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 Data Protection Act 2018 (DPA) and General Data Protection Regulations (GDPR). St Martin-in-the-Fields Charity is a registered charity, with registered address Trafalgar Square, London, WC2N 4JJ and registered charity no 1156305/261359. We are the data controller, which means we are responsible for how your data is processed.
The terms data controller, personal data, sensitive personal data and processing all bear their legal meanings under the DPA. The word ‘process’ covers most things that can be done with personal data, including collection, storage, use and destruction of that data.
This Privacy Notice (together with our forum Terms and Conditions available here), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you contribute to any of our Frontline Network forums or ideas board. It also explains the rights you have around your data, including the right to access it, and to object to the way it is processed.
Our Data Protection Officer (DPO) is Tim Bissett, Director, St-Martin-in-the-Fields Charity, who you can contact at St Martin-in-the-Fields Chartiy, 5 St Martin’s Place, Trafalgar Square, London. WC2N 4JH, email@example.com or on 07957 611203. if you have any queries about this notice or anything related to data protection.
- INFORMATION WE COLLECT ABOUT YOU
‘Personal data’ is any information that relates to a living, identifiable person. This data can include your name, contact details, and other information we gather as part of your use of the Frontline Network. In general terms, we process your data in order to manage our relationship with you.
Information you give us. You may give us information about you when you use our forum.
This includes information you provide when you register to use a particular forum or ideas board, when you submit information to a forum or the ideas board and when you report a problem with the use of the forum.
Types of personal data processed
Legal basis for processing
The information you give us includes your name, work e-mail address, organisation name, work telephone number, job role, organisation address, manager’s email address, together with the ideas, comments and opinions which you express when making a contribution to a forum or survey.
You also give us your contact information when signing up to attend an event, and if you decide to attach your details to an otherwise anonymous survey.
Articles 6(b) and (f) of the GDPR which apply where the collection, storage and use of your personal data is:
Information we collect about you. With regard to each of your visits to our forums we may collect the following information.
Types of personal data processed
Legal basis for processing
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information including your username and password, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Articles 6(a), (b) and (f) of the GDPR which apply where the collection, storage and use of your personal data is:
Information we receive from other sources. We do not routinely receive or use information about you from other sources. If we do in future, we will let you now about this, and update this notice accordingly.
Automated decisions. We do not use your personal data to carry out any ‘profiling’ or ‘automated decision making’ which might involve the use of algorithms, artificial intelligence systems or similar processes.
- INFORMATION YOU SUBMIT TO THE FRONTLINE NETWORK ABOUT OTHER INDIVIDUALS
It is possible that you may also provide information about other individuals when you submit information to a particular forum.
You should, under no circumstances, disclose confidential information on any of our forums, whether or not this is also personal data for the purposes of the DPA, without the express authority from your own organisation for such disclosure and where applicable the consent of the individual third party to whom the confidential information relates. In appropriate cases, we may ask you to provide written evidence of the authority to make such disclosures.
This information should be anonymised so that it is not possible to identify the particular individual concerned. Where this is not possible or appropriate in the particular circumstances, you should not submit such information unless and until you have the written consent of that individual to the disclosure of their personal data for the particular purposes for which their information is submitted.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your identity, contact, technical, usage and profile data (outlined in the tables above) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing) and is necessary to measure or understand the effectiveness of advertising we send to you and others, and to deliver relevant advertising to you (our legitimate interests).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. This includes information about the work of St Martin-in-the-Fields and projects with which we are involved which we feel may be of interest to you, based upon your involvement in the Frontline Network. It may also include suggestions and recommendations to you about services that may interest you. We will get your express opt-in consent before we send marketing to you or share your personal data with any third party for marketing purposes.
Where you do provide your consent for third parties to contact you about research projects that may be of interest to you, we will only share the following information about you:
- your name
- contact telephone number
- organisation name; and
- email address.
If we share the information listed above with any third parties, your data will be processed in accordance with that third party’s own privacy notice.
You can ask us our third parties to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org or St Martin-in-the-Fields, 5 St Martin’s Place, Trafalgar Square, London, WC2N 4JJ
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your membership of the Frontline Network.
St Martin-in-the-Fields is committed to reducing deprivation and tackling homelessness through the Vicar’s Relief Fund and the Frontline Network. We may use the information which you provide to us for research purposes to further the goals of the Vicar’s Relief Fund (a part of St Martin-in-the-Fields Charity) and the Frontline Network.
The relevant ground for this type of processing is Article 6(e) – processing necessary for the performance of a task carried out in the public interest. Where we process any special category data for this purpose, the relevant ground is Article 9(j) – processing necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
Wherever we use your personal data for research purposes we will seek to anonymise or at least key-code this information first so that you cannot be identified from the data processed. Where this is not possible, your information will be held securely and processed in accordance with the legal grounds, strict safeguards and exemptions provided by the DPA in relation to the processing of such personal data. We will not disclose any research results which contain any personal data which enables you to be identified, unless required to do so by law.
- DISCLOSURE OF YOUR INFORMATION
We will always process your information in a secure and confidential manner and will not disclose to any third party for their own purposes without a legal ground to do so under the data protection laws, such as your consent. Any disclosures will be made in accordance with the ICO’s statutory Data Sharing Code. We use “data processors” who have secure access to your data if necessary, only for the purposes of providing us with a contracted service which is necessary for any of the reasons mentioned above that we use your data. This includes our [e.g. Independent researchers hired to undertake research as part of our ongoing monitoring and evaluation and software providers for running the Forum]
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- WHERE AND HOW WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers within the UK. We do not store or share your personal data, which is submitted via the forum, outside the UK / European Economic Area.
If you respond to a survey through Survey Monkey, please be aware that data is stored in the USA, but is protected under Privacy Shield.
We will keep your data for 6 years.
Once the applicable retention period expires, unless we are legally required to keep the data longer, or there are important and justifiable reasons why we should keep it, we will securely delete the data.
- YOUR RIGHTS
As a data subject, you have rights in relation to your personal data processed by us. We will respond to, and fulfil, all valid requests as soon as possible, and at the latest within one calendar month, unless we can legally extend the timescale. This can be extended by up to two months in some circumstances.
You have the right to:
- be informed about how and why your personal data is processed, including the information we provide through this Privacy Notice;
- ask for copies of the personal data we hold about you, which is sometimes known as making a Data Subject Access Request, or DSAR or SAR;
Your right of access can be exercised by contacting us at email@example.com or St Martin-in-the-Fields, 5 St Martin’s Place, Trafalgar Square, London, WC2N 4JJ; registered Charity number 1156305
- ask for any inaccuracies in your personal data to be corrected;
- ask to have some, or all, of your personal data erased, also known as the right to be forgotten, and we will erase your data on request where we have no lawful reason for retaining it;
- ask us to restrict our processing of your personal data, in some circumstances, which means you can ask us to stop using it but not erase it;
- object to your personal data being processed in some circumstances (see below for more details);
- have personal data that you have provided to us provided back to you in a format which can easily be transferred to another party, where the data is being processed based on your consent or for a contract, and is being processed by electronic means; and
- the right not to be subjected to a fully automated decision-making process (i.e. a system generated decision without any human input), where the outcome has a legal or similarly significant effect on the individual concerned.
You have the right to object to the processing of your personal data, when the purpose of the processing is to deliver direct marketing to you, and we will always stop the processing as soon as possible.
You have the right to object where the legal basis for the processing is that it is necessary for a task in the public interest or the exercise of official authority, or if the processing is necessary for our legitimate interests, or another party’s legitimate interests.
If you object to processing for these purposes we will ask you for your specific reasons for objecting, which should be based upon your particular situation. In these cases, we will carefully consider your objection and let you know if we are going to fulfil your request.
Please be aware that we can refuse a request if we can demonstrate compelling legitimate reasons for the processing, which, on balance, override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.
If we are relying on your consent to process your data, you may withdraw your consent at any time by contacting us.
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 make a complaint on the ICO’s website https://ico.org.uk/ .
We ask that you always ensure that you provide us with up-to-date information. However, if you notice an error in the informaion which we hold about you, please contact us immediately at the address given below in order that we may make the necessary correction.
If you wish to exercise any of your rights, please contact us in the usual way, including telephone or email. You may want to contact our Data Protection Officer directly, on firstname.lastname@example.org who can provide more information on your rights, or help if you have any complaints or queries.
- CHANGES TO OUR FORUM PRIVACY STATEMENT