WHO WE ARE
The Old Shirburnian Society (referred to in this policy as the Society) is an umbrella organisation which cares for the members of the Sherborne family throughout the world with the aim of creating and fostering good relations between the School and all interested parties, with the objective of building and maintaining support for, and pride in, all that the School seeks to achieve. The Society also operates the Old Shirburnian Society Charitable Trust 1975 whose objective is the advancement of education in any part of the world, for charitable purposes relating to Sherborne School and for the provision of bursaries at the School (for public benefit). The Charity is registered with the Charity Commission for England and Wales (registration number 271592). The Society’s address is OSS, Sherborne School, Abbey Road, Sherborne, Dorset, DT9 3AP.
WHAT THIS PRIVACY NOTICE IS FOR
This policy is intended to provide information about how the Society will use (or “process”) personal data about individuals including:
- Alumni (from Sherborne School, Sherborne International and the School’s overseas operations)
- Honorary Old Shirburnians
- Current and Past Parents, Carers or Guardians (referred to in this policy as “parents”)
- Sherborne School Staff (past and present)
- Friends of Sherborne School
- Pupils and Potential Pupils on whom we hold bursary application material
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Old Shirburnians, parents, staff and Friends of Sherborne School are all encouraged to read this Privacy Notice and understand the Society’s obligations to its entire community.
This Privacy Notice applies alongside any other information the Society may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to the Society’s agreement to the School’s other relevant terms and conditions and policies, including:
- any contract between the School and its staff or the parents of pupils;
- the School’s policy on taking, storing and using images of children;
- the School’s CCTV and/or biometrics policy;
- the School’s retention of records policy;
- the School’s safeguarding, pastoral, or health and safety policies, including as to how concerns or incidents are recorded; and
- the School’s ICT policies, including its Acceptable Use Policy and Mobile and Remote Working Policy.
Anyone who works for, or acts on behalf of, the Society (including staff, members, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice which also provides further information about how personal data about those individuals will be used.
RESPONSIBILITY FOR DATA PROTECTION
Sherborne School’s Information Governance and Privacy Compliance Officer will deal with all your requests and enquiries concerning the Society’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law
WHY THE SOCIETY NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to its membership, the Society needs to process a wide range of personal data about members as part of its daily operation.
Other uses of personal data will be made in accordance with the Society’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
TYPES OF PERSONAL DATA PROCESSED BY THE SOCIETY
This will include by way of example:
- names, addresses, telephone numbers, e-mail addresses and other contact details;
- bank details and other financial information, e.g. about members and other people who pay for tickets to Society events and for merchandise to the Society.
- financial information on applicants seeking bursaries through the Old Shirburnian Charitable Trust 1975 is processed via the Society’s committees.
- career information for the furtherance of the Society’s careers network operation and the organisation of our graduate event programme;
- correspondence with members including the organisation of Society events;
- images of members (and occasionally other individuals) engaging in Society activities.
HOW THE SOCIETY COLLECTS DATA
Generally, the Society receives personal data from the individual directly in the form of memberships. This may be via a form, or simply in the ordinary course of interaction or communication.
However in some cases personal data will be supplied by third parties, for example Sherborne School, or other professionals or authorities working with that individual; or collected from publicly available resources
WHO HAS ACCESS TO PERSONAL DATA AND WHO THE SOCIETY SHARES IT WITH
The Society will need to share personal information relating to its community with third parties, such as:
- The Sherborne Pilgrims where that individual is a member or potential member of the Pilgrims Club;
- The Old Shirburnian Golfing Society (OSGS) where that individual is a member or potential member of the OSGS
- The Old Shirburnian Sailing Society (OSSS) where that individual is a member or potential member of the OSSS
- Mailing Houses used by the Society for bulk mailings
- For the most part, personal data collected by the Society will remain within the Society, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).
- All interested parties are reminded that the Society abides by School’s Safeguarding Policy and will record and report incidents and concerns that arise or are reported to it to a Designated Safeguarding Lead.
- Finally, in accordance with Data Protection Law, some of the Society’s processing activity is carried out on its behalf by third parties, such as ICT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the Society’s specific directions.
HOW LONG WE KEEP PERSONAL DATA
The Society will retain personal data in accordance with the records retention policy of the School. In the case of Alumni, this would be permanent if kept for a legitimate and lawful reason and unless requested otherwise.
If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Society.
A limited and reasonable amount of information will be kept for archiving purposes: for example, even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a “suppression record”)
KEEPING IN TOUCH AND SUPPORTING THE SOCIETY AND THE SCHOOL
The Society will use the contact details of alumni and other members of the Sherborne community to keep them updated about the activities of the Society and the School including the organisation of Society events and sending updates and newsletters, by email and by post.
Should you wish to limit or object to any such use, or would like further information about them, please contact the Society in writing. You always have the right to withdraw consent, where given, or otherwise object to direct contact. However, the Society is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
- Rights of access, etc
- Individuals have various rights under Data Protection Law to access and understand personal data about them held by the Society, and in some cases ask for it to be erased or amended or have it transferred to others, or for the Society to stop processing it – but subject to certain exemptions and limitations.
- Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, should put their request in writing to the Society.
- The Society will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, (which is one month in the case of requests for access to information).
- The Society will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the Society may ask you to reconsider or require a proportionate fee (but only where Data Protection Law allows it).
- Requests that cannot be fulfilled
- You should be aware the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals or information which is subject to legal privilege (for example legal advice given to or sought by the Society, or documents prepared in connection with a legal action).
- You may have heard of the “right to be forgotten”. However, we will sometimes have compelling reasons to refuse specific requests to amend or stop processing personal details; for example a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such request will be considered on their own merits.
- Where the Society is relying on consent as a means to process personal data, any person may withdraw this consent at any time. Please be aware however that the Society may not be relying on consent but have another lawful reason to process the personal data in question even without your consent.
- That reason will usually have been asserted under this Privacy Notice or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment or because a purchase of goods, services or membership of an organisation has been requested).
- Whose rights?
- The rights under Data Protection Law belong to the individual to whom the data relates.
DATA ACCURACY AND SECURITY
The Society will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the OSS Secretary either by post or email at the addresses below , of any changes to information held about them.
An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under Act): please see above.
The Society will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to systems. All Society staff will be made aware of this policy and their duties under Data Protection Law and receive relevant training.
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to the School’s Information Governance and Privacy Compliance Officer.
If an individual believes that the Society has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the School’s complaints / grievance procedure and should also notify the School’s Information Governance and Privacy Compliance Officer. The individual involved can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with the Society before involving the regulator.