London South Bank University Privacy Notice - Alumni and Supporters

Purpose of this Privacy Notice:

Our alumni and supporters are extremely important to us. This Privacy Notice explains how we, London South Bank University, use the personal data our Alumni and Development Department collects from our alumni and supporters. 

We are the data controller for personal data relating to you and this Privacy Notice explains how we will process your personal data. This Privacy Notice will be kept under review and any changes will be updated on our website and communicated to you as appropriate.

This Privacy Notice was last updated in December 2022. 

Who does this privacy notice cover?
This privacy notice covers LSBU alumni who have completed a course of over 12 months’ duration. It also covers individuals who have chosen to support LSBU in some way that is under the remit of the Alumni and Development Department and have consented to be contacted for one of the purposes set out below. This notice only covers processing of personal data for Alumni and Development purposes as set out below. For other personal data processing related to former-students and alumni see the Student Privacy Notice.

What personal information do we collect?
We may hold a range of personal data about you from a number of sources. 
The majority of the personal data that we hold is information provided to us by you. If you are an alumna/ alumnus of LSBU, personal data collected during your time as a student is transferred from your student record such as your name, date of birth and gender to LSBU’s alumni database when you complete your course.  We may also add information provided by you during interactions with you. If you are a supporter of LSBU, the personal data we hold may be information provided by you during your interaction with us.

Examples of categories of personal data which we may hold are:

• Personal identifiers – e.g. your name, gender, student/ alumni numbers and your date of birth;
• Contact details – e.g. your postal/ email address, telephone number and contact preferences;
• Information about your time at LSBU – e.g. the courses you completed and your membership of clubs and societies;
• Career details – e.g. job role;
• Records of donations – including financial details and Gift Aid status, where applicable (as required by HMRC);
• Communications between the Alumni and Development Department and you;
• Information about your interactions with LSBU – e.g. records relating to volunteering activities on behalf of the University, online interactions with us on social media, information about your use of University resources or facilities (e.g. the library), information on your engagement with University meetings, events, groups or networks;
• Results of automated decision making and profiling processes to focus our interactions with you

We may also hold information collected from publicly available sources, such as social media posts, internet searches and websites, and may augment this information with the personal data you provide to us. 

Why are we collecting your personal data/what are we doing with it (purposes)?
We only process data for specified purposes and if it is justified in accordance with data-protection law. In general terms, we process your personal data for the purposes of increasing alumni involvement with the student experience at LSBU, fundraising, alumni/ supporter communications and related activities by the Alumni and Development Department. More specifically, these activities may include:

• sending you publications (e.g. alumni magazines and email newsletters about LSBU and fundraising activities);
• inviting you to alumni and supporter events, reunions and University events;
• informing you of benefits available to alumni and supporters;
• asking you to support LSBU (e.g. contributing to student mentoring schemes or donations);
• fundraising programmes;
• wealth analysis and research in order to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications; and
• internal record-keeping and administration (e.g. to process a donation or administer an event which you are attending).

There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter. Use of our websites, including our use of cookies, is covered by our website privacy notice: http://www.lsbu.ac.uk/footer/privacy, and https://www.lsbu.ac.uk/footer/data-protection/cookies.

Do we use any automated decision making or profiling?
Automated individual decision-making means making a decision solely by automated means without any human involvement and profiling means the automated processing of personal data to evaluate certain things about an individual. We may use automated or manual analyses including segmentation or profiling to link data together to send you communications which are relevant and timely, to identify opportunities which may be of interest to you, to help us identify your potential for supporting LSBU and to avoid approaching you with opportunities which are not of interest. We may carry out wealth screening to focus our conversations with you and ensure we provide you with an experience which is appropriate for you.

What legal bases do we rely on for processing your personal data?
Depending on the activity being carried out, we will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your data, as explained below.

• UK GDPR Article 6(1)(a) – Consent of the data subject
  Unless mentioned below, we will only process your personal data in relation to alumni and development purposes where we have your consent. This means we will only email you, or call TPS registered numbers, if we have your express consent to do so. We may contact you by post, unless you have asked us not to. We will also only contact you about University news, events or to ask for a donation if we have your express consent to do so.
• UK GDPR Article 6.1(f) -Processing is necessary for the pursuit of our legitimate interests 
  Processing of student record data for alumni under legitimate interests for the purpose of monitoring our academic services and providing you with information (e.g. copy of transcript, confirmation of degree etc.) is covered in the Student Privacy Notice.
• UK GDPR Article6 (1)(c) – Processing is necessary for compliance with a legal obligation 
  If you make or have made a charitable donation we will process your name, address, and donation information under 6(1)(c) of the GDPR for the purpose of administering your donation and claiming Gift Aid on your behalf. We may also use available sources to carry out due diligence checks in line with the University’s Gift Acceptance Policy and to meet money laundering regulations. If you withdraw consent, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. The University has a legal obligation to supply some of the information we hold about you, as a graduate, to the Higher Education Statistics Agency (HESA) – the official agency for the collection, analysis and dissemination of quantitative information about higher education in the United Kingdom. HESA will treat your data in line with its collection notices. HESA produces official statistics (such as university league tables) and its outputs are regulated by the UK Statistics Authority, which has a direct line of accountability to Parliament.
• UK GDPR Article 6.1(e) – Processing is necessary to carry out tasks in the public interest 
  In addition, we may undertake some processing for the performance of tasks carried out in the public interest or in the exercise of our official authority. 

Who do we share your personal data with? What data do we share?
On occasion we may need to share your data internally and with third parties. The following table lists what information we may share with whom.

How are we protecting your personal data and is it transferred outside of the UK/EEA?
Your personal data is held securely on LSBU’s alumni and supporter database, which is accessible by a limited number of staff. We use a database called The Raisers Edge, owned by Blackbaud Inc., which is a secured cloud based, and password protected, database. Blackbaud Inc is a US company however our data is hosted on servers located in the UK and EEA only.
We ensure we have appropriate data sharing agreements in place before sharing your personal data.
We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them.
LSBU is committed to working in a transparent, ethical, responsible and honest way. To reflect this commitment, we are a member of the Fundraising Regulator and committed to the Regulator’s Code of Practice.

Your rights as a data subject
The UK GDPR gives you certain rights:

• The right to be informed – we will inform you if we are using or storing your personal information.
• The right of access – you can ask us for a copy of your personal information by making a subject access request.
• The right to rectification – if you think the personal information, we hold about you is not right you can ask us to correct it. 
• The right to erasure – you can ask us to delete your information and, if we are able to, we will do so. 
• The right to restrict processing – you may want to stop us from using your information for some purposes. 
• The right to information portability – as well as being able to ask for a copy of your information you can ask for it to be in a format that makes it accessible if you wish to share it with others.
• The right to object – If you are concerned about how we are using your information tell us. 
• Rights in relation to automated decision making and profiling – if you think that we have made a decision about you automatically (by, for example a machine or computer) you can ask for the decision to be reviewed by a living person.

These rights are not absolute. Whilst you can ask for certain things to happen, there may be reasons why we cannot comply. For example, we may have to keep information that you would like deleted for legal reasons. For more detailed information about your individual rights please refer to the Information Commissioners Office. 

How long is your personal data kept?
Personal data in support of your alumni relationship with LSBU will be kept until there is no longer a legal basis for holding it, until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent. 
Our retention schedules are publicly available at Student Records Retention Schedule (lsbu.ac.uk) 

How can you maintain your personal data?
You can update, amend or correct the data we hold about you by registering on the alumni website at https://alumni.lsbu.ac.uk/update-your-details or by contacting the Alumni and Development Department by email, phone or post. You can also change your communication preferences at any time to restrict how we process your data, or opt out of some or all communication. 

Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer:

Alice Black – Data Protection and Information Compliance Officer
Address: London South Bank University, 103 Borough Road, London, SE1 0AA
Email: dpa@lsbu.ac.uk
Telephone: 020 7815 6170

Complaints to the Information Commissioner
You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.