We are committed to protecting the privacy of your personal data. We will respect any personal data you share with us and keep it safe. We aim to be clear when we collect your personal data and not do anything you wouldn’t reasonably expect.
Please read this Policy carefully to understand our practices regarding your personal data and how we will collect, use and store your personal data. We may update this policy from time to time so please check it regularly. If there are significant updates, we will inform those people with whom we are in regular contact.
Who we are
CMF or City Music Foundation refers to registered charity number 1148641 (with The Charity Commission) and company number 08133744 (Companies House).
CMF’s registered address is: Church House, Cloth Fair, London EC1A 7JQ
Reason for this new policy
The policy applies to the head office of CMF and any branches, and all staff and volunteers working with us in accordance with GDPR 2018. The Trustees and Board of Directors of CMF are ultimately responsible for ensuring that data is collected, stored and handled correctly.
We are in the process of checking and where necessary changing our internal systems and protocols in order to adapt to the new regulations and comply with the requirements established by the GDPR.
Managing Director – responsibilities
To ensure CMF staff and volunteers are aware of the policy, and what it means to them in their working practice.
To ensure that all necessary steps are taken to ensure CMF complies with the new regulations in terms of collection, storage and confidentiality of data.
To deal with questions from staff and other individuals about their data, and with requests to see the data held about them.
What personal data we collect and the purposes for which we use it
Some examples of the type of information we may collect and hold about you are as follows:
But we may also occasionally collect, hold and process other personal data where it is appropriate and relevant, for example:
We will only process sensitive personal data also known as special categories of data (e.g. in relation to your health), with your explicit consent, for reasons of substantial public interests or where necessary for the establishment, exercise or defence of legal claims.
How and why will we use this personal data
Charitable giving is very important to CMF’s ability to achieve its mission. We carry out a wide variety of marketing activities to seek individuals’ support for our work, ranging from appeals for small one-off donations, to large donations to support our core activities, to large fundraising initiatives for specific projects, such as building renovations. We want to ensure that we are contacting you with tailored and appropriate communications, and ensure we direct our resources and fundraising activities as efficiently and effectively as we can. We also want to communicate with you from time to time to thank you for your support and tell you what we have achieved with the help of your donation.
Since we were founded in 2012 CMF has relied on individual donations as well as trusts and foundations and businesses to support both our recurrent costs and for new projects. In order that our fundraising is appropriate, respectful, efficient and effective, we tailor our approaches to different people in different ways. We use information you have given us, sometimes together with data we collect from publicly available sources, to help us decide how best to do this.
For a small number of people, we may undertake research using publicly available information relating to philanthropic activities, wealth and capacity to give, to create a profile of interests and preferences. This helps us understand the background of the people who we believe may be willing to attend events and enter into a dialogue with us to learn more about supporting our work and organisation. Ultimately it helps us to ensure that proactive requests for gifts are directed to only those who we believe may be able and willing to give. This information is collected from public sources such as news articles, Companies House, the Charity Commission, Who’s Who as well as specialist charity research sources such as Trustfunding.org).
If we do collect such information about you, whether jointly or on our own, we will inform you in order to provide you with an opportunity to opt out of your data being used for these purposes. You can also opt out by emailing us on email@example.com
We also have an obligation to ensure we are undertaking appropriate due diligence on potential donors, in accordance with guidelines set out by the Charity Commission and the Fundraising Regulator, and we may collect information from the public domain information for this purpose too.
What lawful bases do we rely on to use your personal data?
Where you will have provided your consent to us using your personal data for a specific purpose:
For working or contractual relationships:
For example, if you apply to be a CMF artist, or support us as a patron, or help in our selection process, or with mentoring or with workshops or any other support of CMF’s core mission, if you purchase something from us (e.g. CDs), or join a membership scheme, or enter any other relationship with us, we will require your personal data to enable us to perform our agreement.
To comply with a legal obligation:
This would include where we have to retain certain records, for example, to manage health and safety, for the detection and prevention of crime, safeguarding obligations, to ensure we comply with marketing laws, for tax reasons (such as those related to gift aid donations) and undertaking due diligence before accepting certain donations or entering into certain relationships.
When it is within our legitimate interests:
Applicable law allows personal data to be collected and used if it is reasonably necessary for our legitimate interests or a third party’s legitimate interests (as long as the processing is fair, balanced and does not unduly impact individuals’ rights). We will rely on this ground to process your personal data when it is not practical or appropriate to ask for your consent, and where we are confident that this will not impact your rights.
Our legitimate interests include raising funds for a wide range of activities to support our charitable objectives, ranging from recitals and concerts, other musical events, recording and filming, website development, dissemination of information on what we do, attracting applicants to the scheme, the selection process, education, mentoring, workshops, publications and many other activities. We also have a legitimate interest in publicity and income generation, campaigning and fundraising in order to support these objectives and undertaking due diligence to establish the provenance of donations that are made, or may be made, to us.
Where you have provided your details to us, we may contact you by post and phone for certain marketing and fundraising activities as set out above (but we will explain this to you at the point that we collect your details). You can opt out of this activity at any time by emailing us on firstname.lastname@example.org
We will also rely on our legitimate interests for the proper administration of CMF, and to manage our operations (for example, maintaining appropriate records and databases, for the detection and prevention of crime and safeguarding all those who access our premises and facilities).
When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
How we collect personal data
When you give it to us directly
When a third party provides us with your personal data
When you use our websites and digital products
We may collect personal data about you when you use our website www.citymusicfoundation.org and digital products. Whenever you input personal data into our website (for example, if you join a memberships scheme, or otherwise support us through our website we will collect the personal data that you give to us.
Communications and marketing
We may contact you by post and telephone, and, where you have provided consent, by e-mail, to let you know about our events and activities (and we may also mention those of third parties, particularly where they are collaborating with us or sponsoring our events) that might be of particular interest to you; offers and promotions, or about the work of CMF more generally; and to request donations and provide you with information about and the opportunity to participate in our fundraising activities. We provide the opportunity for you to opt-out from receiving our marketing communications every time we contact you.
In addition you can opt-out from receiving our marketing communications, or update your contact preferences at any time by emailing: email@example.com
We do not sell your information under any circumstances. We may from time to time share your personal data with third where we are embarking upon a joint musical venture or a joint fundraising project. However, we will only ever do this where you have given us permission to do so.
We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies.
Unfortunately, the transmission of personal data 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 personal data transmitted to or via our websites and digital products; any transmission is at your own risk.
How we keep your personal data safe and who has access to it
We are committed to ensuring that there are appropriate controls in place to protect your personal data including protection from misuse and unauthorised access. Data is stored on our network, and in cloud storage and Mailchimp and email servers, which are safeguarded. It is also stored in electronic files on hard drives and sometimes on paper.
Your information is only accessible by staff, volunteers and contractors who are bound by appropriate policies and procedures to protect your information
Please note that you may only use/ benefit from some of the following rights in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ – or please contact us using the details below.
Right to restrict processing
In certain circumstances as outlined in the ICO guidance referred to above, you have a right to require us to stop processing your personal data in a particular way.
Right to erasure
You have the right to request that your personal data is erased from our records in certain circumstances.
Right of access
You have a right to ask for a copy of the personal data we hold about you. If you want to access your personal data, please send a description of the personal data you want to see and proof of your identity by post to Managing Director, City Music Foundation, Church House, Cloth Fair, London EC1A 7JQ.
Right to rectification
We also want to make sure that your personal data is accurate and up to date. Please let us know if your details change. You may also ask us to correct or remove personal data which is inaccurate.
Right to object
You can also opt-out of receiving all or some of our marketing/ fundraising communications or request that we stop processing personal data about you for certain purposes at any time by contacting us using the details below.
Right to data portability
In certain circumstances you have a right to data portability which means we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format.
If you are unhappy with the way in which we have handled your personal data please contact us using the details below.
You are also entitled to make a complaint to the Information Commissioner’s Office. For further information see the Information Commissioner’s guidance here: https://ico.org.uk/for-the-public/personal-information
We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected. We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries. In some cases, we are also obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep records of contractual or financial matters).
Whilst the specific time periods vary depending on the circumstances, in general we will not keep records that include personal data for more than 10 years after a particular matter or exchange has concluded. In the event that you ask us to stop sending you marketing communications, we will retain certain details, such as your name and email address, but only to ensure that you are not contacted again.
Websites and digital products
In this policy “websites and digital products” refers to all CMF websites, including the primary CMF website found at www.citymusicfoundation.org , and all our digital products, such as email, applications and digital channels, including social media.