Harrow Association Privacy Statement

The Harrow Association (HA) is an unincorporated members association funded by subscriptions. The purpose of the HA is to enable Old Harrovians (OHs), wherever they are in the world, to maintain lifelong connections with the School and with each other. In order to achieve this, the HA needs to store and process personal information in a number of ways whilst always respecting the laws of the Data Protection Act (2018) and the regulations of the Privacy and Electronic Communication Regulation (PECR).

However Old Harrovians and members choose to stay in touch with us, we will always respect your rights and choices. Here, we explain what we will, and will not do, with your personal data.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

The HA collects specific information about its members in order to provide a more bespoke service to keep you informed about news and events that may be of interest to you. The information we collect can be categorised as follows:

• Personal details including name, titles, date of birth, gender, relationship status and name of spouse
• Preferred contact details such as postal address, email, and phone numbers
• Family relationships including any Old Harrovian relations
• Educational information; prep school and university attendance but not including academic results
• Harrow School achievements; sports teams and positions of responsibility
• Business details
• Membership of any HA clubs & societies
• Membership to any private Club or Livery Companies
• Engagement with the HA and Harrow School; event attendance; work experience placements, careers talks
• Dietary requirements for events
• General hobbies and interests to help us put you in touch with like-minded OHs

The HA starts collecting some of this information as soon as you are enrolled into the School as a boy as a record of your attendance at Harrow. We then collect further contact information from you during your their final term before leaving to become an Old Harrovian. We continue to collect personal data from you when registering for events, volunteering, engaging with our social media channels or otherwise provide us with your personal information.

We may also try to connect with you through social media platforms such as LinkedIn to help us stay in touch and to keep our database up to date. This helps us to capture and collect business details to allow us to send invitations that may be of interest to you.

HOW WE STORE YOUR DATA AND KEEP IT SAFE

All the data that we collect from our members is stored on our database system The Raiser’s Edge NXT, which is supplied by the software company Blackbaud. Our database is a cloud-based system located on servers held within the EU. The software is upgraded regularly and we keep a close relationship with Blackbaud Inc to ensure your information is kept secure. Internally we have strict controls in place when accessing your data and staff undergo regularly data protection training.

Our online networking platform, OH Connect is also a cloud-based database, supplied by software company Graduway. Information is stored on serves located within the EU and we again work with them to ensure that they do everything possible to keep your data safe.

The HA maintains PCI compliance for processing payments for events.

HOW WE USE YOUR PERSONAL INFORMATION

In order to provide you with a high level of service, we will use your data in a number of ways. The Data Protection Act requires us to identify the legal basis for carrying out these activities explained as follows:

Legitimate Interest – We have identified these activities as an integral part of your membership with the Harrow Association and as an Old Harrovian. Unless you tell us otherwise, we will do the following:

• Maintain a record of your attendance at Harrow School
• Send you the annual HA Magazine, Follow Up!
• Send you the annual Harrow School Magazine, The Harrow Record
• Periodically send you communications that are of interest to maintain your connection with Harrow School
• Send you invitations to events relevant to your time at Harrow School and to your specific interests
• Track your engagement with the HA so we can provide you with a better service
• To use anonymised personal data to benchmark our activities

Consent – With your permission, we will do the following:

• Send you email invitations to events and other marketing material relating to HA activities
• Record dietary requirements for events
• Pass your information onto HA clubs and societies you have requested to join

• Periodically call you to update our records or to pass on information we feel is relevant to you

RETENTION OF YOUR PERSONAL INFORMATION

HA membership is life-long and so we consider our relationship with our members to be the same. We must however take into consideration our legal obligations when determining how long we retain your information and will endeavour to review our data regularly to ensure we are not keeping information for longer than required. We will ensure you are always able to update your information with us and are able to change your preferred communication preferences.

SHARING YOUR PERSONAL DATA

The Data Protection Act exists to protect the privacy of individuals. The HA is committed to protecting the privacy of Harrovians and its members. Note that spouses, parents and friends have no automatic right of access to your personal data. The general principle is that your personal data will normally only be disclosed outside the HA with your consent.

However, there are occasions while you are at the school and after you leave when the HA is obliged by law, or under other obligations, to disclose the personal data to external people or agencies. These are sometimes called third party disclosures. The HA has internal procedures to check that the disclosure is appropriate and that the third party is legitimate before any release takes place. Third parties which the HA identifies are as follows:

• Harrow Association Volunteers: The HA uses volunteers to help carry out our activities and stay engaged with our community. A HA volunteer may be an overseas representative (who organises events for OHs in that area) secretaries of our HA clubs and societies, House representatives, or organisers of House dinners and other OH reunions.
• Harrow School: Once you leave Harrow, the HA becomes the main database of those who have attended the School. On occasion, we may be required to share your data with the School such as your name, date of birth and time at Harrow. We may also need to share your contact data with the School so that they may send you transcripts, certificates, references, periodicals and occasional invitations.
• The Harrow Development Trust (HDT): In order to advance the opportunities and facilities provided to current boys, the HDT may use your information to keep you informed of their campaigns relevant and of interest to you. The HA works closely with the HDT and shares a common database.
• Legal Authorities and Law Enforcement: Where disclosure is necessary for the prevention or detection of crime, the HA will release your information where necessary to these authorities.
• Service providers: The HA may use services such as mailing houses under contract for relevant operations.
• Employment references/confirmation of qualifications: The HA receives numerous requests from employment companies and private clubs to confirm attendance at Harrow for applicants. When approached, the HA will first seek your explicit consent before releasing any data. We are only able to provide confirmation of your time at Harrow. We will therefore refer the request to the School when qualifications are also required.

The HA remains the Data Controller at all times.

YOUR RIGHTS

The data protection act is in place to enable you to control how use your data is used. It is therefore important to us that you know your rights and that you may:

• request a copy of the information we hold about you
• update or amend the information we hold about you if it is incorrect
• change your communication preferences at any time
• ask us to remove your personal information from our records
• object to the processing of your information for marketing purposes
• raise a concern or complaint about the way in which your information is being used

You have the right to access the information that the HA holds on you. This is called a Subject Access Request (SAR) and you will be requested to provide proof of identity.

Further Information and how to make a complaint

If you are unhappy with something that we have done or failed to do, we would like to know about it. We also welcome your views on what we are doing well. If you would like to make a complaint, compliment or comment then please contact us at the following address: Harrow Association, 5A High Street, Harrow on the Hill, Middlesex HA1 3HP

It is a legal requirement to notify the Information Commissioners Office (ICO) of the purposes for which we process personal data and you can view the entry for the HA on the ICO register on their website here: www.ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/

The Harrow Association’s registration number is Z714153X.