Privacy

[NAME OF ORGANISATION and any subsidiaries] maintains a database of [alumni/ friends/ supporters/ parents] in order to stay in touch with our community and keep you updated about news, events, careers initiatives and fundraising activities [edit / expand as appropriate].
 
Some of our database (but not all) choose to join our online community by registering on this website and creating an online profile. In both instances (individuals with offline database records and individuals with online profiles), we collect and store personal information (or “data”) about you. We are committed to protecting and respecting your privacy and this Policy sets out what information we collect about you, where and how we use (“process”) it.
 
We may change this Policy from time to time. If we make any significant changes we will advertise this on the website or contact you directly with the information. Please check this page occasionally to make sure you are happy with any changes.
 
If you have any questions about this Policy or concerning your personal information, please contact [Data Protection Officer] [or otherwise refer to contact/helpline] at [email/ address/ phone].
 
For the purposes of the General Data Protection Regulations (GDPR) and any subsequent UK legislation covering data protection, the Data Controller is [NAME OF ORGANISATION].
 
What type of personal information we collect
 
The information we have about you depends on where we collect it, but may include:
 
[Include/ delete/ amend list as appropriate]
 

• First name
• Last name
• Email
• Address
• Photographs
• Gender
• Date of birth
• Family relationships
• Years at [organisation]
• Higher education and work details
• Participation in our events, emails, competitions, surveys and other activities
• Donations made to [organisation]
• Geo-location data (your geographical location based on your IP address)
• Log-ins and activity on the website
• A record of payments made via the website (but we do not store your credit/ debit card details as these are processed securely externally by a third-party payment provider) which could include event tickets, shop purchases or online donations
• Consent options and communication preferences
• Content (such as announcements, stories, photos, documents, comments, events, jobs) that you post on this website or provide to us by other means
• Messages that you send to other community members via the direct messaging system when logged in to this website

 
Where we collect information from
 
We collect personal information when you:
 
[Include/ delete/ amend list as appropriate]
 

• visit this website
• create or update your online profile
• post content on to this website or other websites and social media sites managed by [organisation]
• take part in an event
• attend a meeting with us and provide us with information
• contact us in any way including online, email, phone, SMS, social media or post
• open an email sent from this website
• send a message via the direct messaging system on this website
• leave [organisation] and we transfer some basic details about you from the main [organisation] database in to our [alumni] database

 
[Note: we have not included public sources used in data matching and tele-appending, on which further advice should be sought, if relevant to your organisation]
 
How we use your information
 
We will use your personal information in a number of ways, always with a legal basis for processing your data. These may include:
 
[Include/ delete/ amend list as appropriate]
 

• providing you with the information or updates that you have asked for
• sending you communications (with your consent if required) that may be of interest, including invites to events, newsletters and fundraising campaigns
• delivering our obligations under any contract between us
• seeking your views on the services or activities we carry out, so that we can make improvements
• updating our database records and ensuring we know how you prefer to be contacted
• analysing your engagement with our website and other content to help us improve our services for you
• running our mentoring programme/ club activities/ reunion events/ sports fixtures

 
[Note: The above is a selection of the ways in which data might be used. You should delete where not applicable and add any other intended uses you have. Note that we have not included profiling, wealth screening or transference of personal data off the ToucanTech database to other third-parties – you should clearly state if you are doing any of these things, and potentially seek legal advice on the nature of this processing.
 
Our legal basis for processing your information
 
The use of your information for the purposes set out above is lawful because one or more of the following applies:
 

• you have given us your consent for the information to be used
• it is necessary for us to hold and use your information to carry out our obligations under a contract entered into with you
• it is necessary for our legitimate interests to hold and use your information and we are not impacting your privacy by doing so

 
[Note: there may be other legal bases or you may want to include additional details, specifically around what consents you capture and which types of processing rely on legitimate interests. It’s currently not required that you state your specific legal bases in your privacy policy but the ICO’s position on this might change]  
 
Updating your consent preferences
 
If you have an online profile on this website you can update your consent options by logging-in and clicking on “My Settings” in your profile.  Scroll down to find your ‘Consent options’ where you will see a list of consents and the options “opt-in”, “opt-out” and “unspecified”.
 
Via ‘My Settings’ you can also choose to hide your profile from Google, limit access to your profile so that it’s only viewable to your connections and adjust some of the automatic notifications that you receive from this website.  Please note that your name (but not full profile) may appear in various places around the community website, such as a ‘Recent Joiners’ box and in ‘Search’ results irrespective of the privacy settings you have selected. 
 
If we are using consent as our legal basis for processing your data, we must have an explicit “opt-in” from you for this specific type of processing.
 
If we are using legitimate interests as our legal basis for processing your data, we will process your data responsibly in a way that you would reasonably expect, and you can opt-out at any stage.
 
If you click ‘unsubscribe’ at the bottom of one of our emails sent you will be automatically opted-out of these types of email communications in the future.
 
If you want to contact us about your consent preferences please contact [details] by telephone/ email [details].
 
How we keep your information safe
 
We understand the importance of keeping your personal information secure and take appropriate steps to safeguard it.
 
Your data is stored on a dedicated, secure cloud server hosted by Amazon Web Services (AWS) in the EU and managed by our website provider, ToucanTech.  Industry standard firewalls, anti-virus, encryption and back-up methods are in place, as well as strict data handling protocols.
 
We always ensure only authorised persons have access to your information, which means only our approved employees and contractors, and that everyone who has access is appropriately trained in data management.  
 
If you have an online profile for this website you are responsible for keeping your login details (email and password) confidential and we ask that you do not share your password with anyone.
 
No data transmission over the internet can be guaranteed to be completely secure. So, whilst we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.
 
Who has access to your information?
 
[Include/ delete/ amend list as appropriate]
 

• Third parties who provide services for us, for example [insert details such as, collecting or processing data and sending mailings]. We select our third-party service providers with care. We provide these third parties with the information that is necessary to provide the service and we will have an agreement in place that requires them to operate with the same care over data protection as we do

 

• Third parties if we run an event in conjunction with them. We will let you know how your data is used when you register for any event

 

• Web hosting, email hosting, analytics and search engine providers that enable us to run our community database and improve our website and its use

 

• Third parties in connection with restructuring or reorganisation of our operations, for example if we merge with another business. In such event, we will take steps to ensure your privacy rights will be protected by the third party

 
[Note: ToucanTech does not transfer the personal data of EU customers outside of the EEA, but if you make transfers of your data to third parties outside of the EEA for other reasons, please include details here and explain how you are ensuring compliance with GDPR]
 
Other than this, we will not share your information with other organisations without your consent.
 
Keeping your information up to date
 
Please would you let us know if your contact details change. Online members can update your details directly by logging-in to the website and clicking on ‘My Settings’ under your profile.  You can also update your details by contacting us at [insert details].
 
Cookies
 
Some information and data may be automatically collected through the use of cookies on this website. Cookies are small text files employed on the website to recognise repeat users and allow us to observe behaviour and compile aggregate data in order to improve the user-experience we provide for our website visitors.
 
The law states that we can store cookies on your machine if they are essential to the operation of the website, but that for all others we need your permission to do so.
 
The list below explains the cookies we use and why:
 

Cookie Description	Name	Purpose
Session Cookie	[Organisation]_Member_Code [Organisation]_PyroCMS	Used to remember you as you travel from page to page in a single session (without leaving the website) in order to provide a continuous and unified experience
Functional Cookie	[Organisation]_Identify	Used to remember your login details when you return to the website after previously logging out, by storing them in your browser. This cookie is turned off by default and is only activated when you select the ‘Remember Me’ check box during login.

 
Opting out of cookies
 
If you do not wish to receive cookies from us or any other website, you should be able to turn cookies off on your web browser: please follow your browser provider’s instruction in order to do so.  Unfortunately, we cannot accept liability for any malfunctioning of your computer or its installed web browser as a result of any attempt to turn off cookies.
 
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
 
Use of aggregated data
 
Where data can be aggregated and anonymised, our website provider (ToucanTech) might use this for research purposes without restriction. For example, they may monitor traffic patterns, site usage, response rates and data trends to help make improvement to the website software. They are entitled to do this because the resulting data will not personal identify you and will therefore no longer constitute personal data for the purposes of data protection laws.
 
[Note: it’s optional if you decide to include this – we won’t be processing personally identifiable data for any research/ benchmarking/ usage analysis]
 
How long we keep your information for
 
We will hold your personal information for as long as it is necessary for the relevant activity. [Include link to a Record Retention Policy if you have one]
 
Where we rely on your consent to contact you for direct email marketing/ fundraising purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. This will usually be for [two] years. We may periodically ask you to renew your consent.
 
If you ask us to stop contacting you, we will keep a record of your contact details and limited information needed to ensure we comply with your request. If you ask us to remove your personal data from our database we will delete all the information we hold out apart from your name and the dates that you attended [organisation] and archive your record in our database.
 
Your rights
 
You have the right to request details of how we use your personal information through making a subject access request.  Such requests have to be made in writing by contacting [details].
 
You also have the following rights:

• to request rectification of information that is inaccurate or out of date;
• to erasure of your information (the “right to be forgotten”);
• to restrict the way in which we are dealing with and using your information;
• to request that your information be provided to you in a format that is secure and suitable for re-use (the “right to portability”);
• in relation to automated decision making and profiling.

All of these rights are subject to certain safeguards and limits or exemptions.  To exercise any of these rights, you should contact [details] at the above address.
 
If you are not happy with the way in which we have processed or dealt with your information, you can complain to the [insert details of local regulator – in the UK this is the ICO].  Further details about how to complain can be found here.
 
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This Policy was last updated in [MONTH AND YEAR]