Privacy Statement – King’s College London Alumni and Supporters

Our alumni and supporters are incredibly important to us. The Alumni Office at King’s College London is here to keep alumni and supporters up to date with what is going on, and to engage you with benefits, events, reunions, volunteering opportunities and our fundraising campaigns. However you choose to help, 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.

This statement includes:

  • Who we are
  • Legal Basis for processing
  • Our duty
  • How we collect information on you
  • How we will use your personal information
  • Cookies
  • Analytics
  • Who has access to your personal information
  • How we keep your personal information secure
  • How long will we hold your personal information for
  • Your choices
  • Right to be forgotten
  • Keeping your information up to date
  • Your rights
  • Children and privacy
  • Vulnerable Circumstances policy
  • Complaints, compliments or comments
  • Changes to our Privacy Policy

If you have any questions about our privacy statement then please do contact a member of the team who will be happy to talk you through it.  Our contact details are:

Alumni Office
King’s College London
Virginia Woolf Building
22 Kingsway
London WC2B 6LE
Tel: 020 7848 3053
Email: alumoff@kcl.ac.uk

Who we are
We are the Alumni Office at King’s College London.
Visit our website to find out more about the ways you can get involved with our alumni community.
King’s College London, a university with charitable status, established under royal charter and having its registered office at Strand, London WC2R 2LS, United Kingdom.

Legal Basis for processing
We process your data as described in this statement because we have a legitimate need to do so to deliver our alumni services and fundraising ambitions. Some processing of data may be carried out to perform a contract with you or it is required by law, such as the completion of due diligence or obligations for processing Gift Aid on your donations.
Please see the ‘How we will use your personal information’ section below for more details.
To ensure we fully understand when it is appropriate to rely on consent and when it is a legitimate interest of ours to process your data we routinely carry out impact assessments to ensure the way in which we use you data is fair does not personally impact you

Our duty
In carrying out our day to day activities we process and store personal information relating to our supporters. We are therefore required to adhere to the requirements of the Data Protection Act 2018. We take our responsibilities under this act very seriously and ensure the personal information we obtain is held, used, transferred and processed in accordance with that Act.  We also adhere to all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.

How we collect information on you
The information we gather allows us to provide the best possible tailored experience for our alumni and supporters, enabling us to tailor event invitations and news that are of specific interest to you.
If you are a student of King’s College London, your student record is automatically transferred to the Alumni Office when you graduate, as stated in the Student Data Collection Notice.  The information the Alumni Office receives is:

  • Name
  • Title
  • Gender preference
  • Date of birth
  • Student number
  • Academic department and programme of study
  • Years of study and graduation dates
  • Classification of degree

We gather personal information from you when you enquire about our activities, register for an event, make a donation, sign up to an event, volunteer, engage with our social media channels or otherwise provide us with your personal information.

The personal information that we may request when you engage with us might include your name, your age, gender, location and/or country information, and possibly other information, as well as credit card or other financial information needed to process donations or event fees. 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). We will never request personal information about your health or the health of your family members or friends, unless we inform you how that information will be used, and receive your express consent for such use i.e. for a case study story.

With your permission, we also capture and collect your business details to enhance our mentoring network and allow us to send emails and invitations that may be of interest to you.
Your information 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 King’s College London, and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

We use third parties to collect data on our behalf to support our activities. This might include 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 through running address and detail verification checks through sources that are deemed acceptable by the Information Commissioners Office.
We may also receive information about you from other sources, which include publically available data. Please see the ‘How we will use your personal information’ section below for more details.
To increase our fundraising reach we research information in the public domain, such as contact details for local organisations 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.

Cookies
We don’t currently gather information on how you use our website through the use of cookies but we may do in the future.  
Cookies are text files, which identify a user's computer to our server. Cookies in themselves do not identify the individual user, just the computer used. The Alumni Online website uses persistent cookies - these are used to track returning visitors. They expire after 12 months and enable us to compare website traffic from month to month.
Cookies help us identify which pages are most visited and which events or activities are of most interest. This information can be used to help us improve our website and services and ensure we provide you with the best service. Wherever possible, the information we use for this purpose will be aggregated or anonymised i.e. it will not identify you as an individual visitor to our website.  
You can reject cookies. Most browsers allow you to refuse cookies - consult the help section of the browser toolbar. Information on controlling cookies or rejecting cookies is available from several web sites, e.g. http://www.aboutcookies.org

Analytics
This website uses Google Analytics tracking codes to measure performance enabling us to enhance and improve services for our audiences. However, we do not collect personally-identifiable information (PII) as all data collected is anonymous. For full details on how Google Analytics works, please visit Google Analytics Terms of Service. If you do not want Google Analytics to use your data, then please visit Google Analytics opt-out browser add-on.  

How we will use your personal information?
We may use your information for a number of purposes including the following:

  • To provide you with information about our work or our activities that you’ve requested. This might include sending you e-newsletters, invitations to events and volunteering opportunities.
  • For administration purposes e.g. we may contact you about a donation you have made or event you have expressed an interest in or registered for
  • To ask you for your permission to use the story of your experience with King’s to promote our work
  • To ask you to help us raise money or donate money to King’s, but always in accordance with the fundraising promise
  • To create an account for you if you register with us
  • To process entries into a prize draw or raffle
  • For internal record keeping, including the management of any feedback or complaints
  • To use IP addresses to identify your approximate location, to block disruptive use, to record website traffic or to personalise the way our information is presented to you;
  • To analyse and improve the services offered on our sites to make it as user-friendly as possible
  • To use anonymised personal data to benchmark our activity with other relevant organisations, including CASE
  • Transfer to HM Revenue and Customs in respect of any Gift Aid claims
  • For statutory and regulatory compliance
  • We may assess your personal information for the purposes of credit risk reduction or fraud prevention.
  • To keep your records as up to date as possible. To help us do this we may use publicly available sources for example, the Post Office’s National Change of Address database. Please see the ‘Keeping your information up-to-date’ section below for more details on how you can you let us know if your contact details change.
  • In addition to this we may use your data for wealth screening, research and profiling. Our purpose is to gain a better understanding of how we should engage with you, and tailor our communications more effectively and appropriately. This also helps us make informed decisions about our fundraising strategy and ensure our internal resources and investments are used as effectively as possible. Our objective is to ensure any approaches we make to you are respectful, professional and are based on evidence that you might be interested in our work, providing you with the best experience we can. Please read below for more information:

Wealth Screening - is carried out by a trusted third-party supplier and entails using information such as your name, postcode and data on your existing relationship with us. Wealth screening is a tool which helps us to better understand how to approach you about fundraising and volunteering opportunities in an appropriate way and therefore generate funds cost-effectively.

Research - could include research on financial, business, philanthropic and demographic information sourced from publicly available data, such as Companies House, the Charity Commission and the media. We may also look at professional networks such as LinkedIn, and process special category data if it has been made manifestly made public by you; for example, through an interview or a publicly directed social media post. In addition, we may combine the data you provide with data we obtain from other sources (e.g. to verify we have correct addresses/postcodes).

Profiling – this could include analysis of financial, philanthropic and other personal data we hold on you to assess the likelihood that you might wish to engage with us, as well as broader data analysis. This analysis helps us to gain a better understanding of how to approach you, of your interests, and of broader demographic, geographic and engagement trends amongst our supporters. This process is not solely automated processing and always contains manual assessment to ensure we are making correct assumptions from the analysis.

  • If you do not wish your data to be used in any of the ways listed above or have questions about this, you have the choice to change your privacy options and can notify us using the contact details at the top of this page. If you are unsure and have further queries on how we might use your data, please get in touch and we’ll be happy to answer your questions.

In order to comply with our legal obligations under the Charity Commission Regulations and the Fundraising Regulator’s Code of Practice, we may also undertake due diligence research to assess the source of funds for donations and to ensure that we are robustly considering ethical and reputational risks to our organisations.

Who has access to your personal information?
Your personal information is stored on our database which is password protected and access is limited to King’s College London staff, some departments across the College and trusted subcontracted parties.
We may pass your information 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 information is kept secure. We will not share or sell your data to 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.
Although most of the information we store and process stays within the UK, some information may be transferred to countries outside the European Economic Area (EEA). This may occur if, for example, one of our trusted partner’s servers are located in a country outside the EEA. These countries may not have similar data protection laws to the UK however, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law by the use of EU model contract clauses or for organisations we work with who process personal information in the USA verification that their data processing standards meet the EU-US Privacy Shield. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.

How we keep your personal information secure?  
We ensure that there are appropriate technical controls in place to protect your personal details; 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.
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?
King’s College London Alumni Office considers its relationship with alumni, donors and other stakeholders to be life-long.  However, if any time you want to review or stop entirely the communications we send to you, please contact our Supporter Care Team on 020 7848 3053 or email alumoff@kcl.ac.uk.
We will take into consideration our legal obligations, and tax and accounting rules, when determining how long we should retain your information. When we no longer need to retain your information we will ensure it is securely disposed of, at the appropriate time. 
If you have pledged a legacy gift, it will be necessary to retain your data until your gift is received, so that we can identify the gift against the pledge.

Your choices
You have a choice about whether or not you wish to receive information from us. If you do not wish to receive direct marketing communications telling you about the latest alumni news, events and fundraising updates f then please let us know at any time by contacting our Supporter Care Team on 020 7848 3053 or alumoff@kcl.ac.uk .
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 the telephone number we hold for you is registered with the Telephone Preference Service (TPS) then we will not contact you on that phone number except for administrative purposes.
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.
We will only ever share your data in other circumstances if we have your explicit and informed consent.  

Right to be forgotten
If you choose to opt out of receiving our communications, your data will be retained and marked to prevent you from receiving any communications. If you want your data to be deleted from the database entirely, in most cases we will delete it.  However by deleting your data, we will be unable to guarantee that you will not receive communications in the future, because we will have deleted your data and will therefore have no record of past requests from you.
If you want to guarantee you will not receive communications from us, it is in your best interest for your data to be retained on our system so that your contact preference is recorded and adhered to.
In some cases, we will be required to keep some or all of your data on record for legal or accounting reasons. For example, if you have made a donation, we will be required to keep the donation details for a minimum of seven years from the donation. If you have completed a Gift Aid declaration, we will be required to keep your details in order to claim the Gift Aid on your donation. In these cases, we will anonymise as much of your data as possible until it can be deleted.

Keeping your information up-to-date
The accuracy of your information 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 our Supporter Care Team on 020 7848 3053 or email alumoff@kcl.ac.uk.

Your rights
You have the right to:

  • request a copy of the information we hold about you
  • update or amend the information we hold about you if it is wrong
  • change your communication preferences at any time
  • ask us to remove your personal information from our records
  • object to the processing of your information for marketing purposes
  • raise a concern or complaint about the way in which your information is being used

If you wish to talk through anything in our privacy statement, find out more about your rights, or obtain a copy of the information we hold about you, please contact our Supporter Care Team who will be happy to help:
Alumni OfficeKing’s College London
Virginia Woolf Building
22 Kingsway
London WC2B 6LE
Tel: 020 7848 3053
Email: alumoff@kcl.ac.uk

Children and privacy
We take the protection of children very seriously. To that end, we require that children under 16 do not submit any information to our website without a parent's or guardian's consent. We will not knowingly request or collect from a child any information online that can be traced to the child, such as an email address, name, or information about the child's family. Unless a parent or guardian consents to such use in advance, we will not knowingly use information that a child provides to us for any fundraising or promotional purpose. 

Vulnerable circumstances policy
We recognise the importance of protecting our vulnerable supporters and follow the guidance issued by the Institute of Fundraising on treating donors fairly. We believe this helps to support our staff and fundraisers who come into contact with supporters in providing high quality customer care, ensuring anyone donating to the King’s College London is in a position to make a free and informed decision. 
Access the Institute of Fundraising’s website - for more guidance.

Complaints, compliments or comments
If you are unhappy with your experience of King’s, with something that we have done or failed to do, we want to know about it. We also welcome your views on what we do well. Your comments enable us to learn and continuously improve our services.  If you would like to make a complaint, compliment or comment then please get in touch with our Supporter Care Team:
Alumni Office
King’s College London
Virginia Woolf Building
22 Kingsway
London WC2B 6LE
Tel: 020 7848 3053
Email: alumoff@kcl.ac.uk
The Alumni team are available to help Monday to Friday, 9am – 5pm.

Changes to our Privacy Statement
We may change this Privacy Statement from time to time.  If we make any significant changes in the way we treat your personal information we will make this clear on the Alumni Online website or by contacting you directly.

Privacy statement reviewed July 2018