This statement, effective from 25th May 2018, explains how the Development and Alumni Relations Department (“Development Department”, “we” and “our”) at Westminster School handles and uses data we collect about our alumni, their parents/guardians, former staff (“friends”), and our past, current and future supporters (“you” and “your”).
The Development Department has responsibility for alumni relations, supporter events and charitable giving to Westminster School. We keep you updated with current and future events, publications, volunteering opportunities and fundraising campaigns. We promote relationships between you and other members of the Westminster Community, for example matching Old Westminsters for careers and mentoring. We also fundraise to support the School’s bursary provision, enhance resources and enable capital projects.
We have created this statement in order to demonstrate Westminster School’s firm commitment to your privacy and to meet the requirements of the General Data Protection Regulation (GDPR). Personal data collected by the School is handled responsibly in accordance with the School’s Data Protection Policy, Records Management Policy and Records Retention Policy which are available upon request.
Please also see the School’s overarching Privacy Notice for all aspects of data processing beyond Development and Alumni Relations on the Westminster School website: westminster.org.uk/privacy.
What sort of personal data does the Development Department hold?
The personal data that we hold will typically include some, or all of: your name, postal and email address, phone number, date of birth, gender. We may hold your credit card details where needed to process donations or event fees. We also record information needed to claim Gift Aid on donations. For alumni, we record details of admission and leaving dates, House and university destination. Every time you get in touch with us, we get in touch with you, or you take part in any Westminster School activity, we record this touchpoint on your record.
Where provided by you, or from publicly available and reputable sources (e.g. Companies House, the Charity Commission and other charity registers, Who’s Who and Debrett’s guides, the Electoral Roll, company websites and biographies on professional networking sites, social media platforms such as LinkedIn or Twitter, publications, news articles and media coverage such as the Queen’s Honours List and The Times Rich List , geographic and demographic information based on your postcode, the National Change of Address File), we also record:
- Updates to your contact details
- Family details and key relationships with other Old Westminsters or supporters of the School
- Your career highlights, life achievements, areas of personal interest and philanthropy history
- Personal data provided by you for a specific purpose (e.g. accessibility needs or dietary requirements for event management)
- Communication preferences
- Volunteering by you on behalf of the School
- Information about your wealth
- Media articles about you
- Information on your engagement in School meetings, events, groups or networks
Inclusion of this data allows us to segment our database and gives us a better understanding of the Westminster Community (see ‘How we use your personal information’ below for more details). We do not take data that you have posted in a private environment.
We always aim to keep your details up to date, and we will check the contact details we have for you are correct and, where appropriate, update them.
Photographs and videos
We may use photographs or videos of you on the School’s website, on social media sites or in marketing literature to advertise the School. If you have any concerns, please contact firstname.lastname@example.org.
How does the Development Department collect my personal data?
- When it is provided to us directly: The Development Department maintains a database that contains personal data obtained by Westminster School directly from you or your parents/guardians at the time of admission and day of departure. This data is transferred from the school’s pupil database on a regular basis.We also gather personal information from you when you interact with us, for example when you enquire about our activities, correspond with us by email, sign up to an event, make a donation, volunteer or sign up to a campaign or for a newsletter. Information may be collected in person, over the phone, through our websites, social media or from something you have sent to us.
- When it is available publicly: We collect most of the personal data we process directly from you, but sometimes we collect data from publicly available sources too. Please see ‘What sort of personal data does the Development Department hold?’ and ‘How does the Development Department use my personal data?’ for further details.
- When someone you know refers you to us: On occasion, someone you know, for example friends, family or a business associate, may give us your name and contact details as someone who might wish to support a Westminster School project. We will contact you as soon as is practicable to let you know we are processing your data in the way outlined in this statement.
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How does the Development Department use my personal data?
Your data is used by us for a number of interdependent purposes including alumni relations, communications, organising events and fundraising. We will use your data to:
- Provide you with the services, products and information you have asked us for, including publications such as The Elizabethan Newsletter for alumni or impact reports for donors
- Send you information about activities we believe are most relevant to you, including both financial and non-financial ways to support, such as offering careers advice for Old Westminsters and sharing your expertise through School Careers Panels
- Let you know about forthcoming Westminster Community events
- Administer any donations you make or support your own fundraising activities for the School
- Claim Gift Aid from the HMRC on any of your eligible donations
- Ensure we know how you prefer to be contacted
- Understand how we can improve our services or information
- Create an account for you if you register with us
- Keep a record of your relationship with us
Building profiles and targeting communications
The Development Department aims to approach members of the Westminster Community in a considerate manner when looking for support and it is therefore important that we understand our database of supporters. In order to provide you with the best experience and determine how we can most meaningfully engage with you, we undertake analysis on your personal data. This analysis helps us to gain a better understanding of your interests, preferences, what your potential to give to the School might be and what your level of engagement with the School has been to date. It also reveals broader demographic and geographic trends amongst our Community.
We may profile and categorise individuals using automated or manual analyses, so that we can tailor our communications and make appropriate requests for support, making the most efficient use of our resources. For example, we might create a rating of your level of engagement, considering your likely ability to give and your interest in making a donation to the School. In order to do this, we would review all your interactions with the School such as event attendance and donation history, and geodemographic data and measures of affluence, where available from publicly available sources (see ‘What sort of personal data does the Development Department hold?’ section above).
We may also share your data with one of our trusted third-party suppliers, subcontracted to help us carry out this type of research in the most time and cost effective way, in accordance with the strict guidelines set by the GDPR and Fundraising Regulator. Publicly available information also helps us to find new potential supporters, for whom the charitable activities at Westminster School might be a good fit, so that we can invite them to find out about opportunities to get involved.
Please contact us if you do not want us to undertake profiling of this kind. Before seeking or accepting major donations we are required, however, to conduct appropriate due diligence, including reviewing publicly available personal data and information relating to the donor.
How is my personal data kept secure?
We ensure that there are appropriate technical controls in place to protect your personal details; for example our online forms are always encrypted and our network is protected and routinely monitored. We use a secure server when you enter into any money transaction from our website. We also take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. Personal information is stored on a secure database which is password protected, with access limited to appropriately trained staff in the Development Department.
With whom do we share your personal data?
We may share data occasionally on a considered and confidential basis, where appropriate under contractual confidentiality agreements, with:
- Selected members of school staff for specific reasons (most usually the Head Master, the Bursar, the School Archivist or the Head of Careers and Mentoring)
- Volunteers closely related to us (e.g. School Governors, Development Board members, Alumni Group representatives and US Foundation Board Directors based in the USA – see note below on countries outside of the EEA)
- Third party agencies who provide us with data in the public domain about you
- Contractors providing services to you on our behalf or services to us (our “data processors”), including, but not limited to, Blackbaud Inc (leading supplier of software and services to charities), Asendia (mail processing house), Lavenham Press (mail processing house), Graham-Pelton (UK) (fundraising consultants) and Buffalo Fundraising Consultants (who provide Donor Debit, online processing for direct debits) as at July 2018
- Government departments, particularly HMRC
Should you choose to attend an alumni event organised by the school your name, dates at the school and house along with the names of any guest(s) will be shared with other attendees unless you decide to ‘opt-out’ at the point of registration. We also facilitate communication between individual Old Westminsters, but in doing so we will never release your personal contact details without your permission first.
If you make a donation to Westminster School, you are given the option of deciding whether your name can be used in donor lists and other stewardship materials. If you consent to this, we may publish your current name and the fact that you are a Westminster School donor. We may need to disclose your details if required to the police, regulatory bodies or legal advisors.
We will never sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them.
How long do you keep my personal data?
Westminster School’s Development Department considers its relationship with our alumni, friends, donors and stakeholders to be lifelong, and we will keep hold of your details until you tell us you no longer wish to hear from us. In this instance, the Development Department will delete the majority of your personal data it holds, but will maintain basic personal data to ensure that we do not inadvertently create a duplicate record in the future.
In addition to the above, we will take into consideration our legal obligations, and tax and accounting rules, when determining how long we should retain your information. When we no longer need to retain your information we will ensure it is securely disposed of, at the appropriate time.
Records considered to be of historic value are retained in the School’s archive indefinitely. Personal data concerning living individuals, which is not in the public domain, is unavailable to researchers, unless the subject of the information provides written consent.
Our legal basis for contacting you and processing your personal information
The Development Department processes the information outlined in this Privacy Statement in pursuit of our legitimate interests in:
- Communicating with members of the Westminster Community: pupils, alumni, current and former staff, current and former parents and current and potential supporters
- Providing benefits and services to members of the Westminster Community
- Furthering Westminster School’s educational charitable mission (which includes fundraising and securing the support of volunteers)
- Enabling the School to achieve its strategic and operational goals
We may pursue these legitimate interests by contacting you by telephone, email, post or social media. Information about how you can manage the ways that we contact you, including how to opt out from some or all contact from the Development Department, is outlined in the ‘Your preferences and your rights’ section below.
Whilst we rely on legitimate interest as the legal basis for processing where this is not overridden by the interests and rights or freedoms of the data subjects concerned, we recognise that it is not the only lawful ground for processing data. As such, where appropriate, we will sometimes process your data on an alternative legal basis – for example, because you have given us consent to do so.
In certain circumstances, we may process your personal data in reliance on your consent, for example in relation to some electronic communications.
Your preferences and rights
If you do not wish to receive the School’s publications, updates and invites to our events, or any direct marketing communications from us about the vital work we do for the School, then please let us know at any time by contacting our Development Department.
We will not contact you for marketing purposes by post, email, and phone or text message if you have told us you do not want to hear from us by any of those channels. If the telephone number we hold for you is registered with the Telephone Preference Service (TPS), then we will only contact you on that phone number for administrative purposes, unless you have actively opted in to hearing from us by telephone.
If you unsubscribe from any or all of the communication channels mentioned above, we will update our records to stop further communication as quickly as we can. Due to some communications already being in progress at the point you opt out, please be aware that it can take several weeks for your preferences to be fully implemented. Where you opt out of all future communications or exercise your right to erasure, we will continue to maintain a core set of personal data (name, house, admission and leaving dates, unique identification number and date of birth) to ensure we do not contact you inadvertently in future. We may also need to retain some financial records about you for statutory purposes (e.g. Gift Aid, anti-fraud and accounting matters).
You have the right: to ask us for a copy of your personal data (a data subject access request); to object to processing that is causing you, or is likely to cause you, damage or distress; to object to any form of communications or direct marketing; in certain circumstances to require us to correct or erase your personal data.
You have the right to ask us to stop processing your personal data in cases where we are relying on our legitimate interests, and if it is not necessary for the purpose you provided it to us for (e.g. processing your donation or registering you for an event) then we will do so. You also have the right to withdraw your consent.
Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where some exceptions apply.
Westminster School is a voluntary member of the Fundraising Regulator and we continually review our practices to respect the privacy of our alumni, friends and supporters.
You can find out more about your data protection rights on the Information Commissioner’s Office (ICO) website. Please do raise any issues you have about how we are processing your personal data with us and you can, of course, also raise a complaint with the ICO at any time if you are not satisfied.
Changes to this privacy statement
The terms of this Privacy Statement may change, so please check it from time to time. Any substantial changes that affect how we process your personal data will be published on our website and communicated to you directly, as appropriate and as far as practicable. You can see the date this Statement was last updated at the end of the document.
Should you wish to change your preferences, update your details or discuss any queries you might have in relation to your rights or our policies in general, please contact us:
The Development Office
17A Dean’s Yard
020 7963 1122
Updated July 2018