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Alumni, Donors and Stakeholders Privacy Notice

Introduction

Our alumni and supporters are extremely important to us, and this Privacy Statement explains how the University of Warwick collects, stores, manages and protects alumni, donor and stakeholder data. It outlines the types of data that we hold and how we use them to provide services to our alumni and supporters. We aim to be clear when we collect your personal information, and not do anything you wouldn’t reasonably expect.


The Engagement Group and What We Do

The Aim of the Data Protection Regulations

Definitions

Our Responsibilities

Basis of Data Processing

Consent to Alumni and Fundraising Communications

What Personal Data We Collect

How We Collect Your Personal Data

How We Use Your Data

Your Rights

How We Protect Your Data

Retention

Contact Us

How to Complain

Exactly How We Use Your Data and What We Hold

Future Changes

Additional Help



THE ENGAGEMENT GROUP AND WHAT WE DO

The Engagement Group is part of the University of Warwick and supports the universities objectives through engaging with alumni, students, supporters and stakeholders of the University. We do this by offering a range of academic, social and networking events and by providing access to University library resources, publications and careers advice for graduates. We also fundraise to support the University’s students, teaching, research and capital projects.

Fundraising is a key part of the Engagement Group’s work, and we are committed to working in a transparent, ethical, responsible and honest way. To reflect this commitment, we are a member of the Fundraising Regulator and committed to the Regulator’s Code of Practice.

We value our relationship with you and we use your personal data to ensure we communicate with you in the most appropriate way, to improve our services and to ensure we work efficiently and effectively. In order to do this, we have a database that contains personal data collected by the University during the course of our relationship with our students, alumni, donors and stakeholders.



THE AIM OF THE DATA PROTECTION REGULATIONS
Until 24 May the Data Protection Act 1998 governed your rights to your data and provided the relevant guidance for the University of Warwick to process your personal data. As of 24 May 2018 your rights and the way in which data is processed is governed by the General Data Protection Regulation (the “GDPR”).

The GDPR has been introduced to unify the differing laws and regulations across the EU in order to provide a primary source for your data protection rights and the basis for the processing of your data.

Furthermore, The Privacy and Electronic Communications (EC Directive) Regulations 2003 (the “PECR”) also applies as we market by email and phone.



DEFINITIONS
References to “UOW”, “University”, “we”, “our” and “us” refers to University of Warwick.
References to “you” and “your” refers to the alumni, donors and stakeholders of UOW.
The Data Protection Act 1998 shall be referred to as “DPA”.
The General Data Protection Regulations will be referred to as “GDPR”.
“Personal data” is any information that identifies you. It can also include expressions of opinions about an individual.
“Sensitive personal data” is any information that identifies racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
A “Data subject”, is you – if we hold personal data about you.



OUR RESPONSIBILITIES

As part of our work we process and store personal data on our students, staff, alumni, donors and potential supporters and friends of the University. We take our responsibilities under the GDPR seriously and ensure that the personal data that we obtain is held, used, transferred and processed in accordance with the applicable data protection laws.

BASIS OF PROCESSING DATA

PERSONAL DATA
The UOW lawfully processes your personal data under the following circumstances:
a) Processing is necessary for the purposes of the legitimate interests.

SPECIAL CATEGORY (SENSITIVE PERSONAL DATA)

The GDPR places much stronger controls on the processing of special category data. We only process sensitive data in the following circumstances:

a) Explicit consent - The individual has given explicit consent. However, Union or Member State law may limit the circumstances in which consent is available.
b) Not for profit bodies - The processing is carried out in the course of the legitimate activities of a not-for-profit body and only relates to members or related persons and the personal data is not disclosed outside that body without consent.
c) Public information - The processing relates to personal data which is manifestly made public by the data subject.

LEGITIMATE INTEREST

Under the GDPR the University considers that the legal basis for processing your personal data, for the purposes of alumni engagement and/or fundraising, is legitimate interests.

The University of Warwick’s core mission is to advance education, knowledge and learning through teaching and research. Now more than ever, with changes in the way higher education is funded, our students (past, present and future) and our communities, have an expectation that we will work in partnership with them to enable them succeed academically, but also to champion social, cultural and economic growth and secure our future sustainability. We do this through a variety of teaching, student, research, community and capital projects, which our alumni engagement and fundraising activities are designed to support. As such, we have a legitimate interest in engaging with our alumni, donors and potential supporters to enable us achieve these goals.

Alumni engagement and fundraising are not new to Warwick. Since we were founded, we have been shaped by the generosity, support and friendship of individual donors, business partners and charitable organisations. In the 1960s, under the leadership of prominent businessman and Chancellor Designate, Lord Rootes, a group of visionary community leaders raised the largest amount generated by any of the new universities created at that time (£4 million) the University of Warwick was born. At the time, their mission was to establish a university that would boost skills and business innovation in the heart of Britain’s highly successful manufacturing sector. Now, just over 50 years later and firmly established as one of the UK’s leading universities, Warwick is still committed to supporting our regional partners and our student’s employability through the provision of education, careers advice, knowledge refresh, networking and mentoring.

These services, along with the fundraising that supports them, remain an essential element of Warwick’s role as a higher education institution. The funds raised and relationships built with alumni, donors and friends enable us achieve these goals. Without them, our mission of providing a social, cultural and academic education throughout a lifelong relationship with our alumni, could not be achieved.

The processing of your data is therefore necessary in order to allow us achieve these goals. However, we always ensure that we balance these objectives against your rights and freedoms as an individual, by reviewing our activities regularly for compliance with our ethical and legal obligations.

If you do not agree with us processing your data in this way, then you can request that the University of Warwick removes your information and does not process your data for alumni engagement and fundraising related activities. If this is the case, please consider the below section on your rights and how to contact us.

We have then set out exactly how your data is used and why we use it in this way. The full details of this can be found under the exactly how we use your data section.



CONSENT TO ALUMNI AND FUNDRAISING COMMUNICATIONS
For alumni, donors and supporters, there are a number of purposes for which we process your data, including careers, mentoring, networking, knowledge refresh and fundraising. The reason we do not rely solely on consent to process your data is that due to the wide variety of different services and communications involved, this would mean we would need to constantly send you emails and letters to gain your consent. Therefore, we will rely on the legitimate interest for processing your data in the first instance. However, we may also ask for you to consent to other types of communication or to get involved in additional areas.

In order for you to receive alumni and fundraising emails and telephone calls to TPS registered numbers, we need your informed consent. Consent under GDPR needs to be a positive action, so if you have given us your email address in response to a request for alumni details, and/or you have responded to a particular campaign and said you would be interested in similar information, then we may also consider this to be consent. You have the right to withdraw your consent any time.

In order to be completely transparent we provide a detailed list of all the information that we may have collected from you;
1. From you directly,
2. From your public profile
3. From third parties

We have then set out exactly how this data is used and why we use it in this way. The full details of this can be found under the exactly how we use your data section.

A more general overview of the information we provide can be found under what personal data we collect.



WHAT PERSONAL DATA WE COLLECT
The personal data we store and process, the majority of which is given to us by our alumni and supporters, may include:

• name, title, gender and date of birth;
• contact details including postal address, email address, phone number and links to social media accounts;
• information about your time at the University and other academic institutions you have attended;
• your occupation and professional activities and memberships;
• your recreations and interests;
• family and spouse/partner details and your relationships to other alumni, supporters and friends;
• records of pledges, donations and Gift Aid status, where applicable (as required by HMRC);
• records of communications sent to you by the Engagement Group or received from you;
• Details of events you attended (formal, as a speaker, at career events, as an alumni ambassador) and when;
• volunteering by you on behalf of the University;
• information about your wealth, including net worth;
• media articles about you;
• information on your engagement in University meetings, events, groups or networks;
• information about your use of University resources or facilities (for example the Library);
• Details of businesses you are or were a Director of;

Any other personal information you provide to us during communication with us may be stored in the form of notes for reference purposes. This may include sensitive personal data, but only where you provide this to us directly or is already publicly available.

The University does not store any credit/debit card details and is fully PCI-DSS compliant. Bank details used for processing Direct Debits are stored by a trusted third-party, under the Direct Debit Guarantee scheme.



HOW WE COLLECT YOUR PERSONAL DATA
Initially, data about students is transferred into our database from the student record system, in accordance with agreements like the Student Enrollment Contract and Scholarship Funding agreements. After graduation, many of our alumni choose to manage and update their own details, which you can do online at www.warwickgrad.net. As such, the vast majority of the information we hold is obtained directly from you; and if you interact with any other departments, divisions, schools or faculties within the University we may receive data from these areas.

We always aim to keep your details up to date, and we will conduct projects to check the contact details we have for you are correct, and, where appropriate, update them. We also seek new contact details for alumni with whom we are not in contact, to ensure the University can remain in touch with as many of its alumni as possible.

As a result, some of the data may also have been obtained from publicly available sources – for example, we may find a new address for you by using the Royal Mail’s National Change of Address file (NCOA). We may also use information from publicly available sources to carry out research to assess your inclination and capacity to support the University financially or by volunteering your time.

WEALTH SCREENING AND DATA ANALYSIS

We may carry out wealth screening, a process which uses trusted third-party partners to automate some of this work. We may use information gathered from the sources listed under ‘exactly how we use your data and what data we hold’.
By doing this, we can focus our conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as an alumnus, donor or potential donor which is appropriate for you.



HOW WE USE YOUR DATA
Unless you have requested otherwise, your data is accessible to the University, its academic and administrative departments, and processed for a full range of alumni engagement and fundraising purposes. This is however, subject to restrictions as stated under how we protect your data.

GENERAL OVERVIEW
Generally we will communicate with you about the following alumni engagement and fundraising and activities, by post, email, telephone and social media:
• Keeping your knowledge fresh, by sending university and departmental publications;
• Offering you access to alumni and student careers, mentoring and networking services;
• Letting you know about alumni and university events;
• Asking you to participate in fundraising programmes;
• Offering you the chance to participate in academic projects and research;
• Promoting alumni discounts and services, like access to the library, campus sports facilities and e-journals;

The data will also be used to enable communications on behalf of alumni associations, groups and networks, sports and other clubs associated with the University, including the Friends of the University of Warwick in Singapore Trust, the Friends of the University of Warwick in South Africa, and the Friends of Warwick Inc (USA).

You can unsubscribe from our emails at any time or contact us to update your details by emailing dataservices at warwick dot ac dot uk or visiting www.warwickgrad.net.

TELEPHONE FUNDRAISING
Every term we run a telephone campaign to keep in touch with our alumni and friends, update you on Warwick and raise funds for students and university projects. The telephone campaigns are done in-house and we do not use external agencies. Our callers are current University of Warwick students who are paid for their work, which provides them with valuable work experience whilst raising money for the University. You will always be asked if you are happy to receive a call and to let us know your up to date details.




YOUR RIGHTS
The GDPR expands on the rights that you received under the DPA.

The University of Warwick considers its relationship with alumni, donors and other stakeholders to be life-long, giving you access to certain University services and a vast support network. We will always try to ensure that the data we hold for you are up to date, reasonable and not excessive.

This means that we will maintain a stakeholder record for you until such time as you notify us that you longer wish us to keep in touch. In this instance the Engagement Group will delete the majority of your personal data it holds, but will maintain basic personal data to ensure we do not inadvertently create a new record in the future.

The table below briefly summarises your rights and where those rights and the information on those rights can be found within the General Data Protection Regulations. We also recommend the ICO website guidance on your rights for detail.

Rights
1 To see information that is held by UOW
2 Access your own personal data
3 Right to correct errors in personal data (rectification)
You can ask for inaccurate personal data to be rectified.
4 Right to erase personal data (right to be forgotten)
You can ask for your personal data to be erased completely or in parts.
5 Right to restrict data processing
You can ask for the processing of personal data to be restricted so that the data may only be held and used for limited purposes by the University of Warwick.
6 Right to a copy of your personal data or transfer it to another controller (data portability). This is your right to receive and/or transfer personal data between data controllers. This right overlaps with the right of access, but it is not the same.
7 Right to object to data processing
8 Not to be subject to automated decision-making
9 Be notified of a security breach that has a high risk to your rights and freedoms

If you wish to exercise any of the above rights, please see ‘how to contact us’, below.

HOW WE PROTECT YOUR DATA
A key principle of the GDPR is that the UOW processes your personal data securely by means of ‘appropriate technical and organisational measures’ – this is the ‘security principle’.

To ensure full compliance the UOW carries out detailed risk analysis, has instituted a number of organisational policies, in addition to physical and technical measures.

DATABASE PROTECTION
Your data is held on a database hosted on a secure server within the University network. This database is protected by multi-level authentication and access is restricted to individuals who need to see the data to carry out their duties at the University. The rights of these individuals is also restricted so that only the data that is necessary and required to complete their role is accessible. All access is reviewed on a regular basis.

PSEUDONYMISATION
Where appropriate, we also take measures such as pseudonymisation to ensure data cannot be used to identify you and/or encryption to ensure that the data cannot be accessed without the right security accesses and codes.

RESTORATION
We also have measures to enable data to be restored and accessed in a timely manner in the event of a physical or technical incident. We also ensures that we have appropriate processes in place to test the effectiveness of our security measures.

AUTOMATED DECISION MAKING
None of the processes conducted by the Engagement Group use fully automated decisions. Only people make the decisions within the Engagement Group.




RETENTION
One of the principles in GDPR is that personal data should be kept for no longer than is necessary for the purposes for which the personal data are processed (except in certain specific and limited instances).

When it comes to alumni, donors and supporters of the University, we see our relationship with you as a lifelong one, which includes keeping in touch with us and those that you attended with and engaging in a mutually beneficial relationship. Therefore, information that is kept can be held indefinitely. This means that we will maintain a stakeholder record for you until such time as you notify us that you longer wish us to keep in touch. In this instance the Engagement Group will delete the majority of your personal data it holds, but will maintain basic personal data to ensure we do not inadvertently create a new record in the future.

Information that we hold on gifts and donations will be retained because of our legal obligations under the HMRC and Charity Commission.



CONTACT US
If you wish to contact us about how we have handled your personal data you can contact the Data Protection Officer (DPO). Ms Anjeli Bajaj (DPO) can be contacted via e-mail at infocompliance@warwick.ac.uk

Or write to:
The Data Protection Officer
University of Warwick
University House
Kirby Corner Road
CV4 8UW

If you wish to contact us to unsubscribe from our emails or update your details, email dataservices at warwick dot ac dot uk, telephone Tel: +44 (0)24 7657 4036 or visit www.warwickgrad.net.

Or write to:
The Engagement Group
University of Warwick
University House
Kirby Corner Road
CV4 8UW

HOW TO COMPLAIN
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. Please contact us (see ‘How to contact us’ below).

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].



EXACTLY HOW WE USE YOUR DATA AND WHAT DATA WE HOLD

As mentioned under the basis for processing your data section there are six lawful ways to process your data. The table below will provide a detailed overview of the information that we collect on you and the purpose for collecting that information.
We will NEVER sell your data or pass it on to 3rd parties for marketing purposes. We will only transfer data to 3rd parties who are acting as our agents with a data sharing agreement in place.

DATA RELEASED TO THIRD PARTIES WITHIN THE EU



DATA PROVIDED BY THIRD PARTIES WITHIN THE EU


DATA PROVIDED TO/FROM THIRD PARTIES OUTSIDE THE EU


PUBLIC SOURCES OF INFORMATION
The University of Warwick was founded with the help of philanthropy, and philanthropy continues to make an enormous impact at our University, supporting student, teaching, research and capital projects. As we are a fundraising institution, we may gather information about you from publicly available sources to not only confirm details we hold but also as part of our due diligence process and to assess your capacity and likelihood to make a donation.

WEALTH SCREENING



FUTURE CHANGES
This policy may be updated from time to time in order to reflect changes in the data that we process and how such data is processed. Where there has been a significant update to the policy we will ensure that members of the alumni, donors and stakeholders are notified of the change via our website and other communications channels



ADDITIONAL HELP
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).

Data held by the Development Office is also subject to the University’s Website Terms and Conditions and the central University Data Protection Policy.