You will no doubt have heard of new data legislation, called GDPR, which came into force in 2018. We would like to explain to you how the Old Foleyans’ Association have aligned their policy with the regulations.

Under GDPR all data controllers must have a Lawful Basis for processing Personal Data. The six bases are: Consent, Contractual, Legal Obligation, Vital Interests, Public Tasks and Legitimate Interests. The ICO states that it is the responsibility of the individual organisation to decide on which bases to process data.

Having undertaken a review of the data we hold and the way in which we process it, we believe that all of the data held by the Association is processed under Legitimate Interest.

For data protection purposes we consider our ‘Friends’ community to include: former Pupils, former Parents, former Staff, former Governors and members of the wider community. Due to the nature of the existing relationships we have with you, our ‘Friends’, our interpretation is that we can lawfully process your information under the base mentioned above. We have conducted, as recommended by the ICO, a Legitimate Interest Assessment (LIA) to support this decision. Our LIA will be kept under regular review.

Please be assured that we will treat your data with the utmost integrity, respect and confidentiality. Your personal data will be stored and used in accordance with our updated privacy policy, which reflects current regulations.

Our communications with you will be conducted in the least intrusive way possible and only in ways that you would reasonably expect, as additionally outlined in our privacy policy.

Please be aware that you can opt out of receiving non-legal or non-contractual communications at any time by contacting us by email, or in writing to the Secretary.

Email: Secretary rob.franks@oshofa.com

Address: Secretary Old Foleyans’ Association, School Office, Heath Lane, Stourbridge, Dy8 1QX.
 

The following explains how the Old Foleyans’ Association handles and uses the data it collects and holds.

We are committed to protecting your personal information and privacy and being transparent about what information we hold and why. The Association uses data to help us to organise events and share news from the Association and school.

Activities include the production and distribution of publications, information on current school projects, promotion of events and the celebrations of the successes of Friends and alumni. Communications may be sent by post, telephone, or by email. We may also place some articles on our Website or Facebook page.

We may hold information relating to you from a number of sources. A significant proportion of the information we hold on Alumni and Friends is that which you provide to us (such as by completing forms, on the website or by corresponding with us by letter, email, telephone or otherwise).

Records commonly contain basic contact information, details of education and activities undertaken whilst at school, and career information. Interactions with the school and donation details are also noted. In some cases other data may be linked including information about relatives, partners or other information you have disclosed to us or that we have derived from publicly available sources, and information about your area of interests.

The terms of this statement may change, so please check it from time to time.
 

The Old Foleyans’ Association promises to respect any personal data you share with us and keep it safe. We ensure that there are appropriate technical controls in place to protect your personal details and our network is protected and routinely monitored. We undertake regular reviews of who has access to information that we hold, to ensure that your information is only accessible by appropriate people.

We use InTouch Software Ltd to carry out the technical security of data and its storage. Data may be transmitted to a third party with whom we have a data agreement and who will undertake a specific tasks on our behalf such as mail shots. They are required to delete or destroy all such information once they have completed the agreed activity. Under no circumstances would we sell or allow third parties to sell or share the data nor may they market to you.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

The Association also facilities communication between former Pupils and Friends, however we will not disclose personal contact details but rather forward your communication on and encourage direct contact channels to be opened. We will only ever share your data in other circumstances if we have your permission.

Keeping your information up to date We appreciate if you let us know if your contact details change. Alumni may also update their personal details and control some elements of their data by logging on to the online database using their personal, secure login.
 

You have a right to ask for a copy of the information we hold about you, although we may charge £10 to provide this. If you spot any mistakes, please let us know and we will correct them.

If you want to access your information, send a description of the information you want to the Secretary.
 

Due to your pre-existing relationship with the School, your data will be handled based on our ‘Legitimate Interest’ in appropriately processing your data, by sharing news of developments by the Old Foleyans’ Association and the social and networking opportunities that we offer.

It is on that basis that we hold the information that you or others have supplied to us, and use it in the manner set out in this document.

We believe there is a balanced and legitimate interest in our contacting members of the Association’s community with general news, information about events and development projects. This is based on the need to fulfil our contract with Alumni to provide information for their lifetime and your reasonable expectations of contact from us. Where appropriate, we will ask you if you would like to commence or renew financial support for the Association.

We will always respect your request not to be contacted by certain means, about certain things or at all. We would never knowingly handle or process your personal data in a way that would cause detriment or harm.
 

As we have a contract to deliver information to Alumni for their lifetime, it would be reasonable to retain their data to meet that commitment. We will review this on a regular basis to ensure we still have a lawful basis on which to hold data. If an Alumni requests us to cease contact, we will respect their wishes, but will need to retain sufficient data to ensure we can identify them in order to comply with their wishes and ensure that they are not added back against their wishes.

Please contact the Secretary if you have queries about your data. If you wish to unsubscribe from particular publications or communications or activities please let us know and we will respect your wishes. We will keep our privacy and data policies under review, and any changes we make will be published on the Old Foleyans’ website.
 

We aim to be clear when we collect your data and we would not do anything you wouldn’t reasonably expect. What personal data we collect and how we use it?

The type and quantity of information we collect and how we use it depends on why you are providing it.

Alumni

As a former pupil of the School, we will hold your details in order keep you informed about the School and other Alumni, and occasionally to ask you to support us financially or by giving of your time or expertise. We will usually hold:

• Your name
• Your contact details
• Your date of birth
• Dates you attended school
• Destinations on leaving school
• Interests and positions held whilst at school
• Your family links such as siblings who attended school/ parents/ grandparents and cousins
• Your profession and place of work
• Which events you have been invited to or attended
• A photo

Friends

As a Friend of the School, we will hold your details in order keep you informed about the School, and to invite you to events or occasionally ask for your support. We will usually hold:

• Your name
• Your contact details
• Your connection to the school – past parent, former staff or governor, etc
• Your profession and place of work
• Which events you have been invited to or attended
• A photo

Supporters

If you support us, for example make a donation, we will usually add to our details:

Date of donation & amount of donation and the cause to which it was given.

We will mainly use your data to

• Provide you with the services, products or information you asked for
• Administer your donation or support your fundraising, including processing gift aid
• Keep a record of your relationship with us
• Manage your marketing preferences

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.
We may make use of additional information about you when it is available from external sources to help us do this effectively.

How we collect information about you?

• By request when you leave school or become a friend
• When you give it to us directly, including by email and online
• You may give us your information in order to sign up for one of our events, tell us your story, make a donation, purchase our product or communicate with us
• Depending on your settings or the privacy policies for other online services like Facebook or Twitter, you might give us permission to access information from those accounts or services. The information we get from those services depends on your settings, so you should regularly check them

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