Additional requirements for DCMS funding

Funds from the Department of Media, Culture and Sport, via The London Community Foundation

The London Community Foundation (LCF) is offering small grants to voluntary and community organisations to respond to the needs of their communities affected by the COVID-19 crisis. The Funds which LCF is distributing to Wave 3 applicants of the London Community Response Fund are primarily from the Department of Culture, Media and Sport (DCMS).   

There are additional conditions, audit and assurance requirements for groups in receipt of these Funds. By signing the Acceptance of Grant Offer, your organisation and key person is agreeing to terms and conditions as outlined within the:

  • In Principle Offer of Grant,
  • Conditions of Grant Offer,
  • Acceptance of Grant Offer and
  • Additional requirements for funds awarded from DCMS via LCF as outlined in the below clauses collectively referred to within the clauses below as Your Grant Agreement.

Additional requirements for funds

1. Audit Sample Clause: Provide further information required by LCF, on behalf of DCMS, in a timely manner if your organisation is identified as one of a sample of grantees required to have further audit checks post award.  This could include personal data from two authorised signatories for your organisation, such as Date of Birth and home addresses, as well as possible additional requests for evidence of spend against the grant.  

2. Code of Conduct Clause: Take account of the Code of Conduct for Recipients of Government General Grants, which includes ensuring that your organisation undertake its duties in a manner consistent with the principles set out in the Code of Conduct.   

2.1. You shall immediately notify LCF if you become aware of any actual or suspected breaches of the principles outlined in the Code of Conduct;

2.2. You acknowledge that a failure to notify LCF of an actual or suspected breach of the Code of Conduct may result in our immediately terminating the Grant and taking action to recover some or all of the funds paid to your organisation.  

3. Fraud Clause: The Grant Recipient understands that providing false or misleading information on their application or subsequent communications related to this fund could lead to funds being withheld or [subsequently] recovered. Civil or criminal proceedings may be considered in the event of non-compliance. Post grant award assurance work will be completed to discover and recover fraudulent funds. 

4. Duplicate Funding Clause: Duplicate Funding means funding provided by a Third Party to the Grant Recipient, which is for the same purpose for which the Grant was made, but has not been declared to LCF. 

4.1. The Grant Recipient agrees that it will not apply for, or obtain, Duplicate Funding in respect of any part of the Funded Activities which have been paid for in full using the Grant.

4.2. The Grant Recipient shall promptly notify and repay immediately to LCF any money incorrectly paid to it either as a result of an administrative error or otherwise. This includes (without limitation) situations where the Grant Recipient is paid in error before it has complied with its obligations under the Grant Funding Agreement. Any sum, which falls due under this paragraph, shall fall due immediately. If the Grant Recipient fails to repay the due sum immediately [or within any other timeframe specified by LCFLCF] the sum will be recoverable summarily as a civil debt.  

5. Clawback Clause: The Grant Recipient understands that they must adhere to the requirements of this Clawback Clause in an Event of Default:  

5.1.  An Event of Default occurs if:

5.1.1. You fail to comply with any term or condition outlined in Your Grant Agreement;

5.1.2.  You fail to complete the Project or have failed to make satisfactory progress with the Project or any part of it, in accordance with any agreed timetable;

5.1.3.  Any information given or representations made by You to LCF is found to be incorrect or incomplete to an extent which LCF reasonably consider to be material;

5.1.4.  You fail to take adequate measures to investigate and resolve any reported Financial Irregularity;

5.1.5.  You cease to operate and / or change the nature of Your operations to an extent which LCF reasonably consider to be material, including if You (or any substantial part of Your operations) merge with or are taken over by another organisation;

5.1.6.  before the end of the Funding Period You: are subject to a proposal for a voluntary arrangement or have a petition for an administration order or a winding up order brought against Your organisation; pass a resolution to wind up Your organisation; make any composition, arrangement, conveyance or assignment for the benefit of Your creditors, or purport to do the same; or are subject to the appointment of a receiver, administrator or liquidator; or are unable to pay Your debts as they fall due;

5.1.7.  You receive funding from any other source for the Eligible Expenditure which is funded by the Grant;

5.1.8. You are involved in illegal activity in Your administration of the Project;

5.1.9.  You take any actions which in LCF’s reasonable opinion are likely to bring LCF’s name or reputation, or that of the government, into disrepute, or which pose a risk to public money; or

5.1.10. You are otherwise in material breach of Your Grant Agreement.  

5.2. If an Event of Default occurs, LCF may, at our discretion:

5.2.1. suspend and withhold the payment of Grant for such period as LCF may determine;

5.2.2. require Your organisation to repay all or any part of the Grant that has been paid to You (or such lesser amount as LCF may determine) by issuing a demand for repayment. Prior to issuing such a demand, LCF may (at Our sole discretion) give You an opportunity to rectify such breach or occurrence.

5.2.3. terminate this Grant by serving written notice where the Event of Default is incapable of being remedied or is not remedied within such reasonable period as LCF may determine.    

Privacy notice  

This Privacy Notice explains your rights and gives you the information you are entitled to under the Data Protection Act 2018 and the General Data Protection Regulation (“the Data Protection Legislation”). Note that this section only refers to your personal data that we process (e.g. the details of individuals at your organisation - name, date of birth, home address, email address, phone number, and the details of your organisation’s finances).  

Who controls the information you provide?

The grants for this programme will be made from funds raised by the National Emergencies Trust public fundraising appeal, of which £20 million is provided by The Office for Civil Society, a directorate of the Department for Digital, Culture, Media and Sport (DCMS). This means that not all of the grants will be from DCMS funds.  

The funds are passed to UK Community Foundations (an umbrella organisation) and then onto the 50 Partners of UK Community Foundations including The London Community Foundation.  

Why are we collecting and processing your personal data?

At application stage, LCF processed contact details of an individual at your organisation and the details of Your organisation’s finances which you provided within your application to the London Community Response Fund.  This was in order to undertake organisational checks for the purposes of grant making and fraud detection, and to maintain contact with a representative of the applicant throughout the application process and if successful, during the programme.  

Further personal data may be collected if, as outlined in the Audit Sample clause above, Your organisation is selected as one of the audit sample.  This additional information sought will be processed by DCMS, or an organisation acting on its behalf, to conduct further organisational assurances after the grants have been made (this is called “post grant award assurance”).  

We would usually conduct robust checks before grant making but because of the urgency of the COVID emergency situation it can often be difficult to put in robust up front controls, because of the speed that we have to operate at. This grant making process will therefore be supported by a robust post grant award assurance activity.  

Who will we share your personal data with?

Your data will be shared with UK Community Foundations and DCMS for the purposes of post grant award assurance activity to enable DCMS, or an organisation acting on its behalf, to identify funds that have been paid in incorrectly, either because of fraud, error or if a grant duplicates a grant made by another funder.  

LCF may share your personal data with DCMS, and/or organisations acting on its behalf who have been appointed to monitor and evaluate this programme or that conduct organisational checks and verifications for fraud or error detection at the end of the programme. We will only share personal data which they need to carry out their work and subject to appropriate security measures. 

Our legal basis for processing your personal data

DCMS, UK Community Foundations and LCF are processing your personal data for a task carried out in the public interest  


LCF, UK Community Foundations and DCMS take all reasonable steps to keep personal data in its possession or control, which is used on an on-going basis, accurate, complete, current and relevant, based on the most recent information available to us. If we are advised of a change in information, we will update the data accordingly.  

We rely on you to notify us of any changes to your personal data.  

Security of personal information

We are committed to taking all reasonable and appropriate steps to protect the personal information we collect from you from improper use or disclosure, unauthorised access, unauthorised modification, and unlawful destruction or accidental loss. We have taken and will take appropriate information security, technical, storage and organisational measures to such end, including measures to deal with any suspected data breach. All providers who are associated with the processing of your information are obliged to respect the confidentiality of your personal data.  

Your personal data will not be sent overseas and will not be used for automated decision making.  

Deletion procedure

Any application data collected during the application process, potentially including individual contact details, will be retained by LCF only for as long as LCF has a legitimate interest to do so.   

Any further personal data collected from those organisations selected as one of the audit sample within three months of the completion of the programme.  This additional information sought will be processed by DCMS, or an organisation acting on its behalf, to conduct further organisational assurances after the grants have been made (this is called “post grant award assurance”).    

Your rights, e.g. access, rectification, erasure

Some of the data we have collected from your application form to the London Community Response Fund, and any subsequent collection of data required as part of the Audit Sample clause process, is your personal data, and you have the right:

  • To see what data we have about you
  • To ask us to stop using your data, but keep it on record
  • To ask us to stop using and delete your data in certain circumstances
  • To have all or some of your data corrected
  • To lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law. 

You can contact the ICO at:


Telephone: 0303 123 1113. ICO,

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.  

Should you have any concerns or wish to exercise the rights outlined above in respect of the personal data which: