Purpose of this Notice
This Notice explains how the Development Office will collect and use your personal data for alumni and development activities. Please see below more information on the alumni activities covered by this Notice. Throughout this Notice, “Development Office” “we”, “our” and “us” refers to the High School of Glasgow Development Office. “you” and “your” refers to School alumni, parents, together with other members of the School community. We are the data controller for personal data that we process about you.
Change in the law
Until 24 May 2018 we shall process your personal data in accordance with the Data Protection Act 1998 (or DPA for short). From 25 May 2018, we shall process your personal data in accordance with the General Data Protection Regulations (or GDPR for short).
This Notice complies with requirements under both DPA and GDPR.
Changes to this Notice
Prior to the implementation of GDPR, we are likely to make changes to this Notice. We shall inform you of any changes to this Notice.
Anything you are not clear about
If there is anything you are unclear about, please contact our Data Protection Officer, who shall be happy to answer any queries you may have concerning this Notice or the way in which we process your personal data. The Data Protection Officer’s contact details are provided at the end of this Notice.
Where does the Development Office get your personal data from?
We obtain personal data regarding you from the following sources:
- For Parents via a transfer from the School’s MIS database to the alumni database upon enrolment to the School
- For Pupils via a transfer from the School’s MIS database to the alumni database upon leaving, provided your permission is granted.
Data you provided when you:
- provided information through our website: www.highschoolofglasgow.co.uk, volunteering discussions or donations
- completed and returned surveys or response forms such as contact preference forms, donation/Gift Aid forms
- communicated with the Development Office
- registered to attend an alumni/Development Office related event
Third party sources
- from third party sources such as organisations that assist us with pursuing our purposes described below, media articles, company and, charity filings or social networking posts or other public sources for example the internet.
Categories of personal data being processed
We will collect and process personal data about you. The data we may process includes:
- your title, name (including former name or alias), gender, date of birth
- your High School education record (i.e. class of, year of entry/leaving, House, captain/prefect information) but we do not retain any transcripts, further information can be found in our data retention policy.
- your contact information (address, telephone, email, social media)
- your business details including positions, organisation, professional memberships and qualifications
- your career highlights and other lifetime achievements
- your outside interests and membership of groups
- information about your wealth
- information from articles in the media about you
- your family details, including spouse or partner, and relationships with other alumni, supporters and potential supporters
- events you have been invited to and whether or not you have responded or attended
- your donations of time, expertise or money
- we will keep a record of interactions with you for future reference and to help tailor further communications with you; as part of this, some emails sent by the Development Office may record whether the email has been opened and whether any links have been clicked on
- generally information that you have decided to share with us
The purposes for which we process your personal data
We will use your data to help us maintain an engaged High School community. Please see the “Communications” section for information on the communication that we may have with you. We may also process your personal data for the following purposes:
- to process a gift you have given (and any Gift Aid claims)
- event registration
- to process and organise any volunteering activity you have agreed to undertake
- to process information you provide for use on our School website or publications
- to keep a record of communications between you and us
Fundraising and volunteering
- bursaries for our Senior School pupils
- improvements to the School’s facilities
When organising reunions, we sometimes share ‘Class of’ lists with reunion organisers which detail the first name, surname and leaving year which highlights individuals who left from the same year. These lists are used to remind alumni about their year group and to establish who to invite to the planned event. Details usually indicate who the School is in contact with and who is deceased
The information can also help the Development Office to make contact with alumni we may have lost touch with. Individuals with whom the lists are shared are asked if they are in touch with anyone on the list and, if appropriate, asked to approach these individuals to establish if they would like to receive communications from the School.Page Break
To ensure that we do not make inappropriate requests in our fundraising and volunteering communications, we may carry out research to assess your likely ability and willingness to make gifts to or volunteer for the School.
This research may include collecting and storing data relating to you that is in the public domain (such as career history, directorships, shareholdings and remuneration) as well as data that has been provided by you, including your interests, and School activity you have previously been involved with (donations, volunteering, event attendance etc.) This research is sometimes known as prospect research or wealth profiling.
In addition to conducting this research in-house, we may use approved third party analysts to carry out what is known as wealth screening. Drawing entirely on data held in the public domain, wealth screening companies are used to identify those high net worth individuals who may be interested in supporting the School with a significant philanthropic gift. This process allows the Development Office to use its resources efficiently and guard against unnecessary contact.
If we are using a third party data analyst the company’s analysts are allowed to use your data only in accordance with the strict instructions of the School. The data must be held confidentially and securely and only used for the approved wealth screening activity. Your data will only be kept for as long as necessary and will then be destroyed.
Profiling and planning
We use your data (such as your postcode, age, gender and level of engagement with the School) to help us plan our activities, and determine if we should contact you with certain communications, or information about particular activities. It helps us identify how our alumni are involved with the School, and which alumni activities are most popular. This research helps ensure our communications (including fundraising or volunteering requests) are relevant and of interest to you.
Your data may when, anonymised and no longer constituting personal data, be used to support alumni activities.
Please note that if you wish to make a gift to the School we may process your personal data, including information from the public domain, for due diligence purposes.
Keeping your data up to date
We will update the data we hold on you from time to time. For example, if you provide us with new contact details or change your details on the School website, or social media sites such as LinkedIn. We will respond to your request for your data to be updated.
If you would like your data to be updated please either email: firstname.lastname@example.org, or call: 0141 954 9628.
We may update your contact details by using third party sources/services such as Royal Mail NCOA (National Change of Address). We also use these services to check if there are people we should no longer contact (for example, if someone has died). Where third parties provide these services to us they are only allowed to use your data in accordance with the strict instructions of the School. The third party is required to hold the data confidentially and securely and will not use your data in any other way. Your data will only be kept for as long as necessary and will then be destroyed.
Who can see your data?
Your data is held securely within the Development Office. Access is strictly controlled and staff receive training on data protection.
In addition to third parties helping us keep your data up to date, in order to boost functionality and efficiency, we may employ IT experts from outside of the School to aid with the development of our systems. They may have access to information which is necessary to complete the specific task for which they are appointed. These experts will provide their services in accordance with the strict instructions of the School. In particular they must respect confidentiality and to the extent they do need to temporarily hold any data, that data must be held securely, strictly used only for the agreed purpose, kept for only as long as necessary and then destroyed.
We also facilitate communications between individual alumni, but in doing so we do not release personal contact details without prior permission.
We will not sell or share your data to third parties for their commercial purposes.
We will from time to time communicate with you by email, post, telephone and social media to pursue the purposes mentioned above. In particular we regularly communicate with people for the following purposes:
- share news about the School and our alumni
- invite you to events and reunions
- invite you to support our fundraising activity
If you are unsuccessful in unsubscribing from our communications and/or remain concerned, please contact our Data Protection Officer (see later contact details).
Sharing your data involving other countries
Sometimes to achieve the purposes for which we are processing your personal data we may need to share your personal data with other organisations based within the European Union or if outside the European Union based in countries that have comparable levels of protection.
When it is necessary to share your data with organisations outside of the European Union, we will ensure that there are appropriate safeguards in place.
We see being a member of the School and part of the alumni community as a lifelong relationship. Generally the School will look to retain alumni personal data until the individual asks us to remove it from our records. We will routinely remind you of your right to have us remove your personal data.
If you decide that you no longer wish to receive communication from the School please be aware that we still need to retain a minimal amount of personal data so that we can keep a record that you have asked us not to contact you.
Your rights as a data subject
Under GDPR you have the right to:
- withdraw consent where that is the legal basis of our processing
- access your personal data that we process
- rectify inaccuracies in personal data that we hold about you
- be forgotten, that is your details to be removed from systems that we use to process your personal data
- restrict the processing in certain ways
- obtain a copy of your data in a commonly used electronic form; and
- object to certain processing of your personal data by us
Please see: www.ico.org.uk for further information on the above rights. You may also contact the Data Protection Officer for further information.
You have a right to complain to the Information Commissioner’s Office about the way in which we process your personal data. Please see: www.ico.org.uk
The School Development Office is committed to fundraising in a transparent, responsible and honest way. We are registered with the Fundraising Regulator and have committed to follow the associated Code of Practice.
Legal basis for processing your data under GDPR
GDPR is a new law and it has not yet been applied to circumstances similar in context to our relationship alumni. The extent of lawful grounds for processing data has yet to be fully understood. As legal views mature the School may change its views on its legal basis for processing.
The School will sometimes process your data based upon your consent.
Sometimes the School will be processing your data because you have clearly made it publicly available.
Finally, the School believes that its activities are necessary for the purposes of the legitimate interest of the School and other third parties. These interests are not overridden by the interests and fundamental rights or the freedoms of the data subjects concerned. Legitimate interests of the School and third parties focus around supporting educational activities and ongoing developmental activities for School alumni and others.
It is recognised that some of the above grounds will overlap and that the School could rely on multiple grounds justifying its lawful processing.
Concerns and contact details
If you have any concerns with regard to the way your personal data is being processed or have a query with regard to this Notice, please contact our Data Protection Officer, Chris Castell at email@example.com
Our general postal address is The High School of Glasgow, 637 Crow Road, Glasgow G13 1PL
Our telephone number is 0141 954 9628
Our data controller registration number provided by the Information Commissioner’s Office is Z6483284.
Last updated: 11/04/2018