Harrow Development Trust Privacy Statement

The Harrow Development Trust (HDT) is a registered charity (no. 296097) and serves as the fundraising arm of Harrow School. The HDT carries out fundraising in order to meet a number of its objectives such as: providing Bursary award places, ensuring buildings and facilities are regularly maintained and improved, new projects are implemented. In order to achieve this, the HDT processes 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). The HDT is registered with the Fundraising Regulator.

This statement sets out what information we collect, store and what we do with it.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In order for the HDT to carry out its functions and activities, we need to collect certain information. We collect this data through our close relationships with the School and with the Harrow Association, the School’s alumni organisation. Both organisations make it clear when your data will be shared with the HDT. The information we collect can be categorised as follows:

• Personal details including name, titles, date of birth and gender
• Preferred contact details such as postal address, email, and telephone numbers
• Your relationship with Harrow School (Parent, Old Harrovian or other)
• Family relationships with other Old Harrovians
• Educational information (does not include academic achievements)
• Employment details
• Record of any donations made
• Information on any engagement you may have with the HDT
• Dietary requirements for events

The HDT collects this information from a number of sources and depending on your relationship with Harrow. The School collects information on parents when their child enrols at Harrow. The School passes on this data to the HDT in accordance with the School’s Parents Terms and Conditions. Old Harrovian data is shared with the HDT by the HA in line with their agreements and both organisations work closely together.

HOW WE STORE YOUR DATA AND KEEP IT SAFE

The HDT stores all information 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.

Financial transactions on our website are processed securely by our software provider, Blackbaud Inc. Any hard copy bank details are destroyed once the payment has been processed and the HDT ensures it is PCI compliant.

HOW WE USE YOUR PERSONAL INFORMATION

We promise to respect any personal data you share with us, keep it safe and will not do anything that you would not reasonably expect. Below we explain what we do with your data and our legal basis for carrying out these processes:

Legitimate Interest – We have identified these activities as a necessary function of the HDT. Unless you tell us otherwise, we will:

• Store the information you have provided us in a safe and responsible manner
• Send you mailings to keep you informed of development projects at Harrow and invite you to support our fundraising objectives.
• Track your engagement with us so we can provide you with an improved and more suitable service
• Use your data for research in order to produce biographical briefings.
• Thank you for any donation you make and contact you about any administrative matters relating to your donations
• Use anonymised personal data occasionally to benchmark our achievements against other similar institutions

Consent – With your permission, we will:

• Email you invitations to events
• Email you with other relevant marketing material relating to the School or HDT activities
• Record dietary requirements for events

If you do not wish your data to be used in any of the ways listed above, you can notify us using the contact details at the bottom of this document.

Legal Obligations

• We have a legal obligation to transfer data to HM Revenue and Customs in respect of any Gift Aid claims
• We are legally required to submit information to the Charities Commission annually.

RETENTION OF YOUR PERSONAL INFORMATION

We will retain your personal information for as long as you maintain a relationship with the School or until you inform us otherwise. When your relationship with us ends, we will ensure your personal data is securely removed. Some data such as any donations made to us, will be retained for record keeping in accordance with accounting best-practice and our legal obligations.

SHARING YOUR PERSONAL DATA

The Data Protection Act exists to protect the rights and privacy of an individual’s personal data. The HDT is committed to this, and it should be noted that spouses, parents and friends have no automatic right of access to your personal data. However, there are occasions when the HDT is obliged by law to disclose your personal data to external people or agencies. These are sometimes called third party disclosures. The HDT has internal procedures to check that the disclosure is appropriate and that the third party is legitimate before any release takes place. These third parties are described as follows:

• Harrow Development Trust Volunteers: The HDT, from time to time use volunteers to help carry out our activities and stay engaged with our community. A HDT volunteer may be a peer, OH or parent representative.
• Harrow School: Occasionally we may share your data with the School. This is usually to enable key members of the School to thank donors for their support.
• Harrow Association: The HA is the alumni organisation for the School. We work very closely together and share a database. Therefore, if you are an Old Harrovian and update your contact details with us, we will share this with the Harrow Association unless you tell us otherwise.
• Legal Authorities and Law Enforcement: Where disclosure is necessary for the prevention or detection of crime, the HDT will release your information where necessary to these authorities.
• Service providers: The HDT may use services such as mailing houses under contract for relevant operations.

The HDT remains the Data Controller at all times.

YOUR RIGHTS

The Data Protection Act is in place to enable you to control how the HDT and other organisations use your data. It is 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

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 HDT 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

We are always happy to hear your views on what we are doing well and if you have any compliments or comment on the work of the HDT does. We of course also welcome your complaints and comments and you can contact us at the following address: Harrow Development Trust, 5A High Street, Harrow on the Hill, Middlesex HA1 3HP.