Privacy

(Comprising King’s School, Bruton and Hazlegrove – “the School”)

DEVELOPMENT AND FUNDRAISING PRIVACY NOTICE

This is a combined policy that applies to both King’s School, Bruton and Hazlegrove Preparatory School.

Introduction
This notice explains how and why the School’s Development Office collects personal information about you when carrying out our development and fundraising activities.

This notice also outlines what we do with your information and what decisions you can make about your information in relation to fundraising and development.

If you have any questions about this notice please contact Louis Tuson, Bursar, whose contact details are lst@kingsbruton.com or 01749 814203, King’s Bruton, The Plox, Bruton, Somerset, BA10 0ED, in relation to any of the matters set out in this document.

The School works in close conjunction with the Old Brutonian Association which is a separate entity from the School. However, the School is responsible for how your personal information is used and is the controller of this information for data protection purposes.

This notice just covers how the School uses your personal data for development and fundraising purposes. For more information about how the School uses your information more widely (for example, in relation to the provision of education to pupils) please refer to King’s website (www.kingsbruton.com) for a copy of the appropriate privacy notice.

What is personal information?
Personal information is information that identifies you as an individual and relates to you. This includes your contact details, your relationship with the School and financial information. What personal information does the School hold about you and how is this obtained? We receive information about you from other teams within the School but only where this is relevant to our work. We hold a specific database with information about alumni, parents, staff, former parents, former staff and other supporters.

You provide us with information about yourself during the course of our relationship with you. For example, when you sign up to receive communications from us or order tickets for events.

In addition, we may obtain your information from other public sources, such as LinkedIn, Zoopla and media articles.

We will hold information such as:

the dates when you or your child attended the School (if applicable);
if you are a former staff member the dates when you worked at the School;
your contact details;
your relationship details including the names of your family members;
key dates including birth, marriage and death; • information about your achievements and interests e.g. which sports teams or music ensembles you were involved in and possible scholarship exhibitions;
where you attended university and your occupation (if applicable);
how you like to hear from us e.g. whether you have signed up to receive emails from us;
your involvement with us e.g. if you attend events, support careers or networking activity, carry out mentoring;
records of any donations;
your Gift Aid status if applicable;
information from articles in the media;
any dietary requirements for catering purposes that you have provided; and
any disability information which you may have provided so that we may make reasonable adjustments for you.

Why do we use your personal information?

We use your information in the following ways:

to keep you informed about events (such as concerts and drinks receptions) and activities, and in relation to your attendance at those events;
to tell you about products sold to benefit the School such as clothing and sports goods;
to keep you informed about what is happening at the School, for example, by sending you eBulletins, magazines (e.g. the Old Brutonian magazine) and publications;
in connection with providing financial support to the School (including making donations to the School for specific campaigns, such as for new buildings and facilities, for bursaries, and requests for sponsorship);
in connection with the other ways in which you might support the School (such as volunteering, providing careers advice or mentoring);
the School keeps documents such as photographs and records of achievements to build up an archive for historical reasons.

We will contact you for the above purposes by email, telephone or post. If you tell us that you do not want to be contacted for any of these purposes then we will of course respect that.

If you wish to make a donation, we will carry out financial due diligence on you. This will involve obtaining your personal information from public sources such as internet search engines, Zoopla and related media articles. This is to comply with our legal obligations.

We may take photographs or videos of you to use in our publicity or on our social media platforms and website.

How and why does the School share your personal information with third parties?

If you use a third party platform to donate then we will receive information about you from them, such as Just Giving.

If you attend one of our events, then we will share your information with event booking platforms and joint hosts such as events with King’s School.
In accordance with our legal obligations, we will share information with local authorities, the Independent Schools Inspectorate / Ofsted and the Department for Education, for example, where we have any safeguarding concerns.
On occasion, we may need to share information with the police for the prevention and investigation of crime and the prosecution of offenders.
We may also need to share information with our legal advisers for the purpose of obtaining legal advice.
We will need to share information if there is an emergency, for example, if you are hurt whilst on School premises or at one of our events.
We use contractors to help us with our work (e.g. mailing houses, printers) or where we store our database in the cloud.
We may share archived material for the purposes of research. For example, if someone is carrying out research in order to write a book.

The School shares information about you with the Old Brutonian Association. This is explained in more detail above.

Our legal grounds for using your information

This means that we are using your information when this is necessary for our legitimate interests, except when your interests and fundamental rights override our legitimate interests. We rely on legitimate interests to use your information for all of the purposes described above unless consent applies (in which case see below). Specifically, we have a legitimate interest in:

ensuring that there is an active community of supporters which will benefit the School and members of the School community, such as current and former pupils and parents;
promoting the objects and interests of the School. This includes fundraising e.g. if we want to raise money for the bursary fund or new buildings;
using your personal information to administer our events;
safeguarding and promoting the welfare of our pupils with whom you may be in contact e.g. if you arrange work experience or mentor a pupil; and
ensuring that we comply with our legal obligations.

If you object to us using your information where we are relying on our legitimate interests as explained above please speak to the Director of Development.

In some cases, we are processing your personal information because you have given us your consent to do so. If we ask for your consent to use your personal information you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. To withdraw your consent please contact the Director of Development at thp@kingsbruton.com

Necessary for a contract

We will need to use your information in order to perform our obligations under a contract with you, for example, we need your name and contact details so that we can send you tickets for a concert that you want to attend.

Legal obligation

On some occasions we will need your information to comply with a legal obligation. For example, we may need to keep a record of who is attending an event so that we can comply with our health and safety obligations.

Vital interests

For example, to prevent someone from being seriously harmed or killed.

The following section contains information about the legal basis that we are relying on when handling your information:
The School's grounds for processing special personal information will depend on the circumstances.

Vital interests

To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.

Legal claims

The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.

These two conditions may also apply if we ever need to process information about criminal convictions and offences.

The School must also comply with an additional condition where it processes special categories of personal information. These special categories are as follows: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information, and information about sex life or orientation.

Sending your information to other countries

We may send your information to countries which do not have the same level of protection for personal information as there is in the UK. For example, we may:

store your information on computer servers based overseas; or
communicate with you when you are overseas (for example, when you are on holiday or if you live in a different country).

The European Commission has produced a list of countries which have adequate data protection rules. The list can be found here:
http://ec.europa.eu/justice/dataprotection/internationaltransfers/adequacy/index_en.htm

If the country that we are sending your information to is not on the list, or is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland), then, in the absence of any other safeguards, it might not have the same level of protection for personal information as there is in the UK.

Where appropriate we may put in place additional safeguards, for example, if we are using a third party to process a payment then we may ask them to contract with us using model data protection clauses provided by the European Commission in the absence of any other appropriate safeguard. If you would like more information about the safeguards that are in place please contact the Director of Development.

For how long do we keep your information?
We will keep information about you for as long as we need to do so, in compliance with our data protection and other legal obligations. For example, we will need to retain contact details for you for so long as you want to be part of the school community so that we can communicate with you.

We will also need to keep a record if you tell us that you do not want to hear from us anymore, so that we do not inadvertently add you to our mailing list in the future.

We will keep information about you for a very long time or even indefinitely if we need this for historical, research or statistical purposes. For example, if we consider the information might be useful if someone wanted to write a book about the School.

The School will also keep information for a long time as part of its wider legal and regulatory obligations, even if that information is no longer needed for marketing, development or fundraising purposes. This is especially relevant to former staff, pupils and parents. For more information on how personal information is used by the School more widely please contact the Bursar.

Our information and records retention policy sets out how long we keep different types of information. If you wish to see a copy of this, please contact the Bursar or visit the policies page on the website – www.kingsbruton.com.

What decisions can you make about your information?

From May 2018 data protection legislation gives you a number of rights regarding your information. Some of these are new rights whilst others build on your existing rights. Your rights are as follows:

Rectification: if information is incorrect you can ask us to correct it.
Access: you can also ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to.
Deletion: you can ask us to delete the information that we hold about you in certain circumstances. For example, where we no longer need the information.
Portability: you can request the transfer of your information to you or to a third party in a format that can be read by computer in certain circumstances.
Restriction: our use of information about you may be restricted to simply storing it in some cases. For example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy.
Object: you may object to us using your information where:

- we are using it for direct marketing purposes (e.g. to send you the School magazine;
- the legal ground on which we are relying is legitimate interests. Please see the section "Our legal grounds for using your information" above;
- we are using it for historical or scientific research purposes or archiving purposes. For example, we may keep photographs of your class for historical reasons.

The Bursar can give you more information about your data protection rights. To exercise any of your rights you can submit your request in writing to the Bursar at King’s Bruton, The Plox, Bruton, Somerset, BA10 0ED

Further information and guidance

The Bursar is the person responsible at our school for managing how we look after personal information and deciding how it is shared in relation to fundraising and development. Like other organisations we need to keep your information safe, up to date, only use it for what we said we would, destroy it when we no longer need it and most importantly - treat the information we get fairly. This notice is to explain how we use your personal information.

The Bursar can answer any questions which you may have. Please speak to the Bursar if:

you object to us using your information for marketing purposes e.g. to send you information about fundraising events. We will stop using your information for marketing purposes if you tell us not to; or
you would like us to update the information we hold about you. If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office - ico.org.uk.

Version 1
Next Review: September 2023