Harrow Association Privacy Statement
The Harrow Association Ltd (“The Association”, “we”, “us” or “our”) is a company limited by guarantee, which operates as the alumni, or Old Harrovian, association for Harrow School. The purpose of the Association is to enable its members (“Associate Members”, “you” or “your”) to maintain lifelong connections with the School and with each other.
On 30 April 2026, further to a vote of Associate Members, the assets and activities of the formerly unincorporated association, including the alumni database, were transferred to the Association. The Association is an independent data controller responsible for the personal data it stores and processes in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
This Privacy Statement sets out what personal data we collect, how we use it, and how we protect it.
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
The Association collects and maintains personal data about Associate Members to provide a 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 the name of your spouse, subject to their consent.
• Preferred contact details such as postal address, email, and phone numbers
• Family relationships including any Old Harrovian relations
• Educational information (school and university attendance not including academic results)
• Harrow School activities and achievements
• Professional and business information
• Membership of any Association clubs and societies
• Membership to any private Club or Livery Companies
• Engagement with the Association and Harrow School, including event attendance, volunteering, mentoring and speaking engagements
• Dietary requirements for events
• General interests to help us put you in touch with like-minded Old Harrovians
• Publicly available information such as public social media profiles e.g. LinkedIn
• Participation in the Association’s online community, OH Connect
Much of this information originates from your time at Harrow School, including information collected in your final term before leaving to become an Old Harrovian. We continue to collect personal data from you when you register for Association events, volunteer, engage with our social media channels or otherwise provide us with your personal information.
HOW WE STORE YOUR DATA AND KEEP IT SAFE
The personal data that we collect from Associate Members is stored on secure systems including The Raiser’s Edge, which is supplied by software company Blackbaud, and OH Connect, supplied by software company Graduway. These are cloud-based platforms hosted within the European Economic Area.
We implement appropriate technical and organisational measures to protect your data, including restricted access controls, staff training and contractual safeguards with service providers.
Some personal data is held within systems that are accessible by both the Association and the charity that operates Harrow School, known as The Keepers and Governors of the Possessions, Revenues and Goods of the Free Grammar School of John Lyon within the town of Harrow-On-The-Hill, registered charity number 310033 (the “Corporation”). Where this is the case, access is strictly controlled and limited to authorised personnel, and data is only used for defined purposes in accordance with data protection law.
The Association maintains PCI compliance for processing payments for events.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal data to support your relationship with the Association and within our alumni community. Data Protection legislation requires us to identify the legal bases for carrying out these activities explained as follows:
Legitimate Interest – We have identified these activities as an integral part of your membership with the 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 Association Magazine, Follow Up!
• Send you the annual Harrow School Magazine, the Harrow Record, digitally
• Periodically send you communications that are of interest to maintain your connection with Harrow School
• Communicate with you about fundraising activities, appeals and ways to support Harrow School, where permitted by law
• Send you invitations to events relevant to your time at Harrow School and to your specific interests
• Track your engagement with the Association so we can manage and improve our services
• Use anonymised data for analysis and benchmarking
We consider these activities to be within your reasonable expectations as a member of the Harrow alumni community and have carried out appropriate legitimate interests assessments to ensure that our processing does not override your rights and freedoms.
Consent – With your permission, we will do the following:
• Record dietary or accessibility requirements for events
• Pass your information onto Association clubs and societies you have requested to join
• Make certain types of direct contact where required to update our records or to pass on information we feel is relevant to you
You may withdraw your consent at any time.
DIRECT MARKETING
We may contact you with information about alumni activities, events and fundraising opportunities by post, email or other electronic means.
Where required, we will obtain your consent before sending electronic marketing communications.
You can opt out of receiving marketing communications at any time by using the unsubscribe link in our emails or by contacting us directly.
RETENTION OF YOUR PERSONAL INFORMATION
We retain personal data for as long as you remain an Associate Member. We periodically review the data we hold and will retain only what is necessary for our purposes and to meet legal obligations. 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
We are committed to protecting your personal data. It will only be shared where necessary and appropriate, in accordance with data protection law, or with your consent. Your data may be shared within the Corporation and its affiliated organisations where necessary to support alumni engagement. We may share your data with:
• Association Volunteers: The Association uses volunteers to help carry out our activities and stay engaged with our community. An Association volunteer may be an overseas representative (who organises events for alumni in that area) secretaries of our Association clubs and societies, House representatives, or organisers of House dinners and other alumni reunions.
• The Corporation, which operates Harrow School and Harrow School Development:
o Harrow School: Once you leave Harrow, the Association 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.
o Harrow School Development (HSD): In order to advance the opportunities and facilities provided to current boys, the HSD may use your information to keep you informed of fundraising campaigns relevant and of interest to you. The Association works closely with the HSD and shares a common database which is governed by strict security and access controls to ensure data is only used for appropriate purposes.
• Employment references/confirmation of qualifications: The Association receives requests from employment companies and private clubs to confirm attendance at Harrow for applicants. When approached, the Association will first seek your consent before releasing any personal 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.
We may also share your data with third parties where necessary and appropriate or where required by law. These third parties include:
• Legal Authorities and Law Enforcement: Where disclosure is necessary for the prevention or detection of crime, the Association will release your information where necessary to these authorities.
• Service providers: The Association may use services such as mailing houses under contract for relevant operations.
The Association remains the data controller of Associate Member personal data and any disclosure of personal data is carried out in accordance with applicable data protection law and appropriate safeguards. Where personal data is shared with the Corporation or other organisations acting as independent controllers, this is carried out under formal data sharing arrangements which set out the purposes of sharing and the safeguards that apply.
YOUR RIGHTS
You have rights under data protection law, including the right to:
• 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, with us or with the Information Commissioner’s Office.
If you choose to unsubscribe from communications from us, we will update our records to stop further communication as quickly as we can. Due to some communications that may already being in progress at the point you opt out, please be aware that it can take up to six weeks for your preferences to be fully implemented.
You have the right to access the information that the Association holds on you. This is called a Subject Access Request (SAR). A SAR is normally free of charge, although a reasonable fee may apply in limited circumstances.
FURTHER INFORMATION AND HOW TO MAKE A COMPLAINT
If you have any questions about this Privacy Statement or how your data is used, please contact us at:
The Harrow Association Ltd
c/o Harrow School
5A High Street
Harrow on the Hill
Middlesex
HA1 3HP
HA Ltd has appointed a data protection function which is provided by the Corporation.
If you have any questions about how your personal data is used, or wish to exercise your rights, please contact:
privacyofficer@harrowschool.org.uk
Please indicate that your enquiry relates to Harrow Association Limited.
The Association is registered with the Information Commissioner's Office (ICO) as a data controller. You have the right to lodge a complaint with the ICO.