Privacy Notice

Alumni, Supporter and Donor Privacy Notice

SOASgiving ("We") are committed to protecting and respecting your privacy.

The External Engagement and Public Affairs team is here to keep alumni and friends up to date with what is going on at SOAS and to engage you with benefits, events, reunions, volunteering opportunities, networking and our fundraising campaigns. However you choose to get involved, we’ll always respect your rights and choices. We promise to respect any personal data you share with us, and keep it safe. We aim to be clear when we collect your personal information, and not do anything you wouldn’t reasonably expect. Here we tell you what we will, and will not do, with your personal data. View the policy on our website. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Thornhaugh Street London WC1H 0XG.

Who we are

SOAS University of London is a higher education institution and registered charity, and we are registered with the ICO. Our registration number is Z6740574. We are a Data Controller in respect of your personal data, which means we decide how and why we use your data. We have appointed a Data Protection Officer whose role is to inform and advise us about, and to ensure that we remain compliant with, data protection legislation. The Data Protection Officer should be your first point of contact if you have any queries or concerns about your personal data. Our current Data Protection Officer is David Ogden who can be contacted at dataprotection@soas.ac.uk,or 0207 898 4817. If the Data Protection Officer is unavailable, you can contact the Records Manager by email at dataprotection@soas.ac.uk, or by post at the address below: Information Compliance Office, SOAS University of London, 10 Thornhaugh Street, Russell Square, London WC1A 0XG.

What is this document and why should you read it?

This notice explains how and why SOAS processes personal data about its alumni and supporters, such as donors who provide philanthropic gifts or other individuals who express an interest in the work of the School, or provide gifts in kind. You should read this notice, so that you know what we are doing with your personal data.

How we collect information on you

The following data on graduating students is transferred from SOAS’s student records system to our alumni database at the end of each academic year.

  • Name
  • Title
  • Contact details (email, telephone (home and mobile), home address, local address)
  • Gender preference
  • Date of birth
  • Student number
  • Academic department and programme of study
  • Years of study and graduation dates
  • Classification of degree
  • Program status
  • We will gather personal data from you when you apply for an alumni card, enquire about our activities, register for an event, make a donation, volunteer, engage with our social media channels or otherwise provide us with your data.

Depending on the circumstances, when you engage with us we will collect personal data such as  your name, your date of birth, gender, location, contact information, like address, email and telephone number and possibly other information, as well as credit card or other financial information needed to process donations or event fees (we will only retain the last four digits of your payment card number). We may also ask you if you are a UK tax payer so that we can claim Gift Aid (please rest assured that we do not collect information about your actual tax payments, just whether you are a tax payer). With your permission, we also capture and collect your business details to enhance our mentoring and networking and allow us to send emails and invitations that may be of interest to you. Your data may be shared with us by independent event organisers, for example London Marathon Events Ltd or fundraising sites like Just Giving or Virgin Money Giving. These independent third parties will only do so when you have indicated that you wish to support SOAS, and with your consent. You should check their Privacy Policy to fully understand how they will process your data. We use third parties to collect data on our behalf to support our activities. This might include organisations offering alumni benefits, running raffles, event registrations, setting up Direct Debits and processing your donations.  We also on occasion ensure our records are as up to date as possible by running address and detail verification checks through sources that are deemed acceptable by the Information Commissioner's Office, e.g Experian To increase our fundraising reach we research information in the public domain, such as the contact details of local organisations we wish to get in touch with about our latest activities and appeals. We will not call any company or organisation registered with the Corporate Telephone Preference Service. ###How will we use your personal information?

We gather your personal data for specific purposes and only when it is necessary to fulfil the intended purpose. Processing your personal data allows us to provide the best possible experience for our alumni and to build strong relationships with our supporters, enabling us to tailor communication, event invitations and news that are of specific interest to you. Below is a list of all the activities which involve the processing of alumni and/or supporters’ personal data: - Load of student data to Alumni database before or after graduation - Maintain up-to-date contact details - Use of data for processing other educational opportunities - Alumni mentoring directory search - Alumni e-newsletters - Alumni magazine mailing - Use of data for careers/mentoring/university reputation purposes etc. - Administering alumni feedback and complaints - Data used to administer gift - Gift aid claim submissions - Transfer of gift aid declaration to HMRC - Fundraising appeals by email - Fundraising appeals through online platforms (e.g. Hubbub) - Fundraising appeals by telephone - Fundraising appeals by post - Photos and videos shared on the internet (e.g social media platforms) or by email - Event invitations by email - Alumni stories and biographies - Event invitations sent by post, with return email RSVP - Events advertised online where sign-up is through a third party platform (e.g. Eventbrite) - Graduation attendance sign-up - Profiling, segmentation, predictive analytics on data - Due diligence checks - Prospect research including data matching and appending - Wealth screening i.e. database screening against publicly available information - Management reporting and analytics - Management surveys, including non-statutory surveys of graduate work and study experiences after leaving - Use of data for Graduate Outcomes survey (shared with Higher Education Statistics Agency)

Our Advancement team will, where necessary, use personal data to carry out activities such as wealth screening which help us focus our resources and ensure that the School’s fundraising work is delivered in a cost-effective way. The responsible use of resources is important to us as a publicly funded institution. Additionally, we can gain a better understanding of our alumni and supporters, tailor offers and opportunities to individuals and create effective plans to develop our service by carrying out research and profiling. Please see below for further explanation.

Wealth Screening

We want to make sure we use our resources as effectively as possible to help us engage with our community of alumni and supporters appropriately. In order to achieve this we may undertake wealth screening of our database. Wealth screening enables us to better target our conversations about fundraising and therefore generate funds cost-effectively. In doing so we will share your data with one of our third-party suppliers. Please see the section 'Who do we share your personal data with?

Profiling

In order to provide you with the best experience and understand how we could engage with you in the future, we undertake analysis on the personal data we hold on you. This analysis helps us to gain a better understanding of your interests, of how you engage with us, and to understand broader demographic and geographic trends.

Research

We also undertake research on your personal data to help us make informed decisions. This includes research on demographic, philanthropic, business and financial information from publicly available sources, including social media. Where necessary we will also combine data you provide with data we obtain from other sources (e.g. to verify we have correct addresses/postcodes).

Reporting

If we use your data for management reporting or to benchmark our activity with other relevant organisations, such as CASE, we will convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it.  Anonymised data cannot be linked back to you. 

Why do we process your personal data?

SOAS will process your personal data only where we are satisfied that we have a ‘lawful basis’ for doing so. We will rely on the following lawful bases to process your personal data as an alum or supporter of the School:

  • We process your data because you have given your consent
  • We process your data because it is a necessary to fulfil a task which we carry out in the public - interest or in the official authority vested in us by UK law (public task)
  • We process your data because it is in our legitimate interest

If you have given your consent for us to contact you by email or text, you may ask us to stop contacting you at any time and you also have the right to ask our Advancement team to erase your details from their systems. Some of our activities which use your personal data, such as providing data on our alumni to HESA as part of the Graduate Outcomes survey, are tasks which we carry out in our role as a public authority, and which we have statutory basis for performing i.e. the Higher Education and Research Act (2017). We will also process your personal data where it is in the legitimate interests of the School, the data subject, or a third party. SOAS will carry out a legitimate interest assessment in all instances where we rely on this lawful basis, to make sure that the purpose is legitimate, the processing of your personal data is necessary to achieve the purpose, and that our processing won’t limit your data protection rights and freedom.

Who do we share your personal data with?

Your personal data is stored on our database which is password protected and access is limited to authorised SOAS staff. We may pass your data to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send out mailings). When we use third party service providers, we only disclose information necessary to deliver that service and there will always be a contract in place to ensure your data is kept secure. We will not share your data with third parties to use for their own purposes unless we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. List of third-parties with whom we share personal data, by category:

Data processors

  • Fundraising management software providers
  • Alumni community management platform providers
  • Mailing houses
  • Alumni and supporter database provider

Data controllers

  • Higher Education Statistics Agency (HESA)
  • Regulatory bodies e.g. Information Commissioner’s Office, Fundraising Regulator Courts, law enforcement agencies
  • Legal advisors

What is Special Category Data, and why do we need it?

For some activities SOAS will need to process your Special Category Data which are types of personal data the GDPR and Data Protection Act (2018) considers more sensitive than others. When we process these types of data, we need to apply additional protections. The GDPR Article 9 (1) states that the following types of data are Special Category: - Ethnic or racial background - Religious or philosophical belief - Political opinions - Sexual life - Sexual orientation - Health - Trade Union membership - Genetic data - Biometric data, in so far as it permits identification of an individual

We might need to ask you whether you have a disability in order to make access arrangements if you wish to attend an event organised by the Advancement office. We will not ask you for any other type of Special Category Data. We ask for your explicit consent to process this sensitive data, and will inform you exactly what information we need and why, and you will always be able to withdraw your consent at any time. There are circumstances in which we will not ask your consent to process Special Category of criminal convictions data, such as: - Where SOAS needs to process your personal data to protect your vital interests or the vital interests of another individual (e.g. providing a paramedic with information in the event of a medical emergency). - For carrying out a legal obligation - For the establishment, exercise and defence of legal claims

Where is your data transferred?

Although most of the personal data we store and process stays within the UK, some data may be transferred to countries outside the European Economic Area (EEA). This may occur if, for example, one of our partner’s servers are located in a country outside the EEA. If we do send your personal data overseas, we will only make that transfer if: - the country we are sending your personal data to offers an adequate level of protection for personal data; - we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract with the recipient; - the transfer is necessary and can be made under a condition specified in data protection legislation, and specifically Article 49 of the GDPR, such as the performance of a contract between us and you; or - you gave us permission to make the transfer.

How will we keep your data secure?

We ensure that there are appropriate technical controls in place to protect your personal data. For example, our online forms are always encrypted and our network is protected and routinely monitored.   We use a secure server when you enter into any money transaction from our website. We also take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. If any payments are made by card we will only store the final four digits, and won’t keep any other information. Our payment systems are PCI/DSS compliant. Any payment details on paper donation forms are destroyed once the donation has been processed. We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.

How long will we hold your personal information for?

SOAS considers its relationship with our alumni community to be life-long, and we will keep hold of your details until you tell us you no longer wish to hear from us. We will take into consideration our legal obligations, and tax and accounting rules, when determining how long we should retain your data. When we no longer need to retain your information we will dispose of it securely, at the appropriate time. For further information on how long SOAS retains information about alumni and supporters, please see the SOAS retention schedule (particularly sections 8.2 and 8.3) on the website: here.

Your rights

As a data subject you have certain legal rights in relation to your personal data, which you can exercise at any time. As alumni, supporters or donors you have the right to access, correct, or restrict your data, to object to our processing and you also have the right to withdraw your consent to receive marketing materials and have your data permanently deleted.

Accessing a copy of your personal data

You have the right to a copy of the data which the School holds about you. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, the School may charge a reasonable fee if your request for access is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances. A guide on how to make a ‘Subject Access Request’, including requirements for proving your identity, is available on our website here: Making a request for your data.

Keeping your information up-to-date

The accuracy of your personal data is important to us. You can update your information with us, including your address and contact details at any time. If you would like to change your preferences or update the details we hold about you, please contact: alumni@soas.ac.uk +44 (0)20 7898 4041 Alumni Office, Room FG05, SOAS University of London, 10 Thornhaugh Street, Russell Square, London WC1H 0XG, UK

Choosing when you hear from us

You have a choice about whether you wish to receive information from us. If you do not want to receive direct marketing communications from us about the vital work we do for the School, and our events and activities, then please let us know at any time by contacting us on: Email: alumni@soas.ac.uk Telephone: +44 (0)20 7898 4041 We will not contact you for marketing purposes by post, email, and phone or text message if you have told us you do not want to hear from us by any of those channels. If you choose to send a donation or communication to us by text message we promise to make it clear to you before you text what you are consenting to, and provide instructions for how you can opt out. If you unsubscribe from communications from us, from any or all of the communication channels mentioned above, we will update our records to stop further communication as quickly as we can. Due to some communications already being in progress at the point you opt out, please be aware that it can take up to 6 weeks for your preferences to be fully implemented, although your request will be put into effect within 30 calendar days. If SOAS corrects, restricts, or deletes your personal data at your request and that data has been passed to a third party or third parties for the same purpose, SOAS is responsible for ensuring that those bodies also fulfil the terms of your request unless it proves impossible or requires disproportionate effort.

Updates to this notice

We will update this notice as necessary to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on any significant changes we make to this notice by publicising it through the alumni newsletter, or through other appropriate channels of communication.

Who regulates the use of personal data?

If you think SOAS is processing your data unlawfully, you have the right to lodge a complaint with the Information Commissioner’s Office, which is the UK data protection regulator. More information can be found on the Information Commissioner’s Office website at https://ico.org.uk/.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed either by post to Thornhaugh Street London WC1H 0XG or by email at philanthropy@soas.ac.uk.

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