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Privacy Policy

Who we are

This privacy notice relates to the work of the Development Office, as part of Eltham College, which is the Data Controller for the purposes of the relevant legislation (“Data Protection Law”)[1]. Eltham College is a registered company with company number 03245525, and a registered charity (number 1058438), and is registered at Grove Park Road, London SE9 4QF.

What this privacy notice is for

This policy is intended to provide information about how the Development Office will use (or "process") personal data about individuals including: its staff, its current and past pupils and their parents, carers or guardians. Those in the role of parents, carers or guardians are referred to in this policy as "parents".

We have published this privacy notice in addition to the general school Privacy Notice because we are aware of the need to be specific about the relationship between the Development Office and data subjects both during and after their contractual relationship with the College.

This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Staff, parents, pupils and alumni are all encouraged to read this Privacy Notice and understand the Development Office’s obligations to its entire community.

This Privacy Notice applies alongside any other information the school may provide about a particular use of personal data, for example when collecting data via an online or paper form.

This Privacy Notice also applies in addition to the school's other relevant terms and conditions and policies, including:

  • the school’s general Privacy Notice
  • any contract between the school and its staff or the parents of pupils;
  • the school's policy on taking, storing and using images of children;
  • the school’s CCTV policy;
  • the school’s retention of records policy;
  • the school’s data protection policy for staff
  • the school's IT policies, including its Acceptable Use of IT policy.

Anyone who works for, or acts on behalf of, the Development Office (including staff, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice, and where appropriate, the school's data protection policy for staff, which also provides further information about how personal data about those individuals will be used. 

Responsibility for data protection

The School has appointed the Bursar as Privacy and Compliance Officer. The Bursar, on behalf of the Development Office, will deal with all your requests and enquiries concerning the school’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law. The Bursar may be contacted on Bursar@eltham-college.org.uk, or by telephone on 020 8857 7360.

Why the Development Office needs to process personal data

The aim of the Development Office at Eltham College is to appropriately engage with the wider Elthamians community, be they current pupils, Old Elthamians (OEs), current and former parents of OEs, and current and former staff in order to enrich and sustain their relationship with the school, and to support current and future activities at Eltham College. The collection and processing of data forms an integral part of carrying out this mission. Some of this activity will need to carried out in order to fulfil the Development Office’s legal rights, duties or obligations, for example, in the case of processing Gift Aid.

Most uses of personal data will be made in accordance with the Development Office’s legitimate interests, provided that these do not outweigh the impact on individuals, and provided these does not involve the processing of special or sensitive types of data.

The Development Office expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:

  • Maintaining relationships with alumni and the school community, including direct marketing, careers engagement or fundraising activity;
  • For the purposes of donor due diligence, and to confirm the identity of prospective donors and their background and relevant interests;
  • To make use of archival material and photographic images of past school publications and events, on the alumni website and on the alumni's social media channels (always bearing in mind that the preferences of a living data subject must be accommodated wherever possible and appropriate when publishing data on the basis of public interest);

Types of personal data processed by the Development Office

Data will include by way of example:

  • names, addresses, dates of birth, telephone numbers, e-mail addresses and other contact details;
  • bank details and other financial information of both alumni and parents who are making charitable donations to the school and/or buying memorabilia or event tickets;
  • past and present pupils' years of school attendance
  • past and present staff years of employment
  • records of attendance at alumni events;
  • correspondence by the department with and concerning staff, pupils and parents past and present; and
  • archival images of students and staff engaging in school activities, and alumni images captured for engagement purposes, within reason;

How the Development Office collects data

Generally, the Development Office receives personal data from the individual directly. This may be on a paper or electronic form, or simply in the ordinary course of interaction or communication (such as email, by telephone or by event registrations). In some cases, the Development Office will collect personal data provided through the school’s admissions process, as notified on the school’s general Privacy Notice. Photographs are generally obtained from the marketing department, from publicly available sources and/or from school staff, alumni or students themselves.

Who has access to personal data and who the Development Office shares it with

Occasionally, the school will need to share personal information relating to its community with third parties, such as:

For the most part, personal data collected by the Development Office will remain within the school, and will be processed by appropriate individuals only in accordance with access protocols.

However, a certain amount of relevant information relating to any OE with specific medical needs (such as dietary or accessibility requirements) will need to be provided to staff more widely in the context of providing the necessary care that the OE requires.

Finally, in accordance with Data Protection Law, some of the Development Office’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers, cloud storage providers and printing and mailing companies. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s specific directions.

How long we keep personal data

The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason.

If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Bursar. However, please bear in mind that the school will often have lawful and necessary reasons to hold on to some personal data even following such a request.

A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").

Keeping in touch and supporting the school

The Development Office will use the contact details of parents, alumni and other members of the school community to keep them updated about the activities of the school, or alumni and events of interest, including by sending updates and alumni magazines, by email and by post. Unless the relevant individual objects, the Development Office will also: 

  • Contact parents and/or alumni by post and email in order to promote and raise funds for the school and, where appropriate, other worthy causes;
  • Provide telephone contact information to the company organising our annual telephone fundraising campaign;
  • Collect information from publicly available sources about parents' and former pupils' occupation and activities, in order to maximise the school's fundraising and careers engagement potential.

Should you wish to limit or object to any such use, or would like further information about them, please contact the Development Office in writing on elthamians@eltham-college.org.uk or on 0208 851 9840. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the Development Office is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).

Your rights

The rights under Data Protection Law belong to the living individual to whom the data relates. You have the right to ask us to limit our use of your data (e.g. publication of photographs) or to opt out of any or all forms of communications from the Development Office, although you should be aware that profiling your communications preferences may affect the type of service we will be able to provide. For further explanations or if you would like to discuss communication preferences, please contact the Development Office.

  • Rights of access, etc.

Individuals have various rights under Data Protection Law to access and understand personal data about them held by the school, and in some cases ask for it to be erased or amended or have it transferred to others, or for the school to stop processing it – but subject to certain exemptions and limitations. 

Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Development Office, by post to the College or by email to elthamians@eltham-college.org.uk.

The Development Office will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).

The Development Office will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the school may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).

  • Requests that cannot be fulfilled

You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals (and parents need to be aware this may include their own children, in certain limited situations – please see further below), or information which is subject to legal privilege (for example legal advice given to or sought by the school, or documents prepared in connection with a legal action).

You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.

  • Pupil requests

Pupils can make subject access requests for their own personal data, provided that, in the reasonable opinion of the school, they have sufficient maturity to understand the request they are making (see full Eltham College privacy policy). A pupil of any age may ask a parent or other representative to make a subject access request on his/her behalf.

Indeed, while a person with parental responsibility will generally be entitled to make a subject access request on behalf of younger pupils, the law still considers the information in question to be the child’s: for older pupils, the parent making the request may need to evidence their child's authority for the specific request. 

Pupils aged around 13 and above are generally assumed to have this level of maturity, although this will depend on both the child and the personal data requested, including any relevant circumstances at home. Slightly younger children may however be sufficiently mature to have a say in this decision, depending on the child and the circumstances.

All information requests from, on behalf of, or concerning pupils – whether made under subject access or simply as an incidental request – will be considered on a case-by-case basis.

Data accuracy and security

The Development Office will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible.  Individuals should notify the Development Office of any significant changes to important information, such as contact details, held about them.   

An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the school may need to process your data, of who you may contact if you disagree.

The Development Office will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to school systems. All staff using the relevant systems will be made aware of this policy and their duties under Data Protection Law and receive relevant, ongoing training. 

This policy

The Development office will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.

Queries and complaints

Any comments or queries on this policy should be directed to the Bursar or the Development Office (as appropriate) using the contact details provided above.

If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school’s Complaints Procedure (available on the Eltham College website) and should also notify the Bursar. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the school before involving the regulator. 

 

[1] By 25 May 2018, the relevant legislation is likely to include both the General Data Protection Regulation (EU 2016/679) and the UK Data Protection Act 2018, as well as potentially other relevant supporting legislation.