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Alumni, Donor and Stakeholders Privacy Notice

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ABOUT THIS NOTICE

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event that you have a query or complaint.

The University of Warwick (“UoW”) is committed to protecting the privacy and security of personal data. The purpose of this notice is to promote transparency in the use of personal data, and to outline how UoW collects and uses alumni, donor and stakeholder data, in accordance with the General Data Protection Regulation 2016 (“GDPR”) and the Data Protection Act 2018 (“DPA 2018”).

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

The UoW collects, uses and is responsible for certain personal data about you. This is known as “processing”. When we do so we are regulated under the GDPR and DPA 2018 which applies across the European Union and we are responsible as ‘data controller’ of that personal data for the purposes of those laws.

The purpose of this notice is to explain how the UoW will collect and use (process) your personal data, what rights you have in relation to that data and to provide transparency about the data collected about you.

The UoW is the data controller under the GDPR and the DPA 2018 and we will process your personal data in accordance with the GDPR and DPA 2018 at all times. You, as a ‘data subject’, therefore have specific rights to the data that we hold, collect and process.

Throughout this notice, “University”, “we”, “our”, and “us” refer to the UoW; “you” and “your” refer to the alumni, donors and stakeholders of UoW.

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


DEVELOPMENT AND ALUMNI ENGAGEMENT AND WHAT WE DO

Development and Alumni Engagement is part of the UoW 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 Development and Alumni Engagement’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.


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 data protection responsibilities 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

“Personal data” is any information that relates to you. It can also include expressions of opinions about an individual. The UoW lawfully processes your personal data under the following circumstances:

  • Processing is necessary for the purposes of the legitimate interests;
  • In respect of Higher Education Statistics Agency surveys on the activities and perspectives of graduates, processing is necessary for the performance of a task carried out in the public interest.

SPECIAL CATEGORY PERSONAL DATA

We may only process special category [that reveals 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] personal data in the following circumstances where, in addition to one of the above a lawful bases for processing, there exists one of the following grounds:

  • Explicit consent – where you have given explicit consent;
  • 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;
  • Public information – the processing relates to personal data which is manifestly made public by you.

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 UoW’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.

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 UoW 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 sections on your rights and how to contact us.

Public Interest

We will provide to the Higher Education Statistics Agency (HESA) and/or an organisation acting on its behalf your personal data, including contact details, for the purposes of carrying out surveys on the activities and perspectives of graduates. Further information can be found in the HESA privacy notice which explains that the lawful basis of processing your personal data for this purpose is that it is necessary for the performance of a task carried out in the public interest.


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. In order for you to receive alumni and fundraising emails and telephone calls to TPS registered numbers, we need your informed consent. You have the right to withdraw your consent any time.


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 Development and Alumni Engagement 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 special category personal data, but only where you provide this to us directly or is already publicly available.


HOW WE COLLECT YOUR PERSONAL DATA

Initially, data about students is transferred into our database from the student record system, in accordance with permission obtained during the Course Registration process and in accordance with 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;
  • Asking you to participate in reputation building activities and data collection processes, such as rankings;
  • 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, visiting www.warwickgrad.net or using our online form.

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 UoW 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 you are up to date details.

TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

If we have to transfer any of your personal data outside the EEA we will let you know if the receiving country or organisation is deemed to have adequate data protection provision. Where a country or organisation does not have adequate protections we will put safeguards in place. Details of these safeguards can be provided to you upon request to Legal and Compliance Services.


YOUR RIGHTS

The UoW 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 no longer wish us to keep in touch. In this instance Development and Alumni Engagement 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. We also recommend the ICO website guidance on your rights for more detail.

Rights

  • Be informed of how we collect and use your personal details;
  • Access your own personal data;
  • Require us to correct any mistakes in the data we hold on you;
  • Require the erasure of personal data concerning you in certain situations;
  • Restrict our processing of your personal data in certain circumstances;
  • Receive your personal data, in a structured, commonly used and machine-readable and have the right to transmit those data to a third party in certain situations;
  • Object in certain situations to our continued processing of your personal data or processing of your personal data for direct marketing; and
  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly affect you.

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 Development and Alumni Engagement use fully automated decisions. Only people make the decisions within Development and Alumni Engagement.


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 no longer wish us to keep in touch. In this instance Development and Alumni Engagement 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.


HOW TO CONTACT US
We hope that our Data Protection Officer (DPO) can resolve any query, concern or complaint you raise about our use of your personal data on the contact details below:

The DPO can be contacted via e-mail at dpo at warwick dot ac dot uk

Or write to:

The Data Protection Officer

Legal and Compliance Services
University of Warwick
University House
Kirby Corner Road
CV4 8UW

The GDPR and DPA 2018 also gives you the right to lodge a complaint with the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: [0303 123 1113].

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

Or write to:

Development and Alumni Engagement
University of Warwick
University House
Kirby Corner Road
CV4 8UW


CHANGES TO THIS PRIVACY NOTICE

This privacy notice was published on 17 May 2018 and last updated on 20 October 2020.

We may change this privacy notice 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 notice we will ensure that members of the alumni, donors and stakeholders are notified of the change via our website and other communications channels.


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. A detailed overview of the information that we collect on you and the purpose for collecting that information is detailed on our webpage of third party suppliers.

We will NEVER sell your data or pass it on to third parties for marketing purposes. We will only transfer data to third parties who are acting as our agents with a data sharing agreement in place.


ADDITIONAL HELP
Data held by Development and Alumni Engagement is also subject to the University's Website Terms and Conditions and the central University Data Protection Policy.