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Privacy Notice

Who We Are

The Calne Girls Association (“CGA”) whose address is at St Mary’s School, Curzon Street, Calne, Wiltshire SN11 0DF, is a Data Controller, as defined in the Data Protection legislation.
What this Privacy Notice is For
This notice provides information about how CGA will use personal data about individuals.
This information is provided because Data Protection Law gives every individual the right to understand how their data is used.

Responsibility for Data Protection

The Alumnae Relations Manager, St Mary’s School, Calne is the Data Compliance Manager and will deal with all requests and enquiries concerning the use of personal data and will endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law. The Alumnae Relations Manager may be contacted at the School address, as above.

Why CGA Needs to Process Personal Data

In order to carry out its ordinary duties, CGA needs to process personal data about individuals as part of its legitimate daily operations.

CGA will need to carry out some of this activity in order to fulfil its legal rights, duties or obligations – including those under contracts (such as those with sponsors and donors). Other uses of personal data will be made in accordance with CGA’s legitimate interests, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.

CGA expects that the following uses will fall within that category of ‘legitimate interests’:

• To make use of photographic images of individuals in CGA publications, promotional materials, on the CGA website and on social media channels in accordance with the policy of St Mary’s School’s on taking, storing and using images.
• For security purposes.
• To carry out or cooperate with any complaints, disciplinary or investigation process.
• Where otherwise reasonably necessary for CGA’s purposes, including to obtain appropriate professional advice.
• For the purposes of informing individuals about CGA’s fundraising activities and requesting sponsorship and donations.

Types of Personal Data Processed by CGA
The personal data we process takes different forms – it may be factual information, images or other recorded information which identifies or relates to a living individual. Examples include;
• Names, addresses, telephone numbers, email addresses and other contact details.
• Correspondence.
• Images of individuals engaging in school activities

How CGA Collects and Handles Data
Generally, CGA will receive personal data directly from individuals. This may be via a form, or simply in the ordinary course of interaction or communication. Sometimes, personal data might be provided to CGA by third parties, such as other professionals working with that individual.
Personal data held by CGA is processed by appropriate members of staff for the purposes for which that data information was provided. We take appropriate technical and organisational steps to ensure the security of this information, including policies around use of technology and devices, and access to IT systems, as well as requiring at least equivalent steps to be taken by any third parties who process personal data on behalf of CGA.

Who has access to Personal Data and who is it shared with?
Occasionally, CGA might need to share personal information with third parties, such as:

• Professional advisors.
• The CFT.
• St Mary’s School, Calne.

Personal data collected by CGA will remain within CGA, and will be processed by appropriate staff only in accordance with access protocols (that is, on a ‘need to know’ basis).
Personal data is not transferred outside of the European Economic Area unless CGA is satisfied that the data will be afforded an equivalent level of protection.

Finally, in accordance with Data Protection Law, some of CGA’s processing activity is carried out on its behalf by third parties, such as IT systems providers, web developers, mailing houses and cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with CGA’s specific instructions.

How long we keep Personal Data
CGA will retain personal data securely and follows standard guidance as to the period for which it is necessary to keep the data for legitimate reasons. Please contact the Alumnae Relations Department, St Mary’s School, Calne, with any specific queries about the data retention policy, or with any request for erasure of personal data that you no longer believe to be relevant.
A limited and reasonable amount of information will be kept for archiving purposes, for example, even when you have requested that we no longer communicate with you, we will need to keep a record of that fact in order to fulfil your wishes (a ‘suppression record’).

Keeping in touch
CGA will use your contact details to keep you updated about its events and activities, and those of St Mary’s School and the CFT, including sending updates and newsletters by email and post. Unless you object, CGA may also contact you by post or email in order to seek to raise funds for the School. Should you wish to limit or object to any such contact, or would like further information, please contact the Alumnae Relations Department, in writing, at the School’s address. You always have the right to withdraw consent, where given, or otherwise object to receiving marketing or fundraising communications.
In such case, CGA is likely to retain some of your details (not least to ensure that no further communications are sent to a particular address, email or telephone number).

Your Rights
• Whose rights? The rights under Data Protection Law belong to the individual. Please refer to the Privacy Notice of St Mary’s School, Calne, for further information.

• Rights of access, etc. All individuals have various rights under Data Protection Law to access personal data about them which is held by CGA, and, in some cases, to ask for it to be erased or amended or have it transferred to others, or for the CGA to stop processing it.
Individuals wishing to access or amend personal data, or wish that it be transferred to another person or organisation, or have some other objection to how personal data is used, should put their request in writing to the Alumnae Relations Department.

• Requests that cannot be fulfilled.
Individuals should be aware that the right of access is limited to their own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals, or information which is subject to legal privilege.

Data Accuracy and Security
CGA will endeavour to ensure that all personal data held is as up to date and as accurate as possible. Individuals should notify the Alumnae Relations Department of any significant changes to important information held about them, such as contact details.
Individuals have the right to request that any out-of-date, irrelevant or inaccurate information held be erased or corrected (subject to certain exemptions and limitations under Data Protection Law).
CGA will take appropriate technical and organisational steps to ensure the security of personal data.

Queries and Complaints
Any queries about the application of this notice should be directed to the Alumnae Relations Department.
If you believe that CGA has not complied with any aspect of this notice or acted otherwise than in accordance with Data Protection Law, you should notify the Alumnae Relations Department. You can also make a referral or lodge a complaint with the data protection regulator, the Information Commissioner, although the regulator recommends that steps are taken to resolve the matter with the School as a first step.

 May 2018


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