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WOLVERHAMPTON GRAMMAR SCHOOL

PRIVACY NOTICE FOR ALUMNI, FRIENDS AND SUPPORTERS

INTRODUCTION

This Privacy Notice is intended to provide information about how the School* will use (or "process")

personal data about individuals including former pupils, parents, staff, friends of the School and donors

This Privacy Notice applies alongside any other information the School may provide about a particular

use of personal data, for example when collecting data via an online or paper form.

This Privacy Notice also applies in addition to the School's other relevant terms and conditions and

policies, including:

• Taking, Storing and Using Images of Children Policy;

• CCTV Policy

• Biometric Recognition Systems Guidance for Pupils and Staff;

• Data Retention Guide;

and the School’s Privacy Notice for Pupils and Parents, which also provides further information about

how personal data about those individuals will be used.

*The School, acting as data controller, includes Wolverhampton Grammar School (WGS) Ltd, WGS

Independence Appeal Funds, WGS 1958 Fund and WGS Enterprises Ltd.

RESPONSIBILITY FOR DATA PROTECTION

The School has appointed a Privacy and Compliance Officer who will deal with all your requests and

enquiries concerning the School’s uses of your personal data (see section on Your Rights below) and

wide range of personal data about its alumni as part of its daily operation.

The School will need to carry out some of these ordinary duties in order to fulfil its legal rights, duties

or obligations, including those under a contract with the parents of its pupils.

Other uses of personal data will be made in accordance with the School’s legitimate interests, or the

legitimate interests of another, provided that these are not outweighed by the impact on individuals

and provided it does not involve special or sensitive types of data.

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The School expects that the following uses will fall within that category of its (or its community’s)

“legitimate interests”:

• To enable the collection of subscriptions, donations and payment for events and activities;

• For alumni event or similar activities registration;

• To make use of photographic images and names of former pupils and staff (or other

individuals) in School publications, archive records and displays, in archive enquiries by other

Alumni and/or their families, on the School website, on the School’s online alumni community

website, and (where appropriate) on the School's social media channels in accordance (where

applicable) with the School's policy on Taking, Storing and Using Images of Children;

• For security purposes, including biometrics and CCTV in accordance with the School’s

Biometric Recognition Systems Guidance and CCTV Policy;

• For the purposes of archive research and reference by the School community including other

process; and

• Where otherwise reasonably necessary for the School's purposes, including to obtain

appropriate professional advice and insurance for the School.

In addition, the School will on occasion need to process special category personal data (concerning

health, ethnicity, religion, biometrics or sexual life) or criminal records information (such as when

carrying out DBS checks) in accordance with rights or duties imposed on it by law, including as regards

safeguarding and employment, or from time to time by explicit consent where required. These reasons

will include:

• To run any of its systems that operate on biometric data, such as for security and other forms

of identification (e.g. entry door controls.); or

• For legal and regulatory purposes (for example child protection, diversity monitoring and

health and safety) and to comply with its legal obligations and duties of care.

TYPES OF PERSONAL DATA PROCESSED BY THE SCHOOL

This will include by way of example:

• dates when you or your child attended the School (if applicable);

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• pupil date of birth; sibling records; previous school (if applicable); ethnicity and religious

beliefs (if supplied);

• car details (about those who use our car parking facilities);

• information about any bursaries or scholarships you have received;

• how you would like to hear from us e.g. whether you have signed up to receive emails from

us;

• your involvement with us e.g. if you provide talks at careers fairs;

• information and notes about visits to School or off-site;

• bank details and other financial information provided e.g. from donors or for event payments;

• your gift aid status (if applicable);

• information from articles in the media and from web searches;

• any dietary requirements for catering purposes that you have provided;

• any disability which you may have so that we may make reasonable adjustments for you;

Taking, Storing and Using Images of Children Policy and CCTV Policy); and

• Log-ins and activity on the School’s online alumni community website, including messages that

are sent to other community members via the direct messaging system when logged into this

website.

HOW THE SCHOOL COLLECTS DATA

Generally, the School receives personal data from the individual directly (including, in the case of

younger past pupils, from their parents). This may be via a form, or simply in the ordinary course of

interaction or communication such as email. In addition, basic data regarding former pupils and their

We are grateful to individuals for sharing their professional experiences with pupils in order to inspire

them through talks and to assist them through career advice or work experience. We are also

interested to learn of individuals’ professions as talks from these individuals may assist us in raising

funds for our charitable causes. On occasions therefore, we may obtain information from public media

and internet sites (e.g. LinkedIn) to find information about your professional life and to contact you to

find out if you would be interested in supporting us by talking at our events.

However, in some cases personal data will be supplied by third parties (for example another alumni,

or other professionals or authorities working with that individual in addition to wealth screening

organisations when required); or collected from publicly available resources.

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developers or cloud storage providers. In accordance with Data Protection Law, this type of external

data is always subject to contractual assurances that personal data will be kept securely and only in

accordance with the School’s specific directions.

legal advice;

• We will need to share information if there is an emergency, for example, if you are hurt whilst

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KEEPING IN TOUCH AND SUPPORTING THE SCHOOL

The School will use the contact details of members of the School community to keep them updated

organisations set up to help establish and maintain relationships with the School community,

such as the Old Wulfrunians’ Association and Friends’ Association.

• Contact former pupils, parents and/or alumni, including via the organisations above, by post

and email in order to promote and raise funds for the School and, where appropriate, other

worthy causes;

• Collect information from publicly available sources about parents’ and former pupils’

occupation and activities, in order to re-establish lost contact and to maximise the School’s

fundraising potential.

Should you wish to limit or object to any such use, or would like further information about them, please

We may send your information to countries which do not have the same level of protection for

personal information as there is in the UK, e.g. when communicating with you if you live overseas, or

storing your information on computer servers based overseas. The European Commission has

produced a list of countries which have adequate data protection rules. The list can be found here:

Data protection adequacy for non-EU countries (europa.eu)

If the country that we are sending your information to is not on the list, or is not a country within the

EEA (which means the European Union, Liechtenstein, Norway and Iceland), then, in the absence of

any other safeguards, it might not have the same level of protection for personal information as there

Director.

YOUR RIGHTS

Individuals have various rights under Data Protection Law to access and understand personal data

about them held by the School, and in some cases ask for it to be erased or amended or have it

transferred to others, or for the School to stop processing it, but subject to certain exemptions and

limitations.

The School will endeavour to respond to any such written requests as soon as is reasonably practicable

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Rights of access etc.

The School will be better able to respond quickly to smaller, targeted requests for information. If the

School will not necessarily delete or amend views, opinions, notes or records purely on the request of

an individual who disputes the account, although we may keep a record of all parties’ viewpoints.

Requests that cannot be fulfilled

You should be aware that GDPR rights (including the right of access) are limited to your own personal

data, and certain data is exempt from the right of access. This will include information which identifies

other individuals (and parents need to be aware this may include their own children, in certain limited

situations – please see further below), or information which is subject to legal privilege (for example

legal advice given to or sought by the School, or documents prepared in connection with a legal action).

You may have heard of the "right to be forgotten". However, we will sometimes have compelling

reasons to refuse specific requests to amend, delete or stop processing your (or your child's) personal

data: for example, a legal requirement, or where it falls within a proportionate legitimate interest

identified in this Privacy Notice. Generally, if the School still considers the processing of the personal

data to be reasonably necessary, it is entitled to continue. All such requests will be considered on their

own merits.

Former Pupil requests

Former pupils can make subject access requests for their own personal data, provided that, in the

Former pupils at Wolverhampton Grammar School aged 13 and above are generally assumed to have

this level of maturity, although this will depend on both the child and the personal data requested,

including any relevant circumstances at home. Slightly younger children may however be sufficiently

mature to have a say in this decision, depending on the child and the circumstances.

Former Parental requests

It should be clearly understood that the rules on subject access are not the sole basis on which

information requests are handled. Former parents may not have a statutory right to information, but

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Consent

Where the School is relying on consent as a means to process personal data, any person may withdraw

even without your consent.

That reason will usually have been asserted under this Privacy Notice or may otherwise exist under

some form of contract or agreement with the individual (e.g. the parent contract, or because a

purchase of goods, services or membership of an organisation such as the Alumni or Friends'

Association has been requested).

Whose rights?

The rights under Data Protection Law belong to the individual to whom the data relates. However, the

processing in question, and the former pupil's age and understanding to seek the former pupil's

consent. Former parents should be aware that in such situations they may not be consulted, depending

on the interests of the child, the parents’ rights at law or under their contract, and all the

circumstances.

DATA ACCURACY AND SECURITY

The School will endeavour to ensure that all personal data held in relation to an individual is as up to

date and accurate as possible. Individuals must please notify the School of any significant changes to

important information, such as contact details, held about them.

The School will take appropriate technical and organisational steps to ensure the security of personal

data about individuals, including policies around use of technology and devices, and access to School

systems. All staff and Directors will be made aware of this policy and their duties under Data Protection

Law and receive relevant training.

THIS PRIVACY NOTICE

The School will update this Privacy Notice from time to time. Any substantial changes that affect your

rights will be provided to you directly as far as is reasonably practicable.

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If an individual believes that the School has not complied with this policy or acted otherwise than in

accordance with Data Protection Law, they should utilise the School’s Complaints Policy and should

also notify the Finance Director. You can also make a referral to or lodge a complaint with the