Sevenoaks School Foundation Privacy Statement

About this Privacy Statement

This Privacy Statement tells you what to expect when The Sevenoaks School Foundation (the Foundation) collects and uses (or “processes”) personal data relating to current, past and prospective pupils and parents of Sevenoaks School, our staff, suppliers and contractors, members of the Arts Society[1], the Friends of Sevenoaks School[2] and other friends and supporters.

The Foundation is a data controller for the purposes of the Data Protection Act 2018 and the EU General Data Protection Regulation 2016 and we take our responsibilities as a controller very seriously. This Privacy Statement sets out how we process and protect your personal data and how we manage our commitment and responsibility to you. It also explains the legal rights you have in relation to your personal data.

Whereas the School is a controller of personal data primarily for the purposes of providing education and pastoral care of its students, the Foundation is a controller of personal data for the purposes of marketing, development and fundraising, and administering the School’s alumni association (Old Sennockians.) Where it is appropriate and lawful to do so, the School will share personal data with the Foundation and vice versa for their respective purposes. Where personal data is shared, it is always in compliance with our data protection laws. We have provided more information about the purposes for which we process personal data below.

Because the Foundation exists to advance Sevenoaks School (the School), our Privacy Statement should be read alongside the Privacy Statement for the School www.sevenoaksschool.org/documents. You can find out more about how the Foundation supports the advancement of Sevenoaks School below.

Please read this Privacy Statement carefully and if you have any questions please contact the Clerk to the Trustees by email at foundationclerk@sevenoaksschool.org

Who we are

The Foundation was established in 2004 to support the advancement of Sevenoaks School and all of our activities including why and how we process your personal data are designed to achieve that objective. We are a charity registered in the United Kingdom (No. 307923).

The School is also a charity (registered charity number 1101358).

An overview of what we do

The Foundation carries out its charitable objective in the following ways:

• By leasing the land it owns (i.e. the majority of the estate that forms Sevenoaks School) to the school. In this way, the Foundation supports the provision of education to the school’s students. 
• By creating and supporting an association of alumni (Old Sennockians). In this way, a community of peers is formed that contributes to the ongoing enjoyment and well-being of former Sevenoaks School students.
• By creating and maintaining life-long relationships between the school and its alumni, current and former parents and other friends and supporters. In this way, the Foundation can encourage and invite philanthropic support for the benefit of students today and for generations to come.
• By creating a sustainable culture of philanthropy, the Foundation can raise funds to support the mission and priorities of the school.

Types of personal data held

Personal data processed by the Foundation takes different forms. It may be factual information, expressions of opinion, images or other recorded information which identifies or relates to a living individual. Examples include:

• name, title, date of birth and gender;
• contact details including address, email, phone numbers and links to social media accounts;
• occupations and professional activities;
• recreations and interests;
• family and spouse/partner details, and relationships to alumni and anyone else who has a connection with the School or the Foundation;
• Data held within publicly available sources e.g. LinkedIn, Companies House, the Charity Commission, Who’s Who, Bloomberg, Forbes, the Sunday Times, The Economic Times.
• information about your engagement with the Foundation;
• information about Old Sennockians’ academic attainment, date of leaving, and university attended.
• employment and other contractual information.

Purposes for Processing Personal Data

• To invite those in our community who are leaving the School including students and their parents and staff) to continue their association with the Foundation and the School through membership of the Old Sennockians association.
• To administer membership of the Old Sennockians including keeping members informed about Old Sennockian and School news and events;
• To send School news and information about events and activities to members of the Arts Society¹ and the Friends of Sevenoaks School² and other friends and supporters;
• For a range of communication, engagement, alumni relations, fundraising and stewardship activities, and for the operational management processes that support those activities. E.g. e-newsletters, event invitations and requests to use personal stories or experiences to promote the Foundation or the School.
• To share personal data between the Foundation and the School for necessary and legitimate purposes. E.g. to support and maintain the good reputation of the School and the Foundation. We would never expect to routinely exchange special category personal data or other highly sensitive information unless it is necessary and lawful to do so. If the occasion did arise we would do this on the legal basis of the legitimate interests of the Foundation and the School
• To confirm the identity of prospective donors and relevant details of their background and interests.  We do this on the basis of legal obligations to which both the Foundation and the School are subject including the Proceeds of Crime Act 2002 and the Fundraising Regulator Code of Fundraising Practice and the Proceeds of Crime Act 2002.
• To encourage and invite support for the advancement of the School for the benefit of current and future students through fundraising campaigns and appeals;
• In order to help with fundraising, we may combine basic information about you such as your name and your employer with other information from external publicly available sources such as Companies House, the press, social media sites and third party organisations.  Doing this helps us improve the quality and accuracy of the information we hold and comply with our legal obligation to keep data accurate and up to date.  We also use this information to gain a better understanding of our supporters such as their interests, occupation, activities and level of potential financial support and doing this is in the legitimate interests of the Foundation because it assists us with our overall objective of supporting the School.
• Where we engage an external organisation to help with fundraising, we may share basic information about you with them e.g. Name and employer. Where this happens, we only share the minimum personal data necessary for the purpose and always in a way that complies fully with the Data Protection Act 2018 and the EU General Data Protection Regulation.
• For marketing and promotional purposes.
• To comply with and facilitate our contractual and legal obligations as an employer

The legal basis for processing your personal data

We will process your personal data on the basis of one or more legal grounds depending upon the specific purpose for which we are using your information but in most cases, the legal basis falls into one of the following categories below. (Where appropriate, we have also identified our legitimate interests in processing your personal data.)

- where you have provided your consent to allow us to use your data in a certain way.

E.g. we require your consent to continue to send you certain types of direct marketing by email, telephone or SMS. We also rely on your consent to use images of you on our website and on third party social networking platforms. Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any point in time.

- where the processing is necessary to carry out for the performance of a contract with you.

E.g. we need to process your personal data in order to comply with and facilitate the employment contract with our staff.

- where the processing is necessary in order for us to comply with a legal obligation.

E.g. we have a legal duty to confirm the identity of prospective donors and relevant details of their background and interests to ensure we do not deal with proceeds of crime.

- where it is necessary for the Foundation’s legitimate interests or the interests of another party such as the School or the Friends of Sevenoaks

E.g. we may send you marketing on our own behalf or on behalf of others such as the Friends of Sevenoaks for legitimate business purposes which include raising funds for the School and fulfilling our charitable objective. But you always have the right to control how we go about this by updating your marketing preferences or stop receiving marketing altogether.

E.g. we may engage an external trusted organisation to help us with our fundraising and may share basic information about potential donors with them such as name and employer’s name. It is in our legitimate interests to identify ways in which we can enhance our fundraising so as to achieve our charitable objective. Where this happens, we only share the minimum personal data necessary for the purpose and always in a way that complies fully with the Data Protection Act 2018 and the EU General Data Protection Regulation.

E.g. we may use contact details and other information to identify and approach Old Sennockians, parents, friends and supporters whose knowledge, skills and experience could potentially contribute to school lectures, Old Sennockian forums, career and university information events, focus groups and advocacy for Sevenoaks School and the Foundation.

E.g. we share the contact details of all new Old Sennockians with the Sennocke Sports Centre, so that Old Sennockians can take up complimentary membership of the centre’s facilities for three years after they leave.

- Where it is necessary for reasons of substantial public interest.

E.g. we may share basic personal data between the Foundation and the School for legitimate and lawful reasons. Information shared won’t include special category personal data such as medical information unless there is a legitimate and lawful reason such as sharing dietary needs for an event.

How we process and protect your information

The Foundation has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our online forms that are used to collect personal data such as event booking forms are encrypted. Our network is securely protected and monitored. Our policies on the use of information systems and devices are rigorous. The Foundation undertakes regular reviews of people with access to the information it holds to ensure that it is only available to appropriately trained Foundation staff and vetted contractors.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Occasionally, we may need to transfer information we process about you to countries outside the EU which do not provide the same level of data protection as the country in which you reside, for example, where your data is being held on our behalf by third party service providers whose servers are geographically located outside the EU. Where this happens, in order to ensure that your personal information is adequately protected we have put in place measures to ensure that your personal information is treated by those third parties in a way that is consistent with and respects the EU and UK laws on data protection such as standard contractual clauses which have been approved by the European Commissions.

Cookie Policy

A cookie is a small file of letters and numbers that is sent and stored on your computer and/or mobile device when you visit our website. Cookies may identify your computer’s IP (Internet Protocol) address but do not identify you as an individual.

We use cookies on our website so we can personalise content for visitors, make sure it works the way it should and to make improvements.

Click here for more detail: https://www.sevenoaksschool.org/cookies-privacy-and-data-protection

By continuing to use our website, you agree to our use of cookies.

How long the Foundation will keep your personal data

The Foundation will retain your personal data securely and only for as long as is necessary or required by law. The Foundation aims to maintain life-long relationships with Old Sennockians, parents, and other friends and supporters and in this context, providing there is a legitimate and lawful reason to do so, the Foundation will retain your personal data until you ask us to delete it.

Your rights

Under Data Protection Law you have the right to:

• obtain access to, and copies of, the personal data we hold about you
• correct any inaccurate data we hold about you
• ask for data about you to be amended or erased, subject to certain limitations
• ask us not to send you communications
• withdraw your consent to any further processing, where the Foundation is relying on consent as a ground for processing
• in certain circumstances receive data in a reasonable format specified by you.
• request the restriction of the processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• object to the processing of your personal data where we are relying on a legitimate interest (or the legitimate interest of a third party) and there is something about your particular situation which makes you want to object to the processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

If you wish to access or amend your personal data or object to how it is used, please contact the Clerk to the Trustees. We will respond as soon as we can, and certainly within the statutory time limits. Please note that it is much easier to respond to clearly defined and targeted requests for information. If the request is excessive or similar to previous requests, we may ask you to reconsider.

If you fail to provide personal data to us

Where we need to process personal data by law (for instance, in relation to anti-money laundering or other “know your customer” checks) or under the terms of a contract we have with you and you fail to provide the personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or to process your donation). In this case, we may have to decline to provide or receive the relevant services, but we will notify you if this is the case at the time the personal data is collected.

Keeping your information up to date

The Foundation has a responsibility to keep your information accurate and up to date. To help us with this task we may ask you to update your details from time to time. You can amend your contact details and communication preferences at any time using the details set out below and we will remind you of this in all communications we send.

Contact foundation@sevenoaksschool.org

Children and privacy

The safety and welfare of the students is paramount. The Foundation will not, for example, use individual pupil stories without parental and student consent. Images which do not intrude on individual privacy may be used in accordance with this and the school’s privacy notice.

Vulnerable circumstances policy

The Foundation recognises the importance of protecting vulnerable members of the wider school community and is determined to support staff who provide them with high quality care.

We also adhere to guidance issued by the Fundraising Regulator on treating supporters fairly, and make every effort to ensure that donors to the Foundation are free to make informed decisions.

Complaints, comments or compliments

Your feedback is invaluable. If you wish to tell us about any aspect of your dealings with the Foundation, please complain, comment or extend a compliment via foundation@sevenoaksschool.org

If you are not satisfied with our response, you may take your complaint to the Information Commissioners Office (ICO).

Changes to our privacy policy

This policy may evolve. If we make significant changes to the way your information is handled, we will make this clear on the Foundation website or by contacting you directly.

 

[1] The Arts Society is an opt-in engagement programme offered by the Foundation to all our friends and supporters.

[2] The Friends of Sevenoaks School (FOS) is a registered charity (number 1164214) whose object is to engage in activities that advance the education of our students.

 

Last Updated 25.5.2018