About this document
This privacy notice explains how The London Marathon Charitable Trust Limited, company number 01550741 and registered charity number 283813 (the Trust, we, our, us) of 190 Great Dover Street, London, SE1 4YB, collects, uses and shares personal data, and your rights in relation to the personal data we hold. For these purposes the Trust is the Controller of your personal data under the General Data Protection Regulation and other UK data protection laws.
The Trust may change this Privacy Notice from time to time. This Privacy Notice is effective from [●] 2018.
How we collect your information
We may collect your personal data in a number of ways, for example:
- From the information that you provide (or is obtained by us) when you complete a grant application or other Trust form on behalf of any organisation;
- When you register or enter your details on our website, for example when signing up for an account;
- When you communicate with us by post, telephone, fax, email or other forms of electronic communication;
- When you attend a Trust event or meeting, or otherwise provide your details to a member of staff or Trustee;
- When you complete a Trust survey or questionnaire (eg our Annual Grantmaking Survey).
The categories of the data we collect
We may collect the following categories of personal data about you:
- Your name and contact information such as address, email address and telephone number (and, on an ongoing basis, any change of address details);
- To a limited extent and only occasionally, medical information such as dietary requirements where we require this information to provide catering services to you at our events;
- Information you provide about yourself when you complete our grant application form/s;
- Information concerning your engagement with the Trust, including records of communications between you and us and your attendance at events and meetings organised by the Trust; and
- Your opinion and feedback in relation to any surveys or questionnaires issued by us that you complete, such as feedback on our charitable services.
The basis for processing your data, how we use that data and with whom we share it
1. Legitimate interests
We may process your personal data because it is necessary for our or a third party's legitimate interests. Our legitimate interests include operating the Trust in a professional, sustainable manner, in accordance with our charitable purposes and all relevant legal requirements. This will always be weighed against your rights, interests and expectations. Examples of where we process personal data in accordance with our legitimate interests include:
- To correspond with you about our charitable services and an expression of interest or grant application which you may be in the processing of submitting or have submitted;
- To evaluate grant applications and expressions of interest and monitor compliance with any conditions of grants provided, and to request updates on projects;
- To inform you of media opportunities, potentially, and of opportunities to write or feature in Trust content (such as our annual report), and to send you these updates and other similar updates (such as invitations to events) from time to time;
- Processing technical information about your use of our website to ensure that content on our website is presented in the most effective manner;
- Processing enquiries, complaints and analysing our charitable services;
- Marketing our services, events (including those run by our trading subsidiary, London Marathon Events Limited) and resources by post, telephone and electronic mail – except in situations where it is required or appropriate to seek your specific consent.
In this respect, we may also provide your personal data to the following (where this is necessary for our or a third party's legitimate interests):
- Third party service providers who we may engage to assist in delivering grant or other services to you or the organisation you represent: for example, event organisers, caterers, speakers and instructors;
- London Marathon Events Limited, which provides back office and administrative support to the Trust (such as finance administration);
- Other grant funders: as part of the assessment of applications we may contact other grant funders to whom you have applied. This may involve (limited) sharing of personal data – ie the name / contact details of the individual who has submitted the application to us on behalf of an organisation. We may also share this (limited) personal data (ie name and contact details) where it is appropriate to put another grant funder in touch with your organisation about other funding opportunities;
- Our bank, to whom payment details are provided to process a payment made to grant recipients;
- Our website operator, who may store details such as name and email address to enable you to log in to our website;
- Our professional advisers, where it is necessary for us to obtain their advice or assistance; and
- Professionals who assist us in putting together our reports, website content and surveys, and our IT support and grants database provider(s).
2. Legal obligations
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data to comply with subject access requests of others, tax legislation, safeguarding requirements (for example those required by the Charity Commission), for the prevention and detection of crime, and in order to assist the police and other competent authorities with investigations (including criminal investigations). In this respect, we may provide your personal data to our professional advisers, where this is necessary for us to obtain their advice or assistance.
In some circumstances the Trust may seek your specific consent to process your personal data: for example, if we wish to use your name, likeness or an attributed quote in our materials (eg our annual report) or on our website or in marketing materials.
We will normally seek consent when processing your medical information such as dietary requirements or other information about your health, for example for our records. At times the processing of personal data concerning your health may be necessary to protect your vital interests (such as your immediate safety) and it may not be appropriate to seek your consent in such circumstances.
If you have given your consent and you wish to withdraw it, please contact us using the contact details below. Please note that where our processing of your personal data does not rely on your consent, we may not be able to fulfil your request (please see Your Rights section below).
Retention of your data
We may retain your personal data for so long as is necessary to deliver our charitable services to the organisation you represent, and to protect our legal interests (for example where required by relevant authorities, or for a reasonable legal limitation period after we have ceased providing grant funding or services to the organisation you represent/ed), or as otherwise stated to you when your data is collected, or for such period as we reasonably consider appropriate in connection with our relationship with you and/or the organisation you represent/ed; or for record-keeping and archival purposes.
We retain information relating to grant applications for 6 years from the date of the most recent application. When we work with other grant funders we retain the information for 6 years after the end of any applicable contract or the most recent correspondence. Where we have allocated grants, we retain information relating to that funding allocation indefinitely so that we can monitor project compliance, for internal analysis / record-keeping purposes and/or to comply with any legal or regulatory obligations.
When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following bases:
- the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
- the transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
- the recipient has entered into European Commission standard contractual clauses with us; or
- you have explicitly consented to the same.
To find out more about transfers by us of your personal data outside the European Union please contact us using the details below.
You have the following rights:
- To be informed what personal data we hold about you and/or to obtain access to it (i.e. by receiving a copy of it in a permanent form);
- To require us not to send you direct marketing communications;
- To require us to correct the personal data we hold about you if it is inaccurate;
- To require us (in certain circumstances) to erase your personal data;
- To request that we restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
- To object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights. You have a right to lodge a complaint with the Information Commissioner.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply: for example, if we have reason to believe the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Privacy Notice.
You can find out more about your rights under data protection legislation at www.ico.org.uk.
Questions and concerns
If you have any questions or concerns about how we process your personal data, or you wish to exercise any of the rights set out above, you may contact: