

You can opt out of some – or all – communications at any time by contacting the Trust Office or by using the Fundraising Preference Service.

You are always welcome to contact us to discuss any matters concerning the Trust’s fundraising activity and your data. To do so, please contact Katy Shaw, Trust Director

  • By phone: 020 7766 1168
  • By email: katy.shaw@smitf.org
  • By post: St Martin-in-the-Fields Trust, 5 St Martin’s Place, Trafalgar Square, London WC2N 4JH

Personal data that we may collect

The type of personal data we may collect directly from you includes:

  • Name
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Date of birth (where required)
  • Information on past and current donations
  • Correspondence with supporters and potential supporters
  • Communication preferences
  • IP addresses

We will only ever collect the information we need – including data that will be useful to help improve our services and our relationship with you. This data helps us to;

  • Process and acknowledge donations
  • Record details of meetings, events and communications
  • Keep supporters informed about our work and the impact of their gifts
  • Understand more about our supporters (capacity to give)
  • Identify and seek support from new potential supporters

Ultimately, this processing helps us work more efficiently, effectively and professionally. The processing we do is lawful and in line with best practice advice from the Fundraising Regulator and the Information Commissioner’s Office (ICO).

From time to time we collect data on our supporters from other sources, not directly from you. 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.

This data is gathered entirely from publicly accessible and robust sources including:

  • Public Registers: Companies House, the Electoral Commission (Political Donations), the Electoral Roll (Open Register), the FCA (Financial Services Register), the Law Society, the Land Registry.
  • Trade & Industry References, Professional directories, Charity Commission.
  • UK Reference Volumes: Who’s Who, Debrett’s People of Today, Debrett’s Peerage and Baronetage, City of London Livery Company information, Trustfunding.org.uk.
  • Reliable print and broadcast media; newspapers (The Telegraph, The Times and Sunday Times, City AM), magazines, rich lists.
  • Internet; general google searches, company websites, online-only articles, social media, justgiving.com, linkedin.com

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 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. We also use publicly available sources to carry out due diligence on donors in line with our Gift Acceptance Policy and meet money laundering regulations.

This research helps us 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.

If you would prefer us not to use your data in this way, please contact us.

For more information about Prospecting for Gold, please visit www.prospectingforgold.co.uk/privacy-policy

From time to time we may also use third parties to update addresses to ensure any post we send goes to the correct, up to date, address.

Lawful basis for processing personal data

There are several lawful ways for charities and businesses to hold and process data in the UK. The most common for fundraising activities are Consent and Legitimate Interest.  For email and other electronic communications we always obtain your consent to contact you in that way.  For other fundraising activities, we usually rely on legitimate interest. This is reviewed regularly and you will be informed of any updates to this notice.

Sharing your personal data

We will only share your information if:

  • We are legally required to do so, e.g. by a law enforcement agency legitimately exercising a power or if compelled by an order of the Court
  • We believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites
  • We are working with a carefully-selected partner that is carrying out work on our behalf under a contract

These partners may include

  • Mailing houses (such as MailChimp)
  • Marketing agencies
  • IT specialists
  • Donation processing companies
  • Data disposal and archive firms
  • Research firms (such as Prospecting for Gold)

The kind of work we may ask them to do includes processing events bookings, sending postal mail and checking data against the Mailing Preference Service, sending emails and text messages on our behalf, carrying out fundraising research or analysis and processing card payments.

We only choose partners we can trust. We will only pass personal data to them if they have signed a contract that requires them to:

  • Abide by the requirements of the Data Protection Act, and GDPR as of May 2018
  • Treat your information as carefully as we would
  • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation)
  • Allow us to carry out checks to ensure they are doing all these things

Storage and Security of personal data

We maintain a high level of physical and electronic security in relation to the collection, storage and use of your information. We take reasonable steps to ensure that any information we hold about you is protected. We use SSL encryption for the transfer of data and have other appropriate security measures in place for day to day activities.

Details of transfer to third country and safeguards

Your personal data will usually be stored and processed within the EEA.

On occasion, we may use a system such as Mailchimp to send email newsletters.  This may result in processing in the USA.  MailChimp or any other similar providers that we use must be signed up to equivalent data protection principles.

Retention Period

We will keep your information only for as long as we need it to provide you with the services or information you have required, to administer your relationship with us, to inform our research or the preferences of our supporters, to comply with the law, or to ensure we do not communicate with people that have asked us not to.

In line with our data retention policy, when we no longer need your information we will always dispose of it securely, using specialist companies if necessary to do this work for us.

The right to withdraw consent at any time

Our fundraising is legal, open, honest and respectful. We adhere to the Code of Fundraising Practice and are registered with the Fundraising Regulator, which sets and maintains the standards for charitable fundraising in England, Wales and Northern Ireland.

You are welcome to withdraw your consent/opt out at any time. Simply contact the Trust Office by post, email or phone.

The right to lodge a complaint

We make every effort to handle your data lawfully and with care. If you have any concerns about the way we use your data you can lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO).

Concerns can be lodged online at www.ico.org.uk

Subject Access Requests

All individuals have the right of access to a copy of the information we hold about you on both paper and computer records and any related information. This is known as a Subject Access Request.

To make a Subject Access Request you should write to the Trust Director by email or post.

Currently the Data Protection Act 1998 gives us 40 days to respond. From May 2018 we will have 30 days to comply once we are satisfied you have rights to see the requested records and we have successfully confirmed your identity.

A Subject Access Request is free of charge. However, where a request is deemed excessive a fee may be charged to cover administration costs.

Automated profiling and decision making

The Trust does not use any form of automated decision making, including profiling and information about how decisions are made.

Identity and contact details of the controller

St Martin-in-the-Fields Trust registered at 5 St Martin’s Place, Trafalgar Square, London WC2N 4JH, registered charity no: 1110406, company registration number: 4986630.

The controller for St Martin-in-the-Fields Trust is Katy Shaw, Director of the St Martin-in-the-Fields Trust.

You are welcome to contact the Director to discuss any matters concerning your data and the Trust’s fundraising activity.

  • By email: katy.shaw@smitf.org
  • By phone: 020 7766 1168
  • By post: St Martin-in-the-Fields Trust, 5 St Martin’s Place, Trafalgar Square, London WC2N 4JH