Fundraising and Development Privacy Notice

Fundraising and Development Privacy Notice

HOW WE USE YOUR INFORMATION

Introduction

This Notice explains how and why our Development Office collects personal information about you for our fundraising and development activities.  It also outlines what we do with your information and what decisions you can make about your information in relation to fundraising and development. If you have any questions about this, please contact the Development Director whose contact details are at the end of this Notice.

Our relationship with our parents, alumni (Old Stortfordians), friends and supporters is of great importance to the College, especially with regard to respecting their privacy and data security.  We also value the philanthropy and generous support of those who support our academic mission.

This Notice only relates to Personal Data processed by the Development Office. It is the College department  that has responsibility for alumni relations, reunion events, fundraising and charitable giving.  We consider the College has a strong legitimate interest in maintaining relationships with parents, alumni, friends and supporters for the benefit of its fundraising and development activity and to help safeguard our future. We also wish to balance this against your personal privacy choices.

Development is the careful relationship building between the College and its supporters, with the long term aim of securing financial support for our work.  Development offers a range of communications and events to help facilitate the “friendraising” process.   

This Notice also covers how the personal information of College alumni is used. The College controls all Personal Data of alumni as the Data Controller. Names of alumni may occasionally appear in the OS Newsletter and their contact details used for communications. Personal Data is also shared with the Development and Fundraising Office in line with data protection regulations.

Individuals can ask for all or part of their details not be used by contacting the Development Office. For more information about how the College uses your information more widely (for example, in relation to the provision of education to pupils) please ask the Assistant Bursar and Data Protection Lead for a copy of the appropriate Privacy Notice.  Their contact details are at the end of this Notice.

What personal information does the College hold about you and how is this obtained?

Personal information is that which identifies you as an individual and specifically relates to you. This includes your contact details, your relationship with the College and financial information.

The College receives information about you from other teams within the College but only where this is relevant to our work.  The Development Office holds a specific database with information about alumni, parents, staff, former parents, former staff and other supporters. 

You provide us with information about yourself during the course of our relationship with you e.g. when you fill in a survey, or sign up to attend an event. Additionally, we will obtain your information from other sources.  These may include LinkedIn, Zoopla, Companies House, Bloomberg, Facebook, Twitter, media articles and your company website. These sources help ensure we communicate with you in the most appropriate way.

We will hold information such as;

  • the dates when you or your child attended the College (if applicable);
  • if you are a former staff member the dates when you worked with us;
  • your contact details;
  • information about your achievements and interests e.g. the sports teams you were part of as a pupil;
  • where you attended university and your occupation (if applicable);
  • your communications preferences;
  • records of any donations;
  • your Gift Aid status if applicable;
  • information from articles in the media;
  • any dietary requirements for catering purposes that you have provided; and
  • any disability you may have so that we may make reasonable adjustments for you.

Why do we use your personal information?

We use your information in the following ways to;

  • keep you informed of events and activities and if you attended any events;
  • help communications between the College and alumni, we provide an online portal called Stortfordians Connect;
  • keep you informed about what is happening at the College e.g. sending you a copy of College magazines;
  • provide opportunities for you to consider financial support to the College (including making donations to specific campaigns e.g. a new Sports Centre or requests for sponsorship); 
  • suggest other ways you might wish to support the College (such as when you volunteer); and
  • sometimes contact alumni to find out how their careers progress so we can refine our careers and University advice to pupils.

We will contact you for the above purposes by email, telephone, post or by text message but we will only do this where we are allowed to do so under data protection law (e.g. we will usually need your consent before sending you an email about a fundraising opportunity).  If you tell us that you do not want to be contacted for any of these purposes then we will respect that decision.  As an exception, we will not send you fundraising communications by email and we will not call any telephone preference service registered numbers about fundraising opportunities.  However, we will still send other types of communication by email, such as newsletters. 

If you wish to make a donation, we may carry out financial due diligence on you using sources as described above, this is to comply with our legal obligations.

We may take photographs or videos of you to use in our publicity or on our social media platforms and website unless you would prefer us not to.

We will carry out a targeted fundraising activity to ensure we are contacting you with the most appropriate communication and will provide an improved experience for you. In doing so, we may use profiling techniques or use third party wealth screening companies and insight companies to provide us with information about you. 

Such information is compiled using publicly available data about you such as those already described. This assists us in understanding the financial means and background of those who could support us. It also helps us make appropriate requests to supporters who may have the means and who may want to give more.  You can opt out of your data being used for profiling and wealth screening techniques by contacting the Development Office.

How and why does the College share your personal information with third parties? 

  • We have a website that collects credit card/Paypal gifts and one for Direct Debit gifts.
  • If you attend a College event, we may share your information with event booking platforms,
  • In accordance with our legal obligations, we will share information with local authorities, the Independent Schools Inspectorate and the Department for Education.
  • On occasion, we may need to share information with the police for the prevention and investigation of crime and the prosecution of offenders.
  • We may also need to share information with our legal advisors for the purpose of obtaining legal advice.
  • We will need to share information if there is an emergency, for example, if you are hurt whilst on College premises or at one of our events.
  • We use contractors to help us with our work (e.g. a company will be used to process Personal Data so that we can post your paper copy communications) or where we store our database in the cloud. 

Our legal grounds for using your information

This section contains information about the legal basis that we rely upon when handling your information. 

Legitimate interests

This means that we are using your information when this is necessary for our legitimate interests, except when your interests and fundamental rights override our legitimate interests.  Specifically, we have a legitimate interest in;

  • ensuring there are active supporters who will benefit the College, such as current and former pupils and parents;
  • promoting our objects and interests. This includes fundraising e.g. if we want to raise money for new buildings;
  • using your personal information to administer our events;
  • safeguarding and promoting the welfare of our pupils with whom you may have contact; and
  • ensuring that we comply with our legal obligations.

If you object to us using your information where we are relying on our legitimate interests as explained above, you can inform us. If we ask for your consent to use your personal information you can take back this consent at any time.  Any use of your information before you withdraw your consent remains valid. You can withdraw your consent by contacting the Development Director.

Necessary for a contract.

We will need to use your information in order to perform our obligations under a contract with you e.g. we may need your name and contact details to send you tickets for a concert that you are attending. 

Legal obligation

Sometimes, we will need your information to comply with a legal obligation e.g. we may need to keep a record of who is attending an event so that we can comply with our health and safety obligations. 

Vital interests

For example, to prevent someone from being seriously harmed.

The College must also comply with an additional condition where it processes special categories of personal information.  These include personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information, and information about sex life or orientation. 

Our grounds for processing special personal information will depend on the circumstances.

Vital interests

To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.

Legal claims

The processing is necessary for the establishment, exercise or defence of legal claims.  This allows us to share information with our legal advisors and insurers.

These two conditions may also apply if we ever need to process information about criminal convictions and offences.

Sending your information to other countries.

We may send your information to countries which do not have the same level of data protection as the UK e.g. we may;

  • store your information on computer servers based overseas; or
  • communicate with you when you are overseas (for example, when you are on holiday or if you live in a different country). 

The EU has produced a list of countries which have adequate data protection rules. 

If the country that we are sending your information to is not on the list, or is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland), then in the absence of any other safeguards, it might not have the same level of protection for personal information as there is in the UK. 

Where appropriate, we use additional safeguards e.g. if we are using a third party to process a payment then we may contact them to use a data sharing agreement.  If you would like more information about this please contact the Assistant Bursar.

For how long do we keep your information?

We will keep your information for as long as we need, in compliance with our data protection and other legal obligations e.g. we will need to keep your contact details for as long as you want to be in communication with us. 

We also need to keep a record if you tell us not to contact you anymore, so that we do not inadvertently add you to our mailing list.  We will keep information about you for a long time or even indefinitely if we need this for historical or research purposes.

The College will also keep information for a long time as part of its wider legal and regulatory obligations, even if that information is no longer needed for marketing, development or fundraising purposes.  This is especially relevant to former staff, pupils and parents.  Our Information and Records Retention Policy sets out how long we keep different types of information.  For more information on how personal information is used by the College more widely, please contact the Assistant Bursar and Data Protection Lead.

What decisions can you make about your information?

From May 2018 data protection legislation gives you a number of rights regarding your information.  Some of these are new whilst others build on your existing rights.  Your rights are as follows: 

  • Rectification: If information is incorrect you can ask us to correct it.
  • Access: You can also ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to.
  • Deletion: You can ask us to delete the information that we hold about you in certain circumstances e.g. where we no longer need the information.
  • Portability: You can request the transfer of your information to you or to a third party in a format that can be read by a computer in certain circumstances.
  • Restriction: Our use of information about you may be restricted to simply storing it in some cases.  For example, if you tell us that the information is inaccurate, we can only use it for limited purposes while we check its accuracy. 
  • Object: You may object to us using your information where;
    • we are using it for direct marketing purposes (e.g. sending you letters about fundraising opportunities);
    • we are relying on the legitimate interests legal ground to use it; or
    • we are using it for historical or scientific research purposes or archiving purposes.  For example, we may keep photographs of your class for historical reasons.

The Assistant Bursar and Data Protection Lead can give you more information about your data protection rights. 

Further information and guidance

The Development Director is the person responsible at our College for managing how we look after personal information in relation to fundraising and development.

Like other organisations we need to keep your information safe, up-to-date, only use it for what we said we would, destroy it when we no longer need it and most importantly, treat the information we get fairly.

Please speak to the Development Director if; 

  • you object to us using your information for marketing purposes e.g. to send you information about fundraising; to use for profiling/wealth screening purposes.  We will stop using your information for these purposes if you tell us not to;
  • or you would like us to update the information we hold about you.

If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office

Contact Details:

Development Director for fundraising enquiries:

Assistant Bursar and Data Protection Lead for general enquiries: