CONTENTS OF PRIVACY NOTICE FOR ALTRINCHAM GRAMMAR SCHOOL DEVELOPMENTS LIMITED ("AGSD")
- What is AGSD?
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- Combining your data for personalised direct marketing
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How we use your personal data
- Contacting the Regulator
- If you live outside the UK
- Any questions?
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how AGSD uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
2. What is AGSD?
AGSD – which we’ll refer to as ‘the Charity’ in this document – handles data on behalf of related organisations:
- AGSD itself – a company limited by guarantee register in England (03454310) and also a Registered Charity (1071870).
- AGSD Trading Ltd (02562077) – a dormant subsidiary of AGSD which may, in the future, be used for profit-making trading activities.
- Altrincham Grammar School for Boys (“AGSB”). AGSD is independent of the School but we collect donations for the AGSB School Fund.
- The School Parents and Friends Association (“PFA”). Again, AGSD is independent of this organisation but collects donations either for the PFA or the PFA Lotto.
For simplicity throughout this notice, ‘we’ and ‘us’ means the Charity.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, if you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you make a donation under Gift Aid, we need to keep data as specified by HMRC in order to make a valid claim to them.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the Charity to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will also use your address details to send you notifications of Company meetings by post.
4. When do we collect your personal data?
- When you fill in our Membership Form and associated Direct Debit Instruction (“DDI”).
- When you make a donation under the DDI.
- If correspondence posted to you is returned because you have moved away from the address notified to us, we ask AGSB if they have your current details.
5. What sort of personal data do we collect?
- From your completed Membership Form, we record your name, gender, address, email address and telephone number, your son’s name, his entry form and year of intake.
- We also record the details of the donations you choose to make to the AGSD Capital Fund, the AGSB School Fund and to the PFA.
- We record whether you are making donations under Gift Aid.
- We record your bank account details in order to collect your donations via BACS.
- We record details of the successful donations made by you or any unpaid direct debits (“UDD”).
6. How and why do we use your personal data?
When you sign and submit a Membership form, including a DDI, we record your personal data into our bespoke database system. We then write to you confirm the data held in our systems which we ask you to verify and notify us of any errors or omissions.
By using securely encrypted messages, we notify your bank (via the BACS AUDDIS notification) that we have received a new valid direct debit authority. We then generate collection data each month and transmit this to BACS in accordance with your DDI.
Should you change banks, or cancel your DDI, we receive an ADDACS notification from BACS and we update our database accordingly. If you change banks we send a notification to your new bank as an AUDDIS instruction that we will commence collection from your new account.
In addition to collection donations to the AGSD Capital Fund, we also collect amounts indicated by you for transmission to the AGSB School Fund (which is controlled by. The Headmaster) and amounts on behalf of the PFA. The PFA donations are in respect of their monthly “Lotto” draw unless you delete the word “Lotto” on your donation form. We cannot claim Gift Aid on Lotto donations – however, we can if your donation does not form part of the Lotto entry.
At the end of each Fiscal year, we submit to HMRC details of the donations made by you in the previous tax year as part of our claim for Gift Aid relief.
Your bank account details are not disclosed to any third party.
The School Accounts team maintain our financial records and therefore we pass to them details of individual collections made and the split between the funds.
We also pass data to the PFA of individuals (and amounts donated) for entry by them into their Lotto draw. We do not pass individual details of any amounts donated which are not Lotto related.
7. Combining your data for personalised direct marketing
We do not undertake any personalised direct marketing. Should we change our decision, we shall obtain your explicit consent before commencing.
8. How we protect your personal data
We know how much data security matters to all our donors. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to our bespoke database to restricted users and use banking standard encryption technology to transmit our collection file to BACS for processing.
Access to your personal data is password-protected, and sensitive data (such as DDI information) is secured by encryption within our bespoke database.
We regularly monitor our system for possible vulnerabilities and attacks.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis.
10. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties (being AGSB and the PFA).
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our dealings with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our donors into consideration.
11. Where your personal data may be processed
If you are based outside the UK, or emigrate, and donate to us, we will maintain the personal data that we collect from you in the Charity database in the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. Our primary database is maintained in the UK. However, the entire database is mirrored using a cloud-based service whose servers are primarily based across the USA. All such data is heavily encrypted.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that the Charity holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact the Company Secretary at our Registered Office, or via the AGSB School
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. If you cancel your DDI we shall consider that a withdrawal of consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. How we use your personal data
AGSB and PFA use your personal data for the purposes of essential administration only.
Personal data we request from AGSB
We write to each donor every year in accordance with our legal requirement to send you notice of our Annual General Meeting (“AGM”). If you have moved address and have not advised us, we request AGSB to provide us with your current address based on your son’s name and year of entry into the School. We do this as we need to record your current postcode in order to make a valid Gift Aid claim to HMRC.
14. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
15. If you live outside the UK
For all non-UK donors
By providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK and the USA.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
16. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Company Secretary who will be pleased to help you:
This notice was last updated on 29/04/2021
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