CORNISH MARITIME TRUST (CMT)

Registered Charity No. 1037745

Data Privacy Notice


1.  What is personal data?

Personal data is information that relates to a living individual who can be identified from that data.  Identification can be through that data alone or in conjunction with other information in the CMT’s possession or even data that is likely to come into CMT’s possession. 

2. Who is the ‘data controller’ for CMT? 

The Board of Trustees of CMT is the ‘data controller’ for CMT (contact details below).  This means the board decides how personal data is processed and for what purposes.

3. How does CMT process personal data?

Processing personal data is governed by the General Data Protection Regulation (GDPR) and means holding or using data via computer systems and/or manual filing systems. “Processing” includes collecting, storing, using and destroying data. CMT complies with its obligations under the “GDPR” by 

  1. keeping personal data up to date; 
  2. storing and destroying data securely; 
  3. collecting and retaining only data that is relevant for CMT’s purposes; 
  4. protecting personal data from loss, misuse, unauthorised access and disclosure; and 
  5. using personal data in line with data subjects’ rights under data protection regulations. 

CMT uses personal data for the following purposes: -

  1. To promote the CMT’s objects as defined in its governing documents for the benefit of its members and others who support it; 
  2. To administer membership records; 
  3. To fundraise for the objects of the Trust; 
  4. To manage volunteers; 
  5. To maintain CMT’s accounts and records (including processing gift aid);
  6. To inform members of CMT’s news, events, activities and services, and matters of particular relevance or interest to its members, including related or relevant matters from related organisations;
  7. To provide members with CMT’s newsletter ‘AHOY’ whenever it is published;
  8. To facilitate health and safety during events, e.g. sailing voyages, where information about food allergies or medical conditions may require conveying such information.

4. What is the legal basis for processing personal data?

  1. The CMT is using Legitimate Interest as it's Legal Basis for processing personal data. This means that the CMT will only process your personal data in so far as it is necessary to achieve the efficient administration and operation of the Trust.  Further, the CMT will only use your data in ways that you would reasonably expect and  will not use your data in ways that you would find intrusive or would cause you harm.
  1. Under Legitimate Interest  the CMT does not need your specific consent to use your personal data for the purposes described in paragraph 3 above.  However, by joining the CMT you have implied your permission for the CMT to carry out the activities listed and to communicate with you as necessary.  Communication will normally be by email.  As explained in Section 7 you have the right to opt out of receiving communications from the CMT. 

5. Sharing personal data
The CMT will share your data with other members or organisations only when it it essential for the efficient and safe operation of the Trust. 

6. How long do we keep your personal data?
We keep data in accordance with the guidance set out by the ICO for no longer than necessary for the purpose for which it was obtained.  Specifically, CMT retains membership records while they are still current, or only recently lapsed; gift aid declarations and associated paperwork for up to 6 years after the calendar year in which a gift aid claim was last made. We ensure that personal data is destroyed securely if/when it is no longer needed, to reduce the risk that it becomes inaccurate, out of date or irrelevant.

7. Your rights 

Unless subject to an exemption under the GDPR, an individual has the following rights with respect to his/her personal data: -

  • The right to request a copy of the data which the CMT holds about you; 
  • The right to request that the Board of CMT corrects any personal data found to be inaccurate or out of date;  
  • The right to request that personal data is destroyed where it is no longer needed by CMT; 
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data. 
  • The right to lodge a complaint with the Information Commissioners Office.
  • Members can view and edit the data held by logging onto their paysubsonline account.

8. Transfer of Data Abroad 

Your personal data will NOT be transferred to countries or territories outside the EU. 

9. Automated Decision Making 

CMT will provide details of any necessary automated decision-making, together with information about the logic, significance and consequences of such processing. 

10.  Further processing

If CMT wishes to use personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining the new use prior to commencing processing. The new notice will set out the relevant purposes and processing conditions, and the CMT will seek prior consent from you before new processing begins.

11. Other Organisations

Transactions carried out through other organisations such as  PayPal and GoCardless to purchase goods and services from the CMT are covered by the privacy and data protection policies of those organisations.  The CMT uses services provided by Google,  MailChimp and GoCardless  which have appropriate data protection and privacy policies. 

12. Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the Secretary of the Cornish Maritime Trust, 13 Trevethan Road, Falmouth TR11 2AS or by email at secretary@cornishmaritimetrust.org

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.