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Privacy Statement – King’s College London Alumni and Supporters

The King’s College London Alumni Office is here to inform, connect and engage our former students and staff and help you keep in touch with the latest developments at the university and how you can support our work. Staying in touch with our alumni is important, so that we can help you access the latest King's news, alumni benefits, event invitations and much more. 

Visit our website to find out more about the ways you can get involved with our alumni community.

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 would not reasonably expect. In this notice we will outline what we will and will not do with your personal data.

This statement includes:

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: forever@kcl.ac.uk

Who we are

We are the Alumni Office at King’s College London.

King’s College London, is a university with charitable status, established under royal charter (RC000297) and having its registered office at Strand, London WC2R 2LS, United Kingdom. The College though a fully autonomous institution in its own right, is also a constituent college of the University of London.

Our duty

In carrying out our day-to-day activities we process and store personal information relating to our alumni and supporters, and we are therefore required to adhere to the Data Protection Act 2018. We take our responsibilities very seriously and we ensure the personal information we obtain is held, used, transferred, and otherwise processed in accordance with that Act and all other applicable data protection laws and regulations. This includes, but is not limited to, the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018, and the Privacy and Electronic Communication Regulations 2003 ('Data Protection Laws').

The basis for processing your personal information

Data Protection laws require us to outline the lawful grounds on which we collect and process your personal data.

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.

When we process your personal data, we rely on one or more of the following grounds:

Legitimate interests

King’s College London Alumni Office considers its relationship with alumni to be life-long. We may process your personal data where it is within our legitimate interests to do so to enable us to deliver our alumni services and effectively administer and further the fundraising ambitions of King’s College London. In the case of our legitimate interests to process your personal data, we will ensure that our interests are balanced against any detriment you may face from our processing.

Consent

We will use consent as a basis for processing, where we ask you if we can use your personal data for specific purposes (having informed you of those purposes), and you freely and unambiguously agree to such use. You have the right to withdraw your consent at any time, by emailing our Supporter Care Team at forever@kcl.ac.uk.

Legal obligation

In order to comply with our legal obligations and charity regulations such as the Charity Commission’s CC20 and ‘Know Your Donor Policy’ and the Fundraising Regulator’s Code of Fundraising Practice, we may 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 organisation. We may also hold donor transactional details for Gift Aid or accounting/tax purposes.

Performance of a contract

In order to process donations, we may need to collect bank details and financial information alongside contact details. We rely on these details to be able to fulfil a contract with you and service your financial transactions i.e. Direct Debits.

How we collect your personal information

The information we gather allows us to provide the best possible tailored experience for our alumni and supporters and to send you invitations and news that are of specific interest to you.

As a student

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 Alumni Office receives the following information which includes (but may not be limited to):

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

As one of our alumni or supporters

We gather personal information from you when you enquire about our activities, register for an event, make a donation, volunteer, engage with our social media channels or otherwise provide us, or an alumni group i.e. KCLA 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 taxpayer 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 taxpayer).

We also capture and collect your business details to enhance our mentoring networks and to allow us to send emails and invitations that may be of interest to you.

We use trusted third parties to collect data on our behalf to support our activities. This might include event registrations, donation and Direct Debit processing platforms, and emailing portals. We also 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. These third parties are trusted partners with long-standing data sharing processes in place. Please see the ‘Who has access to your personal information?’ section below for more details.

We may also receive information about you from other sources, which includes publicly available data. Please see the ‘How we use your personal information’ section below for more details.

Sensitive personal information

In some limited circumstances we may process what is known as 'special category' or 'sensitive' data. This may include information regarding your ethnic origin or political, philosophical and religious beliefs, health or sex life. We will only ever record this information where it is useful for the development of our relationship with you, and we will ensure you are aware we are doing so. Occasionally we may also record ‘sensitive’ data which has already been publicised by you.

Cookies

Cookies are small text files stored on your device (desktop, tablet, mobile phone etc.) by your device's web browser. They relate to a specific site and can be used to enhance that site's functionality and your interaction with it; they may also be used for usage tracking, research, targeting etc.

We use cookies from various websites (Facebook, Instagram, Twitter, LinkedIn, KCL Website, YouTube, Mailchimp) which collect data that helps us to optimise ads, build targeted audiences for future ads, and remarket to people who have already taken some kind of action on our website. This will help us to accurately report on live fundraising campaigns and build cost effective media campaigns. 

Analytics

This website uses Google Analytics and Site Improve 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 and Site Improve work, please visit Google Analytics Terms of Service and Site Improve’s Privacy and Security page. If you do not want Google Analytics to use your data, then please visit Google Analytics opt-out browser add-on.

How we use your personal information

We may use your information for a number of purposes including the following:

  • To provide you with direct marketing communications about what we are doing and/or campaigns which may be of interest to you by email, post or phone or on social media channels.
  • To provide you with alumni communications by email unless you have unsubscribed or told us you do not wish to hear from us by email.
  • To provide you with information about our work or our activities that you have requested. This might include sending you e-newsletters, invitations to events and volunteering opportunities.
  • To facilitate alumni events including reunions. As part of this we may include your name (this could be your current name and your name at graduation) on a class list.
  • To take and use photos and/or films of event participants and attendees.
  • For administration purposes, 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 conduct research, analysis and profiling to better understand who our supporters are and more efficiently target our fundraising communications and future activity.
  • To personalise your supporter experience with us.
  • To ensure you receive relevant, personalised and interesting content we may host encrypted personal data on third party websites (for example, social media platforms).
  • To manage our volunteer programme.
  • 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 websites to make it as user-friendly as possible.
  • To pass on to the Higher Education Statistics Agency to undertake the Graduate Outcomes Survey as required by UK law.
  • To use anonymised personal data to benchmark our activity with other relevant organisations, including CASE.
  • To transfer to HM Revenue and Customs in respect of any Gift Aid claims.
  • For statutory and regulatory compliance.
  • To assess your personal information for the purposes of credit risk reduction or fraud prevention.

Research and profiling

In addition to this we may use your data for research and profiling. Philanthropy is vital to King’s to ensure it can continue to support students from all backgrounds and carry out world-leading research which goes above and beyond to solve global challenges. Research and profiling are activities which enable King’s to achieve this as they allow us to gain a better understanding of who we should engage with, 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.

Research – this could include research on financial, business, philanthropic, biographical 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 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 us with, such data as your address, the name of your bank, or where you previously went to school, with data we obtain from other sources. We use this data both to verify we have the correct information, but also to assess whether it would be appropriate to approach you directly about philanthropic opportunities at King’s. Mostly, this work is carried out manually in-house, but occasionally it 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 to identify whether it is appropriate to approach you about higher level giving. This is known as wealth screening and is a tool which helps us to better understand who to approach about fundraising and volunteering opportunities in an appropriate way and therefore generate funds cost-effectively. We also use subscription resources which aggregate publicly available data such as business and philanthropic information or press sources to enable the best quality of research. Please see below for more information on how we work compliantly with third-party suppliers.

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 and always contains manual assessment to ensure we are making correct assumptions from the analysis.

Reunions

As an Alumni Reunion leader (and therefore connected to the college), you are committing to the following:

  • You will only use information, including alumni data, for the purposes of the reunion. You must not use any knowledge gained during your relationship with the Alumni Office to influence a separate relationship you may have with the same individual. If you require the information for any other purpose you must obtain written permission from the Alumni Office.
  • You will not share alumni personal information with any person or organisation without written permission from the Alumni Office.
  • You will return any personal data that has been disclosed to you when it is requested and you will not keep any copies or records of this data.
  • You will store any personal data shared with you securely in a password protected system, and where possible personal data will not be stored in paper form. If paper form is deemed necessary then you will store it in a locked drawer and you will take all reasonable precautions not to inadvertently disclose data.
  • You will delete any confidential data shared with you once it has served its purpose. Where personal data has been stored as a paper document, the document must be shredded or disposed of in a suitable confidential waste bin.

If you are sharing alumni data with the Alumni Office you will:

  • Ensure you have the consent of the individual to share their data with us. Under law, consent to be contacted needs to be freely given, specific, informed, and unambiguous. This means it needs to be made clear to them that they are being introduced to contact them about fundraising/ways of supporting a specific project.
  • Only transfer the contact information and personal data that is necessary.
  • Be aware of Special Category (sensitive) Data. This is personal data that relates to someone’s health; religion; ethnicity; political views; trade unions membership; sexual life or criminal history. If, during the cause of your discussions with an alumnus/a you are made aware of any special category data, you must not pass this information on to the Alumni Office unless that person has overtly expressed that they are happy for you to do so.
  • Ensure any personal data being shared is transferred safely either through a secure File Transfer System, or by using encryption or password protection.

If you are taking photography at the event to share with the Alumni Office it is your responsibility as the reunion leader to ensure the individuals in the photos have given your consent for these photos to be shared.

Please note this agreement will not prevent you disclosing any personal data required of you by law or by any competent authority.

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 will never sell your personal information.

Your data will be passed to the Higher Education Statistics Agency to undertake the Graduate Outcomes Survey (GOS) fifteen months after you complete your studies, as required by UK law. Details on how your information will be used can be found here: Graduate Outcomes Survey.

We may share your data with other third parties and alumni groups such as King’s College London Association or the Friends of King’s College London Association Inc. when it is necessary for the College's legitimate interests or the legitimate interests of the third party.

We may pass your information to our trusted 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.

Sometimes organisations and individuals who work on our behalf may manage information outside the UK or EEA. A transfer out of the UK or EEA may be to countries that are not subject to privacy regimes that are equivalent to the privacy regime in the UK or EEA. In those circumstances, we will make sure that we have a valid reason for doing so and put adequate contractual clauses in place to ensure your data is safeguarded.

Keeping your personal information safe

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. We do not store any credit card details.

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.

We will follow King’s College London’s Data Breach Protection and Mitigation Protocols, in the event that something goes wrong.

How long will we keep your information for?

King’s College London Alumni Office considers its relationship with alumni to be life-long, and with other stakeholders and donors we will retain data in accordance with our data retention schedule. You can stop this relationship at any time by sending a request to forever@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.

Children and privacy

We take the protection of children very seriously. To that end, we require that children under 18 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.

If we obtain knowledge that a child has engaged with our office without consent, we will cease communications at the earliest opportunity and take the necessary steps to obtain consent.

People in vulnerable circumstances

We recognise the importance of protecting our vulnerable supporters and follow the guidance issued by the Chartered 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 King’s College London is in a position to make a free and informed decision. A copy of our full policy can be made available on request.

Communicating complaints and feedback

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: forever@kcl.ac.uk

The Alumni team are available to help Monday to Friday, 9am – 5pm.

You can also complain to the ICO if you are unhappy with how we have used your data:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113

ICO website: https://www.ico.org.uk

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, email forever@kcl.ac.uk or log in to your King’s Connect account.

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 a particular purpose
  • raise a concern or complaint about the way in which your information is being used

For further guidance please see the Information Commissioner’s Office website.

If you wish to talk through anything in our privacy statement, exercise any of your rights above, 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 Office
King’s College London
Virginia Woolf Building
22 Kingsway
London WC2B 6LE

Tel: 020 7848 3053

Email: forever@kcl.ac.uk

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 2022