Privacy Notice: Advancement
Our relationship with our alumni, friends and supporters, is of great importance to Imperial College London. We value the generous support of those who are committed to helping us promote our academic mission and build our global reputation.
As a controller of personal data relating to our alumni, friends and supporters we are committed to maintaining the high standards that you would expect from the College in terms of how we respect and care for your personal information.
This Privacy Notice describes how the College collects, holds and uses the personal data that we process in the course of our work around alumni relations, events, fundraising and charitable giving. This data processing is mainly carried out by the Advancement Division, but other College departments also contribute to it.
This Privacy Notice should be read in conjunction with any other relevant information the College provides to you from time to time regarding how your data is used. Data relating to Advancement events will also be processed in line with the College Events Privacy Notice.
Personal data held and processed for Advancement purposes may include:
Contact and communications information, such as:
- Your contact details, which may include your parental or personal address
- Links to your social media accounts
- Your communication preferences, including any consent or opt-out you have provided us with
Biographical information, such as:
- Your name, gender, nationality and date of birth
- Your professional activities and employment, including work contact details
- Your links to organisations such as businesses and business networks, trusts and foundations
- Your education history at other schools or universities
- Media articles about you
- Information you have publicly shared on social media
- Your personal interests
We may also process biographical information about your family, such as your partner or spouse and children.
Financial information, such as:
- Your donation history, including gift amount, purpose, date, method of payment and cheque numbers or other payment references
- Your bank account number, name and sort code, for processing Direct Debits
- Credit or debit card details provided directly to us in the process of making a gift. Note that credit and debit card payments made using our online forms are processed by our payment processing supplier according to their terms and conditions, and are not processed directly by us.
- Your tax status and Gift Aid declaration information
- Details of your other financial transactions with us, such as event tickets purchased
- Our assessment of your ability and willingness to make donations, including considerations of wealth
- Donations you have made to other organisations
Interaction with the College, such as:
- Your education at Imperial
- Your attendance at events
- Records of meetings, conversations and correspondence with you
- Your website activity and interaction with emails we send
- Your relationships with other Imperial alumni, donors and friends
- Your volunteering activity for the College, including alumni volunteering
- Your student clubs or societies affiliations and other connections with the College
Special Category Data
We may also collect, store and use “special categories” of more sensitive information, but only with your consent and when it is relevant to your relationship with the College. This information may include:
- Information relating to disability, if it has been provided by you for a specific purpose, such as event planning.
- Information relating to dietary requirements, if it has been provided by you for a specific purpose.
- Sensitive information that you share with us at meetings and during the course of your relationship with us and which may have a bearing on your charitable interests, such as information about your health, including medical conditions.
How we collect your data
Information we collect from you
Much of the information that we hold for Advancement purposes is obtained directly from you. The ways we collect your data directly include through contact detail update forms, donation forms, event registrations and in person. If you are a student, or studied at the College, some of your personal data is routinely transferred from your student record to the College's alumni database. Personal data collected from you by other College departments may also be used for Advancement purposes, depending on the circumstances under which it is collected.
Information we may collect from elsewhere
If we lose touch with you and we believe you wish to hear from us, we may use external sources and data agencies, such as the Royal Mail’s National Change of Address Update database, to update your contact details. This allows us to continue to communicate with you about the range of events and activities that may interest you. If you would rather the College did not do this in relation to your data, please contact us using the details in the ‘Contact us’ section below.
If you interact with the College through a third party, such as making a donation to a crowdfunding page, then they may provide us with information about you.
If we believe you may be interested in becoming more involved with the College, we may gather additional data from external sources as described further in the ‘Research and potential donor identification’ section below.
Our lawful basis
We will only process your personal data when the law allows us to, and with respect to personal privacy choices and the reasonable expectations of our community. Most of the College’s core education and research activities rely on public task as the College’s lawful basis for processing of personal data. Advancement relies on different lawful bases.
We consider that the College has a strong and legitimate interest in keeping up our relationship with alumni, friends and supporters; we do this for the purposes of building a vibrant, engaged community, to support the College’s philanthropic aims, and to help safeguard its future. Legitimate interests is the lawful basis we rely on for most of our activities set out in this privacy notice.
Other lawful bases are used for some activities, such as where you have provided consent to certain types of marketing activity or to processing special category data; where the processing is necessary under a contract with you such as where you purchase event tickets; or where the College is legally obliged to process your data such as in compliance with tax law or anti money laundering regulations.
How we use your data
This data is used to support a wide range of activities for and in relation to our alumni, friends and supporters. These include:
Alumni, friends and supporter relations, such as:
- Providing you with information about our work and our activities. This might include sending you College news and research updates, department and College e-newsletters, invitations to events and details of volunteering opportunities. Such information might also include content about the College’s charitable mission.
- Providing services such as access to events and facilities on campus including the Alumni Visitor Centre, alumni email accounts, Imperial Plexus online alumni accounts, and careers services.
- Conducting surveys, focus groups and other research.
- Supporting an international network of over fifty alumni associations that provide opportunities for alumni to network in their local area and connect around academic interests. This support may including sending you communications on behalf of alumni associations and offering paid benefits to you, such as College elective courses, events or College gym membership.
- Administrative purposes, such as recording your registration for, or attendance at, an event.
- Internal record keeping, including the management of any feedback or complaint.
- Monitoring the impact of our communications and other activities, such as measuring email open rates or analysing the uptake of our events programme.
Gift administration, such as:
- Processing and recording a donation you have made.
- The transfer of data to HM Revenue and Customs in respect of any Gift Aid claim.
- Acknowledging donors and those who have pledged a legacy gift in the College’s online and printed lists of supporters.
- Providing you with updates on the use and impact of donations the College has received, a specific donation you have made, or a specific fund that you have contributed to.
- Offering membership of our donor circles to those who make a particularly significant contribution to the College.
Fundraising, such as:
- Furthering our charitable objectives, including helping us to raise money. We may ask you to donate money to Imperial, but always in accordance with our Fundraising Promise.
- Research to gain a better understanding of our supporters, inform our fundraising strategy and target our communications more effectively and appropriately. See the ‘Research and potential donor identification’ section below for more detail.
Research and potential donor identification
There are a number of data processing activities we may undertake to help us to understand you better. This will help ensure that our communications are relevant to you and your interests, and to assess your likely interest in and ability to make donations to the College. It also helps us to avoid inappropriate or unwelcome communications.
We may combine the information you provide to us with biographical and financial information from external sources. This data may come from company resources and publications, news media, aggregators of publicly available information, and social media sites like LinkedIn, Facebook and Twitter (depending on your privacy settings and interaction with us). It may also come from personal contacts, leads or recommendations. Our sources are all carefully evaluated to ensure that it is reasonable for us to use them for this purpose, and a list, which changes from time to time, is available on request.
Much of the support we receive comes from our existing alumni, friends and supporters. However, we also seek to identify other individuals who we believe will be interested in developing a relationship with the College. We do this through referrals from College contacts such as academics, clinicians or other supporters, and through research using the external sources described above.
We use automated and manual processes to link data together. This allows us to direct our activities most effectively, such as by identifying those we think are most likely to welcome further communications from the College. These processes are always managed carefully, and the outcomes of any automated processing are reviewed to ensure there are no unexpected or unreasonable outcomes.
If you would rather that the College does not undertake this activity in relation to your data, please contact us using the details in the ‘Contact us’ section below.
Sharing data with third parties
We may disclose your data to third party service providers who support us in our work. For example, suppliers of printing and mailing services, email communication services or web services, or suppliers who help us carry out any of the activities described above, including research and potential donor identification. Our third party service providers are required to enter into data processing agreements with us. We only permit them to process your personal data for specified purposes and in accordance with our policies.
From time to time your personal data may be shared with other external organisations. Such data sharing will take place when it is necessary for the College's legitimate interests or the legitimate interests of a third party, but this will always be weighed against your rights, interests and expectations. These organisations will process your data in line with their own privacy notices, and may include:
- Alumni associations with whom the College has data sharing agreements, including the City and Guilds College Association and Royal College of Mines Association
- The Imperial College Foundation in the USA
- Imperial College Union
- Organisations that conduct independent surveys in relation to our courses for their rankings or guides, such as the Financial Times Masters in Finance Ranking
- Organisations we collaborate with on joint activities, such as events
- Suppliers who are also data controllers and who support us in our work, for instance in undertaking research and potential donor identification or due diligence.
We will also share your data with third parties if we are legally required to. We will not sell your data.
Where our data sharing involves transferring your data outside of the EEA, we put contracts in place as required by EU data protection laws, to ensure that your information is secure and protected.
Before seeking or accepting large donations we are required to conduct due diligence, including reviewing publicly available data relating to criminal convictions and offences. Due diligence is conducted in accordance with the College’s Gift Acceptance Policy. We may also carry out due diligence in advance of other interactions that pose an ethical or reputational risk to the College, such as volunteering activity.
Data security and retention
We are committed to holding and processing your data securely, in line with the College’s Data Protection Policy and any relevant legislation. Personal data is held digitally on secure servers, with access restricted to trained, authorised personnel. We aim to minimise the amount of personal data we process physically; where it is necessary to hold physical copies of data it is stored in secure, restricted locations and destroyed securely when no longer needed. In the event of a suspected data security breach we will notify you and any applicable regulator, where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting purposes. The College’s Retention Schedule details the retention periods of different types of information.
Imperial considers its relationship with its alumni to be lifelong, so we maintain a minimum record of each alumnus indefinitely. For alumni information that doesn’t link to your period of study at the College, and for other friends and supporters, the length of time we hold your data will depend on the nature of the information and the nature of our relationship with you. If you advise us that you no longer wish to remain in touch we will keep a record of that fact, and will delete any information about you for which we no longer have a purpose or lawful basis.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you.
You have rights under data protection law, including the rights to:
- Request a copy of the data we hold about you.
- Ask us to correct or complete the information we hold about you
- Ask us to erase your personal information
- Ask us to stop processing your personal data in particular ways, or altogether
- Withdraw consent you have provided at any time
- Make a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.
Requests can be made using the contact details in the ‘Contact us’ section below. Sometimes we will have a lawful basis to continue processing your data, even if you request otherwise. We will always inform you of the actions we take in response to your request, and our justification if we refuse any part of it.
If you have any questions about this privacy notice, or would like us to update your personal information, please contact the Advancement Division using the details below.
Imperial College London
SALC Mezzanine, Sherfield Level 5
South Kensington campus
London, SW7 2AZ
Imperial College London has appointed a Data Protection Officer to oversee compliance with data protection legislation. If you have any questions about data protection at Imperial or would like to exercise any of your rights under data protection legislation, please contact the Data Protection Officer using the details below.
Data Protection Officer
Data Protection Officer
Imperial College London
Faculty Building Level 4
South Kensington campus
London, SW7 2AZ
+44 (0)20 7594 3502
We may amend this Privacy Notice from time to time, and a current version is always available on our web pages. Any significant changes to this notice or to the way we treat your data will be communicated online, or by contacting you directly through the most appropriate means.
Advancement Division, 26 July 2019, version 3.0