Members and Friends Data Protection Policy

This statement explains how King's College (“we” and “our”) handles and uses data we collect about alumni and other supporters (“you” and “your”). In broad terms, we use your data to manage the ongoing relationship between the College and you as part of our lifelong community of scholars, including keeping in touch with you, keeping up to date on your achievements, and engaging with you on how you can continue to contribute to College life and otherwise support the College.

We will retain your data indefinitely or until you request us to do otherwise. When changes are made to this statement, we will publish the updated version to our website and notify you by other communications channels as we deem appropriate or necessary.

The controller for your personal data is King's College, King's Parade, Cambridge, CB2 1ST, United Kingdom. The person responsible for data protection at the time of issue, and the person who is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, is the Data Protection Officer and Fellow Librarian, Dr Peter Jones.

The legal basis for processing your personal data is that it is necessary for the purposes of our legitimate interests, where we have concluded that our interests do not impact inappropriately on your fundamental rights and freedoms, except where elsewhere in this statement we have indicated otherwise. You may ask us to explain our rationale at any time.

Contents

  1.     How your data is used by the College
  2.     What data is held by the College
  3.     When the College shares your data with others
  4.     Your rights
  5.     Questions and further statutory information

1. How your data is used by the College

Your data is used by us for a number of interdependent purposes, including alumni relations, communications and fundraising. These include:

  •     publications (e.g. King's Parade magazine and King’s Herald)
  •     surveys, to help us direct and refine our activities
  •     appeals and requests for donations, including an evaluation of when and whether particular appeals may be appropriate or of interest to you,
  •     the promotion of social and academic College events, and
  •     the promotion of other services and benefits open to our members.

Communications to you may be sent by post, telephone or electronic means, depending on the contact details we hold and the preferences expressed by you about the types of communications you wish to receive.

If you have concerns or queries about any of these purposes, or how we communicate with you, please contact us at .

2. What data is held by the College

We believe that most alumni understand in detail the complex and many interactions of the College with the University of Cambridge. Personal data of our members is shared with the University routinely throughout any course of study, and it is our strong preference to continue such collaborative working thereafter.

The University and its partners (including the College) have a data sharing agreement to govern the sharing of personal data of alumni and other supporters.  This is necessary because they are distinct legal entities. The agreement outlines that, depending on constraints set by you, and which you may change at any time, the University and College may share any of the above categories of personal data with the University, and can be viewed in full at www.cam.ac.uk. Any transmission of data to or from the University is managed through agreed processes which comply with UK data protection legislation.

For clarity, the College has a separate database from the University, but has access to the University’s database: additionally, we maintain other electronic and paper records.

The University has its own data protection statement and procedures – see: https://www.alumni.cam.ac.uk/data-protection

Most records contain:

  •     details of your school, College and University education,
  •     unique personal identifiers (e.g. student number, date of birth), and
  •     your contact details.

Where provided by you, or provided by the University or obtained from reputable sources, we also may record:

  •     your attendance at College or University events,
  •     other contact with us or the University since graduation,
  •     your key relationships with other alumni or supporters of the College and/or the University and other colleges within Cambridge,
  •     your career highlights and other life achievements,
  •     financial information relating to you and any of your key relationships (including but not necessarily limited to income, philanthropy and other giving),
  •     donations made by you to either the College or the University,
  •     information about your areas of personal interest (e.g. clubs, hobbies, voluntary work),
  •     personal data provided by you for a specific purpose or purposes (for example, disability, catering preferences or lifestyle status for event management), and
  •     your communication preferences.

Where data is included from sources external to the University and the College, we only use data from our partners (as outlined below) or other reputable sources. We may use automated or manual analyses to link data together to help us assess your potential for supporting us and/or the University.

3. When the College shares your data with others

Depending on constraints set by you, and which you may change at any time, we may share any of the above categories of data with the University of Cambridge.

Additionally, we share data on a considered and confidential basis, where appropriate, with

  •     Cambridge in America (the University’s affiliate alumni office in the US);

third party agencies who provide us with data in the public domain about alumni and supporters, examples of which are:

  •     UKChanges, for verification of contact details, National Change of Address database, deceased status, TPS lookup
  •     Factary, for evaluation of UK-resident alumni and supporters against publicly-sourced data on property and company ownership, philanthropy, trusteeships, etc.

selected companies who provide College-branded or College-endorsed products and services:

  •     Aluminati, managers of the lifetime email scheme
  •     HMRC, for Gift Aid claim and audit

contractors providing services to you on our behalf or services to us (our “data processors”), examples of which are:

  •     Peters, Elworthy & Moore, College Auditors
  •     Barclays Bank plc, for financial transactions including credit card payments for donations and events
  •     The Charities Aid Foundation (CAF), for the receipt of online donations and direct debit processing
  •     Buffalo Fundraising Consultants Ltd, for fundraising consultancy and the delivery of the annual telephone campaign
  •     Mailchimp, for the processing and dispatch of bulk email communications, including King’s Herald
  •     Blackbaud Inc, the vendor of our contact management database, for technical support purposes only
  •     Doris and Bertie Ltd, publishers, for the production and delivery of the King’s Parade magazine
  •     SurveyMonkey Inc., for the collection of survey data and opinion to guide our alumni relations and fundraising programmes

We do not sell your personal data to third parties under any circumstances, nor permit third parties to sell on the data we have shared with them.

We also facilitate communication between individual alumni (of the College or the University), but in doing so we do not release personal contact details without prior permission.

Any transfers of your data overseas or to international organisations, as set out above, are protected either by an adequacy decision by the European Commission or by standard data protection clauses adopted by the European Commission (which are available from our Data Protection Officer) or, before 25 May 2018, by a self-assessment of adequacy.

4. Your rights

You have the right: to ask us for access to, rectification or erasure of your data; to restrict processing (pending correction or deletion); to object to communications or direct marketing; and to ask for the transfer of your data electronically to a third party (data portability). Some of these rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

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, subject(s), matriculation and graduation details, unique University identification number and date of birth) to ensure we do not contact you inadvertently in future, while still maintaining our record of your academic achievements. We may also need to retain some financial records about you for statutory purposes (e.g. Gift Aid, anti-fraud and accounting matters).

You retain the right at all times to lodge a complaint about our management of your personal data with the Information Commissioner’s Office at https://ico.org.uk/concerns/

5. Questions and further statutory information

The controller for your personal data is King’s College.

Development-specific enquiries about our data policies, procedures, and your personal data and communication preferences can be directed to .

The College’s Data Protection Officer is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, and can be contacted at .

Please contact us through the addresses given above if you have any concerns or questions about the above information. Where you have specific requests relating to how we manage your data, we will endeavour to resolve these, but please note that there may be circumstances where we cannot comply with your specific request.

If you were a student at King's please see the general Data Protection Statement about student records which lists the information which the College processes in the course of its business interests. As that processing does not require your consent to be legitimate, it is not covered in your right to opt out of the processing.

If you have any concerns about your personal data held by the University, you will need to contact the University separately.

Statement adopted by College Council October 2017
Revised 12 June 2018, to update list of third-party contractors with whom we share data.