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
It was updated on: 9 August 2021
Next review date: January 2022
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
The type of personal data we may collect directly from you includes:
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;
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:
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.
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.
We will only share your information if:
These partners may include
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:
St Martin-in-the-Fields Trust is one of several organisations and independent charities that make up St Martin’s. The others include:
Each organisation has its own contact/supporter database together with its own privacy notice and lawful basis for processing data.
From time to time we may talk to our partner organisations about you and/or your support to ensure good stewardship, appropriate fundraising and relationship management. Any data shared will adhere to our proportional and legitimate processes; data will be minimised and relevant to the task in hand.
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.
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.
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.
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.
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
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.
The Trust does not use any form of automated decision making, including profiling and information about how decisions are made.
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.
