Privacy Notice for Website Users

Privacy Notice – updated October 2020

About us

The St Martin-in-the-Fields Charity (registered charity number 1156305/261359) helps homeless and vulnerably housed people. We are best known for our annual BBC Radio 4 Christmas Appeal with St Martin-in-the-Fields. The money we raise directly supports people through The Connection at St Martin-in-the-Fields and across the UK through the Vicar’s Relief Fund (VRF) and the Frontline Network.

At St Martin-in-the-Fields Charity we are committed to protecting and respecting your privacy and all personal data is held by us and processed in accordance with the General Data Protection Regulation 2018 (GDPR), Data Protection Act 2018 and all other relevant legislation and regulation. The data controller is St Martin-in-the-Fields Charity of Trafalgar Square, London WC2N 4JH (ICO registration number ZA222666). We adhere to the Fundraising Code of Practice administered by the Fundraising Regulator.

This Statement (together with our website Terms and Conditions), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read this Privacy Notice carefully to understand our approach to handling your personal data and how we will treat it.

Why we process your data

We process your personal data to enable us to effectively deliver our charitable objectives and to help us raise funds to deliver our charitable services.  Some of the different ways we may process your data are outlined below:

• Fundraising and marketing – we have a range of fundraising and marketing activities to help us raise income to enable us to achieve our charitable objectives. This includes newsletters, appeals and events
• Working with volunteers – each year many fantastic volunteers help us with fundraising and other activities.  We use your personal information to manage our volunteer programme and communicate with you about your volunteering
• Delivery of our charitable activities – you may contact us about one of our grants via the Vicar’s Relief Fund, or as part of our Frontline Network or as part of our work with The Connection at St Martin-in-the-Fields. We may use your personal data to manage that relationship, communicate with you and deliver our services
• We sometimes conduct research amongst our clients to better deliver our charitable objectives.

Our Lawful basis for processing your 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 fundraising and marketing via email and other electronic communications we always obtain your consent to contact you in that way
• For fundraising communication by post we rely on Legitimate Interest and will always give you information on how to change or withdraw your communication preferences.
• For other fundraising activities, we usually rely on Legitimate Interest. This includes prospect research including wealth screening where we rely on our Legitimate Interest as a fundraising charity
• Some activities are conducted under contract, for example receiving data from third parties that process donations for us
• Where we conduct research amongst our clients, we seek consent for any research where you may be identified
• Our legal basis for processing personal data is reviewed regularly and we will inform you of any changes via updates to this privacy notice

Personal data that we may collect directly from you when you contact us

We may collect and process the following data about you:

• The information you give us most commonly includes
  • Name
  • Postal address
  • Email address
  • Telephone number
  • Communication preferences
  • Gift Aid preferences
  • Any correspondence from you to us or from us to you
  • Information about your donations to us
  • If you volunteer with us, details of your volunteer work with us
• If you contact us via our website we may also collect the following technical information about your use of the website
  • the Internet protocol (IP) address used to connect your computer to the Internet
  • browser type and version
  • time zone setting
  • browser plug-in types and versions
  • operating system and platform
  • weblogs and other communication data.
• If you purchase an item from the St Martin-in-the-Fields shop and make a donation to us we may collect, the shop will provide us with the following details about you:
  • Name
  • Postal address
  • Email address
  • Gift Aid preferences
  • Information about your donations to us
  • If you are involved in our Frontline network or the Vicar’s Relief Fund, please refer to the Frontline Network Privacy Notice or the Vicars Relief Fund Privacy Notice for the specific ways we process your data

Personal data we may collect from other sources on our supporters for fundraising purposes

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 procedures and to meet money laundering regulations.

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.

How we use the information we collect for fundraising and marketing

We use your personal data in the following ways:

• • To process a donation you have made on our online donation page, via post , telephone, via  the St-Martin-in-the-Fields shop. Through a third party such as a church of school collecting on our behalf, any other method
  • To provide you with information about the work of St Martin-in-the-Fields Charity and projects with which we are involved which we feel may be of interest to you, based upon your interest in St Martin-in-the-Fields Charity and agreed communication preferences.
  • To send you our summer newsletter, appeals and other similar materials.
  • To invite you to events associated with St Martin-in-the-Fields Charity which we feel may be of interest to you
  • To conduct analysis to understand the effectiveness of any direct marketing we send to you
  • To help 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
  • To manage your volunteering with us
  • To help us to develop our website and other similar websites that we operate (such as the Vicar’s Relief Fund portal)
  • To notify you about changes to our website or the services that we offer.
  • To ensure that content on our website is presented in the most effective manner for you and for your computer
  • To administer our website and for internal operations, including troubleshooting and testing
  • To ensure that our website is safe and secure

We do not undertake automated decision making or automated profiling as described in the GDPR.

Research with our clients around our core mission of tackling homelessness and deprivation

St Martin-in-the-Fields Charity is committed to reducing deprivation and tackling homelessness. To help achieve this, we sometimes undertake research amongst the beneficiaries of our services.  To find out more about how we use personal data in this way see our Vicars Relief Fund notice here.

Sharing your information

We will always process your information in a secure and confidential manner. As a small team, we work with, and share data with, a number of suppliers and agencies to carry out our core activities.  They do not use any of this data for their own interests.

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
• To ensure that the best interests of our supporters are upheld in partnership with other areas of St Martin-in-the-Fields.

These partners may include

• • Mailing houses (such as MailChimp)
  • Marketing agencies
  • IT specialists
  • Donation processing companies (eg Stripe, Capita, CAF, Solchar, Muchloved, Secure Trading, Justgiving)
  • Data disposal and archive firms
  • Research firms (such as Prospecting for Gold)
  • Providers of grant making software such as Flexigrant
  • Survey providers such as SurveyMonkey

Within the St Martin-in-the-Fields broader organisation, we may also share data with:

• • The Connection at St Martin-in-the-Fields
  • The St Martin-in-the-Fields Trust
  • St Martin-in-the-Fields Limited

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. If you would like to see a full list please contact Tim Bissett (contact details below).

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

Any disclosures will be made in accordance with GDPR and the Information Commissioner’s Officer’s statutory Data Sharing Code (available to view here https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/)

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Where we store your personal data

All information you provide to us is stored on our secure servers within the European Economic Area.  If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Where we use a service that requires processing outside of the EEA, we work only work with organisations that have Privacy Shield or any other appropriate processes in place.  Currently Mailchimp is the only service we use that requires data to leave the UK.

Your rights

You have the right to access information held about you. You can do this via a Subject Access Request by contacting us at [email protected] or St Martin-in-the-Fields, 5 St Martin’s Place, Trafalgar Square, London, WC2N 4JH. Any access request will be free of charge, unless we believe a request is manifestly unfounded or excessive, particularly if it is repetitive.  The information will usually be provided within 30 days, in line with legal requirements.

As well as your right to access your personal data, you have a right to correction, deletion, restriction and data portability. Data portability allows you to obtain your personal data and move, copy or transfer this data to another environment in a safe and secure way.

If you notice an error in the information which we hold about you or wish to withdraw your consent to our processing of your personal data, or to request that we do not process your data for specific purposes,  please contact us immediately at the address given below.

[email protected] or St Martin-in-the-Fields, 5 St Martin’s Place, Trafalgar Square, London, WC2N 4JH.

You have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can find out more about how to make a complaint on the ICO’s website https://ico.org.uk/

Retaining your data

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 for us.

Changes to our privacy Notice

Any changes we may make to this Privacy Notice in the future will be posted on our site and, where appropriate, notified to you by e-mail and in our other materials such as newsletters and updates. Please check back frequently to see any updates or changes to this Privacy Notice.

Contact: Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to [email protected] or St Martin-in-the-Fields, 5 St Martin’s Place, Trafalgar Square, London, WC2N 4JH.