Throughout the history of Swansea University and its founding institutions, philanthropy has played a fundamental role in its growth and success. From the foresight of Viscount Haldane, who was instrumental in establishing the University a century ago, to the generosity of donors past and present, the support of those who believe in the power of education has helped Swansea University become the world leader it is today.
This statement explains how Swansea University ("we" and "our") handles and uses the personal data we collect about our alumni (which includes honorary alumni (e.g. Honorary Fellows) as well as former students) and our past, current and future supporters, whether donors, volunteers or participants in events we run ("you" and "your"). "The University" in this context means the Development & Engagement Office. Developing a better understanding of our alumni and supporters allows us to keep in touch with you, in order to keep you apprised of our activities and developments, to provide services to you, and to identify ways in which you can support us, through donations or other forms of financial and non-financial support.
We are committed to protecting your personal information and being transparent about what information we hold. The University has a range of data protection policies and procedures, an overview of which can be found here: http://www.swansea.ac.uk/the-university/world-class/vicechancellorsoffice/compliance/dataprotection/dataprotectionpolicy/.The following statement sets out how the University specifically uses your personal data for fundraising (including public events) and alumni relations purposes.
Personal data held by the University
We may hold information relating to you from a number of sources. The basic information we hold, if you studied at Swansea University (or predecessor institution), is transferred from your student record. This is augmented by any information that you provide to us (for example, you may give us information by filling in forms on the University's website, by registering for an event, by corresponding with us by telephone, email or otherwise).
Typical records contain some or all of the following:
• Details of your Swansea University (or predecessor institution) education (e.g. the courses you have completed, dates of study, class of degree)
• Unique personal identifiers and biographical information (e.g. student number, date of birth)
• Your contact details, if known (which we update whenever you let us know that they have changed)
• Details of your interactions with the University, including:
o Your membership of clubs, societies, and alumni groups
o Your attendance at University events
o Other contact with us or our partners (as listed below)
o Your relationships with other alumni or supporters of the University
• Details about your family (e.g. your marital status, the name of your partner or spouse)
• Personal data provided by you for a specific purpose (e.g. disability and dietary preferences for event management purposes)
• Your communication preferences, to help us provide tailored and relevant communications.
We also record, where applicable, based on information which you provide to us and, in some cases, publicly available information and information from our partners (as listed below):
• Financial information relating to you and your family, including:
o Your history of donations made to the university and colleges
o Your ability and willingness to make donations, including our assessment of your income and whether particular donations or funding appeals may be of interest to you
o Your philanthropy and other giving, including donations to other organisations and other support that you provide (e.g. details of volunteering roles)
- Your career highlights and other life achievements
- Information about your areas of interest and extra-curricular activities
How we keep your data accurate and up-to-date
In order to maintain data integrity, we augment the data we hold from the University with data from our partners (as listed below) and publicly available data, including from the following databases (which are usually accessed via a third party partner such as CCR (see below), not directly by Swansea University):
• Royal Mail’s National Change of Address service
• BT Operator Services Information System (OSIS)
• Various databases and suppression files maintained by, among others, Experian (e.g. Absolute Movers), Equifax (e.g. disConnect), Acxiom (e.g. Purity), Wilmington Millennium (e.g. Mortascreen)
• Prospecting for Gold, for information about wealth and philanthropic inclinations
• LiveAlumni for accessing publicly available LinkedIn data
We use targeted internet searches and may search the following websites (either directly or using search engines), where relevant in order to obtain and maintain the accuracy of the data listed above:
• Public sources for companies (in order to find personal data of those companies' employees, etc.):
o Companies House and other business-related resources for UK companies
o Company websites
• Public sources for charities (in order to find personal data of those charities' employees, trustees, etc., and to find information about donations and support):
o Charity Commission and other internet sources for UK non-profits
o Charity websites
• Public sources for individuals:
o Sunday Times Rich List
o Other rich lists, including Forbes Magazine's international rich lists
o The Queen's Honours Lists
o Linkedln, to check business details
• Press Sources
o Newspaper articles and publications
o LexisNexis (subscription)
We may also record, where applicable, based on information which you provide to us and have given us explicit consent to process:
• Special Category data e.g.
o Ethnicity
o Sexuality
How your data is used by the University
Your data is used by us for a number of interdependent purposes in support of alumni relations, supporter communications, events and fundraising. These include:
• Sending you publications (e.g. alumni magazines and updates about the university)
• Emailing you to keep you apprised of University news, to invite you to events and occasionally to solicit financial support
• Conducting surveys
• Providing services, including access to find a friend and other services
• Sending you tailored proposals, appeals and requests for donations
• Sending you details of volunteering opportunities
• Inviting you to alumni and other public university events
• Wealth analysis (sometimes known as ‘wealth screening’) and research (‘prospect research’) in order to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications more effectively
• Internal record keeping, including the management of any feedback or complaints
• Administrative purposes (e.g. in order to process a donation you have made or to administer an event you have registered for or attended)
• To support activity linked to our mentoring and employability programmes
• To conduct internal analysis of the progress and effectiveness of our campaigns and other activities
• We only process Special Category data when you have informed us that we may do so for a specific purpose, such as to support our employability and mentoring programmes.
Before seeking or accepting major donations we are required to conduct due diligence, including reviewing publicly available personal data relating to the donor, including criminal convictions and offences, political exposure, presence on watchlists, corruption, adverse reference, international sanctions, links to sensitive regions, financial misconduct etc.
Furthermore, we may also conduct similar due diligence on event panellists and delegates. This research may be conducted either manually, by using a solution such as DDIQ (see https://www.exiger.com/ddiq/), or by a combination of both methods.
We do this research in order to protect the reputation of the University and to uphold its high ethical standards.
Communications may be sent to you by post, telephone or electronically (email and SMS), depending on the options you chose. If you provide us with contact details for a particular method of communication we will assume that you have given us your consent for us to update your record and communicate with you using this information, unless you have told us otherwise. Contact details provided directly by you will update any previous preferences in relation to this channel unless you inform us otherwise. If you are registered with the Telephone Preference Service (TPS) but provide us with a telephone number we will assume that we have your consent to call you on this number.
If you have concerns or queries about any of these purposes, or how we communicate with you, please contact us using the details listed below.
We may analyse data to help us identify your potential for supporting the University, to provide you with an improved experience, to send you communications which are relevant and timely, to identify volunteering opportunities or opportunities for providing support which may be of interest to you, and to avoid approaching you with opportunities which are not of interest. All of this enables us to raise more funds, sooner, and more cost-effectively, in support of the University's strategic research and teaching objectives. We always seek to ensure, where possible, that any opportunities we present are aligned with your interests, based on the research we conduct.
We will always respect a request by you to stop processing your personal data. Your statutory rights are set out below.
When the University shares your data with others (our partners)
We share data on a considered and confidential basis, where appropriate, with:
• Affiliated organisations which support and provide services to alumni and supporters, such as:
o Volunteer partners closely related to us (e.g. Development Board members, Alumni Chapter heads)
• Third parties engaged by the university to provide fundraising related services, such as:
o Third party agencies who provide us with data about individuals' capacity to donate (this is sometimes called ‘wealth screening’)
o Third parties who provide services to assist with our due diligence (https://www.exiger.com/ddiq/)
o Contractors who use national databases (e.g. National Change of Address service) to provide us with updated details for our alumni, for example if you move house. This is often called ‘data cleansing’, and is carried out by a third party such as CCR (http://www.ccr.co.uk/data-cleansing).
o Other contractors providing services to us, or services to you on our behalf, (for example, our alumni engagement platform Graduway (swanseauniconnect.com); mailing houses for distribution of our alumni magazine)
• Online services to allow alumni to perform voluntary tasks such as:
o Updating your biographical, employment and contact details (JotForm: https://eu.jotform.com/)
o Completing online surveys which we may send you (Online Surveys: https://www.onlinesurveys.ac.uk/)_
• We will never share Special Category data with any other organisations or individuals outside of Swansea University.
How we protect your data
We ensure we have appropriate data sharing agreements in place before sharing your personal data, including for any subcontractors. 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. We also facilitate communication between individual alumni, but in doing so we do not release personal contact details without prior permission.
Any transfers of your data overseas (outside of the European Economic Area), for example to servers located in the US are protected either by an 'adequacy decision' by the European Commission (declaring the recipient country as a 'safe' territory for personal data) or by standard contractual clauses adopted by the European Commission (which give obligations for the recipient to safeguard the data). Further information about the measures we use to protect data when being transferred internationally is available from our Data Protection Officer (whose contact details are set out below).
Your rights
Data protection legislation provides individuals with a number of different rights in relation to their data. These are listed below and apply in certain circumstances:
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request data portability of your personal information. In certain circumstances, you may have the right to require that we provide you with an electronic copy of your personal information either for your own use or so that you can share it with another organisation. Where this right applies, you can ask us, where feasible, to transmit your personal data directly to the other party.
If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact:
Mrs Bev Buckley
Data Protection Officer
Vice-Chancellor’s Office
Swansea University
Singleton Park
Swansea
SA2 8PP
Email: dataprotection@swansea.ac.uk
Further information
Swansea University is registered as a Data Controller with the Information Commissioner’s Office (ICO) to process personal data. Reg no Z6102454., Our Data Protection Officer is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, and can be contacted at dataprotection@swansea.ac.uk.
The legal basis for processing your personal data for the interdependent purposes set out above is that it is necessary for the pursuit of our legitimate interests. We always handle your personal data securely and minimise its use, and your interests are not overridden by using your personal information for these purposes. In addition, there is no statutory or contractual requirement for you to provide us with any personal data.
Where the law requires it, we will rely on your consent in order to communicate electronic direct marketing communications. If you wish to stop receiving communications from Alumni then please contact us at alumni@swansea.ac.uk.
In the case of Special Category data, our lawful basis for processing is Consent. We only hold Special Category data (e.g. Ethnicity, Sexuality) when you have told us the information for a particular purpose (e.g. supporting our employability and mentoring programmes) and we have your explicit consent to process it for the limited set of purposes outlined above.
The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here: http://www.ico.gov.uk/for_the_public.aspx.
You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. We will always do our very best to solve any problems you may have.
Please contact us at alumni@swansea.ac.uk if you have any concerns or questions about the above information or you wish to ask us not to process your personal data for particular purposes. Where you have specific requests relating to how we manage your data, we will endeavour to resolve these, but please note that there may be circumstances where we cannot comply with specific requests. In the event you remain dissatisfied with the response from the University, you are entitled to take your complaint to the Fundraising Regulator for an independent investigation. Please see their website for further details: www.fundraisingregulator.org.uk
We will retain your data in support of your lifelong relationship with the University or until you request us to do otherwise. We will publish on our website any changes we make to this data protection statement and notify you.