Introduction : Thank you for visiting The Edinburgh Academy's privacy policy.

We respect your privacy and are committed to protecting your personal data. In this policy we explain what personal data we collect, how it is collected, how we may use it and how we look after it.  We also explain your rights and how the law protects you.

When we collect personal data, we must do so lawfully, fairly and in a transparent manner. Part of our commitment to transparency is providing you with a clear and easy to access policy that outlines our use of personal data.  We provide this policy online in a layered format so you can click through to specific areas of interest to you.  

It is important to read this together with any other privacy information we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we are using it. This policy supplements other notices and policies: it is not intended to override them.  For instance, additional information about use of your personal data when interacting with our website is contained in our Cookie Policy, available here (it also explains what cookies are). 

1.                   Who we are & purpose of this policy

The Edinburgh Academy is made up of different legal entities.  This policy applies to both

·         The Edinburgh Academy (Royal Charter RC000168, Scottish Charity number SCO16999)

·         The Edinburgh Academy Foundation (Company registration SC181779, Scottish Charity number SCO027543)

which we refer to as The Edinburgh Academy.  Our registered office is at 42 Henderson Row, Edinburgh, EH3 5BL. When we mention "we", "us" or "our" in this privacy policy, we are referring to those entities, which are joint controllers of your personal data.

A separate privacy policy, applies to AccessEA and is available on request. It consists of Edinburgh Academy Trading Limited (company registration SC167036) and Edinburgh Academy Enterprises Limited (Company registration SC130146)

Our Bursar at The Edinburgh Academy is Data Protection Coordinator and responsible for handling queries about this policy. If you have questions, including requests to exercise your legal rights, please email [email protected] or alternatively contact +44 (0)131 624 4920 or +44(0)131 624 4941

What this privacy policy explains

This policy sets out how we use personal data of current and former pupils (who we refer to as “Accies”), their parents, guardians or carers (who we refer to simply as “parents”), friends  and  supporters of the Edinburgh Academy, and its trustees.

Changes to the privacy policy

This privacy policy is reviewed regularly.  It was last updated on 23 May 2018. Historic versions are archived and can be obtained by contacting us if required.

Implementation of this policy is subject to periodic audit and the policy is reviewed at three yearly intervals or earlier if legislation or changes makes a review necessary.

Your duty to inform us of changes

It is important the personal data we hold about you is accurate and current. You will receive reminders from us from time to time to ensure that we hold the correct details about you – of course, if you were to move or change your contact details, or your personal data changes during your relationship with us, then we would appreciate if you told us

2.                   Personal data we may collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·         Contact data includes address, email address and telephone numbers.

 

·         Criminal offence data includes personal data relating to criminal convictions and offences or related security measures.

 

·         Education data includes information which relates to the education and skills of an individual, such as their student and pupil academic and attendance records and qualifications, examination scrips and marks, information about your time at the school, including student society and sport club memberships and achievements, references given or received by the School about pupils and information provided by previous educational establishments or other professional and/or organisations working with, information from their time at the School and correspondence with and concerning pupils and parents.

 

·         Employment data includes information relating to the employment of an individual, including employment and career history, professional career and business activities

 

·         Family, lifestyle and social circumstances data includes contact details for next of kin, where appropriate, and information relating to the family of the data subject, for example details of family and other household members, their involvement with activities at the School, as well as car details (for those who use the car parking facilities), alongside information about the data subject’s lifestyle and social circumstances, including housing, travel details, habits, interests and preferences and leisure activities, membership of charitable or voluntary organisations, philanthropic propensity and capacity to aid meaningful fundraising, and (in the case of some) current marriage, partnerships and marital history.

 

·         Financial data includes bank account and payment card details.

 

·         Identification document data includes information issued as an identifier by a public authority, such as national insurance numbers, identity card numbers, driving licence details, passport details, and any other information required by the Edinburgh Academy

 

·         Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, gender, age, date of birth and any information that identifies an individual and their personal characteristics, including physical description and immigration status information (such as visa status, including right to work or right to study in the United Kingdom).

 

·         Image data includes photographic and video images of pupils and occasionally other individuals including family, engaging in school activities, and images captured by the CCTV system. in accordance with the Edinburgh Academy’s policies on the use of CCTV, taking, storing and using images of children and social media)

 

·         Marketing and Communications data includes preferences in receiving marketing and communications from The Edinburgh Academy and third parties, such as AccessEA

 

·         Profile data includes online username and password, information provided about interests and preferences, online survey responses and feedback.

 

·         Special category data includes personal data revealing nationality, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (where used for identification purposes), sexual orientation, information concerning a person’s sex life or health, which may include additional support needs information.

 

·         Technical data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used

 

·         Transaction data includes details about payments from an individual and other details of services purchased, and information about any donations and/or gifts

 

·         Usage data includes information about how website services are used, such as pages you have visited (including date and time), services and pages you viewed or searched for, page response times, download errors, files downloaded, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from a page.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. (For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.)

If you fail to provide personal data

Where we need to collect personal data – for example, to comply with a legal obligation, or under the terms of a contract we have with you – and you do not provide it, we may not be able to provide the services you expect.  We would contact you to further discuss any such situations if this arose.

3.                   How your personal data may be collected

We use different methods to collect data, including through:

·         Direct interactions: Generally, The Edinburgh Academy receives personal data from individuals directly (including, in the case of pupils, from their parents). You may give us personal data about yourself, immediate family members and about current/prospective pupils or students, for example when filling in online forms available on this website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o   request information to be sent to you;

o   apply for a pupil’s admission;

o   contract our services;

o   subscribe to our publications; or

o   give us feedback or contact us.

·         Automated technologies or interactions. As you interact with our website, it automatically collects Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. Please see our Cookie policy for further details.

·         Third parties: In some cases, personal data may be provided by third parties, for example:

o   a guardian or parent on behalf of a pupil;

o   Local Authorities, including for example social services professionals;

o   another school or college which pupils have attended;

o   professionals working with that individual, including for example professional counsellors or educational psychologists;

o   providers of health care services, including for example NHS Scotland

o   regulatory or government sources or law enforcement agencies, including for example Police Scotland

o   friends who on occasion inform us that you may be interested in an event and would probably welcome an approach by the Edinburgh Academy

o   AccessEA

o   independent service providers we use to run events which you attend, for example EventBrite or TicketTailor or Just Giving

 

·         Publicly available and also subscription-based sources We may collect personal data about you from sources including the Electoral Register, social media, business and financial reference sources, such as Linkedin

4.                   How we use your personal data

We use your personal data in accordance with data protection laws. Most commonly, we will use it in circumstances where the following lawful basis are available:

·         Where we need to comply with a legal obligation

·         Where we need to perform a contract have entered into (or are about to enter into) with you

·         Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 

The Edinburgh Academy’s legitimate interests include contributing to the educational life of Scotland in its widest sense, which would include

o   to advance health, public participation in sport, arts and culture through the provision of facilities for enjoyment by the public;

o   to assist with and cooperate on matters likely to promote the advancement of education for the public good;

o   to advance citizenship and community development;

o   to engage with the wider community through (but not limited to) the organisation of holiday camps and the provision of facilities and benefits related to the purposes of the Edinburgh Academy for enjoyment by the public or those who may not be enrolled pupils.

In exceptional circumstances, vital interests can be our lawful basis, when personal data is used where necessary to protect someone’s life.

Generally, we do not rely on consent as a legal basis for processing personal data.  But we will get consent in some situations, for example involving use of special category data or image data.  Also we would obtain your consent before sending fundraising or marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.

5.                   Purposes for which we will use your personal data

We set out below ways we may use your personal data.

Note that we may process your personal data for more than one lawful ground listed in the section above, depending on the specific purpose for which we are using your data. Please contact us if you require further information.

 

Edinburgh Academy will use personal data for:

·         providing information about our school through a range of online and offline channels, which would include social media, sending you emails and e-newsletters and publications (Supporting EA Magazine, Chronicle, The Academical etc.), sharing Accie and supporter news and activities, invitations to events and meetings and reunions, keeping you up to date about the goings-on at the school and to highlight networking, career and volunteering opportunities

·         administration of the admissions process

·         delivering educational, academic and welfare services (if you are a pupil), which would include recording academic progress, safeguarding pupil welfare, ensuring that we provide sufficient and appropriate pastoral care for the pupil, getting in touch in the event of emergencies, and the provision of references

·         enabling pupils to take part in national or other assessments, which would include providing certificates and publishing results of public examinations or other achievements of pupils

·         enabling relevant authorities to monitor the school's performance, which would include carrying out or cooperating with any school or external investigation, disciplinary or complaints process, or  intervening/assisting with incidents as appropriate

·         organisation and administration of any extra-curricular event or activity, which would include to hold conferences, meetings, lectures and exhibitions for the consideration and discussion of matters concerning or affecting or incidental to the objects of The Edinburgh Academy and issue reports of proceedings of conferences, meetings, lectures and exhibitions and generally to collect, collate, exchange and publish information and advice in furtherance of our objects

·         carrying out obligations from any contracts entered into between you and us, which would include managing payments, fees and charges, collection and recovery of money owed

·         managing our relationship with you, which would include communication informing of services and benefits available to pupils and parents, and notifying you about reunions, networking, such as the message forwarding services provided to our Accies, as well as volunteering and career opportunities

·         changes to our terms and/or privacy policy

·         security purposes, including operation of a number of CCTV cameras (with a 30-day retention policy in respect of all footage).

·         administration of bursary and scholarship funds, funding research and appointing third parties to carry out research projects

·         for the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law such as tax, diversity or gender pay gap analysis

·         preparing, editing, publishing, selling and circulating such books, papers, magazines, periodicals, gazettes, publications, circulars and other literary undertakings and films and other visual or audio aids as The Edinburgh Academy may think desirable for the promotion of its objects, and maintaining a library and collection connected with or incidental to any of the objects of The Edinburgh Academy;

·         ensuring that content from our website is presented in the most effective manner for you and your computer, and as part of our efforts to keep our site safe and secure.  For example, when you visit our website it may collect information about you to administer our site and for internal operations, including research, data analysis, testing, and troubleshooting

·         providing details of Accie events and other events organised by the Edinburgh Academy’s Development Department

·         to raise philanthropic funds to support key capital projects, scholarships and widening access programmes, and a range of projects to enhance the teaching and learning environment for our students and the community

·         for the purposes of donor due diligence, and to confirm the identity of prospective donors and their background and relevant interests

·         to promote such charitable causes as The Edinburgh Academy shall think fit, including but not limited to The Edinburgh Academy itself.

 

The Edinburgh Academy may from time-to-time process “special category” personal data as described above.  For example, it is used for the provision of health care and welfare, which means we may need to access pupils’ medical records.

 

Also, to comply with security vetting and/or Child Protection legislation, from time to time the Edinburgh Academy may need to process “criminal offence” personal data, which includes information about criminal convictions or alleged offences.  Such processing will only be undertaken when strictly necessary and with absolute respect to individual privacy and confidentiality.

 

Where special category personal data is processed, we seek the explicit consent of the pupil or parents unless it is necessary to use that information without explicit consent and it is lawful to do so.  That will only be in limited and exceptional circumstances (involving safeguarding, for example, or where we consider this to be necessary to protect the interests of an individual who is incapable of giving consent).

 

Fundraising, marketing and advertising

We provide you with choices regarding certain personal data uses, particularly around fundraising, marketing and advertising.   

 

If you have sent a pupil to The Edinburgh Academy, we may use your personal data to form a view on what we think you may be of interest or relevant to you and send information about similar services or merchandise.  You can ask us to stop sending such messages by following the opt-out links in the message or by contacting us at any time.

 

Further detailed information about purposes for which we may use personal data for Development and Alumni Relations is  detailed at the end of this notice, and available on request.

Changes of purpose

We only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

 

If you ever wanted an explanation about how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6.                   Disclosure of your personal data

To provide services and complete tasks we may from time-to-time share some of your personal data with external third party service providers, agents, subcontractors and other associated organisations listed below for the purposes set out above.

·         Service providers acting as processors who provide IT and system administration services, card payment processing, the management and distribution of mailing, such as MailChimp

·         External contractors, such as excursion/trip organisers, external school counsellors, visiting art/music tutors or teachers for workshops, other schools, universities and colleges, external providers of facilities for pupils, organisations involved in exchange programmes or extra-curricular activities, sports bodies, service providers we use to run events which you attend, for example EventBrite or TicketTailor

·         Regulatory, law enforcement and/or government authorities, such as Education Scotland, local authorities, Police Scotland, and  HM Revenue & Customs in certain circumstances

·         Professional advisers including lawyers, bankers, auditors and insurers  who provide consultancy, banking, legal, insurance and accounting services

·         Edinburgh Academy Trading Limited, for commercial activities

·          The Edinburgh Academical Club

In some instances, we will pass some of your details on to a third party, with your permission, for publicity purposes or to register your association with The Edinburgh Academy. This may include placing details of your name in the School Donor Roll.

The Edinburgh Academy would also share personal data in the unlikely event that all or part of the Academy were acquired or reconstituted, or we were setting up some form of joint working or partnership arrangement in the UK or abroad. In such circumstances, appropriate legal safeguards including confidentiality agreements would be put in place as required.

Disclosure is always subject to contractual assurances that personal data will be kept securely and only in accordance with our specific directions.  We require all third parties to respect the security of your personal data and to treat it in accordance with the law. For example, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or alternatively by using specific contracts approved for use in the UK which give personal data protection equivalent to what is available in the UK. Please contact us if you want further information.

7.                   Security of your personal data

We are required to keep your personal data safe and secure using appropriate technical and organisational means. This includes both physical and electronic security. 

 

Your personal information will be stored securely on our encrypted computer systems and in secured physical storage in the United Kingdom. We have put in place appropriate measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They only process your personal data on our instructions, and they are subject to a duty of confidentiality. Also, we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

We regularly review and update our measures in order that we are providing an appropriately high level of safety and security. 

 

8.                   How long will you hold onto my personal data?

Our Retention Policy, which explains how long we may hold onto your personal information, is available on request.

 

When we store personal data, we only hold it for as long as is necessary. The amount of time that we may hold different types of personal data about you can vary, for example depending on whether you are a parent or pupil.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

9.                   Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, namely your right to

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

·         If you want us to establish the data's accuracy.

·         Where our use of the data is unlawful but you do not want us to erase it.

·         Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

·         You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to complain: you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

If you wish to do so, or to exercise any of the rights set out above, please email [email protected] or alternatively contact +44 (0)131 624 4920 or +44(0)131 624 4941

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. (Alternatively, we could refuse to comply with your request in these circumstances).

We may need to request specific information from you to confirm your identity and ensure your right to access personal data or to exercise any of your other rights. We may ask you to provide a copy of your current and valid passport and/or driving license plus a utility bill (no more than 3 months old and with your current address) and we might also ask you to visit our office or obtain a solicitors or notary public’s confirmation of your identification.

All of this might sound onerous but please understand that we have an obligation to protect your personal information and we need to be certain that it is being released to the right person.  This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to requests within one month. Occasionally it could take us longer if your request is particularly complex. In this case, we will notify you and keep you updated.

Contact us

This Privacy Policy was prepared with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of your personal information. However, we are happy to provide additional information or explanation needed.  If you have any questions, comments or requests then please get in touch with us. 

 Version 2.0 (10-08-2023)

Development and Alumni Relations Privacy Notice Addendum

1.       Purpose

Accies (former pupils of The Edinburgh Academy),  friends  and  supporters  play  an  important  role  in the  life  of The Edinburgh Academy, contributing to our achievements and supporting our ambition to ensure we deliver an outstanding educational programme, while supporting students to strive to be the best in all that they do, during and after their time at the Academy.

The Development Office is here to support Accies, friends and supporters, keeping you informed as to what is happening at the Academy and beyond: engaging with you on relevant activities which we hope will be of interest to you. This includes sharing Academy, Accie and supporter news and activities, events, reunions, fundraising campaigns, networking, career and volunteering opportunities. We cannot connect with you, without making use of your personal data, which, more often than not, will involve your contact details.

The Development Office within The Edinburgh Academy works in tandem with the Edinburgh Academical Club, and the Edinburgh Academy Foundation.  

The protection of personal information collected and processed by the Academy is legislated through the European and UK legislation, notably through the General Data Protection Regulations (more commonly known as the UK GDPR), the Data Protection Act 2018 (“the DPA”) and through rules on direct marketing activities as provided by Privacy and Electronic Communication Regulations 2003 (“the PECR”). The Academy takes its obligations to protect personal information and to uphold the rights and freedoms of individuals seriously.

One of the core principles of data protection legislation is that personal data is processed fairly. Fairly, in this context, is concerned with individuals being informed as to how their personal information will be used. It is important that the Academy is clear about how personal data will be used to support Development and Accie related activities.

The purpose of this statement is therefore to inform Accies and friends how their personal information will be used by the Academy, and to set out our promise to you that –

The Academy will work at all times to protect your privacy. We will only make use of your personal data for clearly stated purposes and we will always respect and uphold your rights.

2. Our Work

The Development Office exists to communicate The Edinburgh Academy’s activities, institutional views, latest news and points of excellence with: staff, stakeholders, students, Accies, friends, current and past supporters of the Academy. The Development Office is also responsible in raising philanthropic funds to support key capital projects, scholarships and widening access programmes, and a range of projects to enhance the teaching and learning environment for our students and the community.  We do this by providing information through a range of online and offline channels including publications, events, press releases, social media and email.

In order to do this, we maintain a database that contains personal data collected by the Academy during the course of our relationship with our stakeholders, staff, students, Accies and friends. The vast majority of the information we hold will have been obtained directly from you via our website’s sign-up form or other hard copy information returns and also via letter, email, social media interaction, telephone updates from you and Valete forms.

3. How do we collect your personal data

3.1. After you leave

To create the basis of your record, the following core Accie information is carried over from your student record and Valete form:

• Your name, title, gender, date of birth;
• Your home or parental address, and telephone number(s);
• Your email address;
• Your years as Edinburgh Academy;

• A list of your student sports clubs memberships and achievements;
• Membership of societies;
• Scholarship award and prizes information and other achievements;
• Up to date business information and contact details shared through LinkedIn, Graduway and other Careers activities.

 

3.2. When engaging with the Development Office

In most instances, the Development Office will collect data from Accies and friends of the Academy when directly when engaging with you; or you may have provided your details to the Academy, along with your consent for their use, at your request via our sign-up form, letter, online updates, social media interaction or email.

3.3. Payment processing

We collect bank or credit/debit card details in order to process event ticket or donation payments but we will not store bank or credit/debit card details beyond the requirements for processing the payment. This may involve using third parties to assist in setting up Direct Debit payments and processing your donations or ticket payments.

3.4. Via an Accie/parent or friend of the Academy

Accies, parents and associates often drift away from Academy activities. Signals that a person wishes to reengage/maintain positive engagement often come to light from friends. Those friends (who are engaged Accies) will on occasion inform the Development Office about these individuals and that they may be interested in an event and would probably welcome an approach by the Academy. The Academy may follow-up, and where those individuals do not want to engage further, no further use of their contact details will be made.

 

 3.5  Via a third party who has asked your permission to pass on your details to the Development Office

On occasion, we may receive your details from independent event organisers e.g. Just Giving. These independent third parties will only provide us with your details, with your consent, when you have confirmed that you wish to support The Edinburgh Academy. You may wish to request and check the privacy notices of such third parties, to ensure that you understand fully how your details will be used and that you are happy with any decisions made.

 3.6. When using our Website and similar services

Some of the Academy’s web pages, with a user’s consent, will log how a person has explored the content that is made available. This information is used, where provided, so that we can understand how to improve our services.

Some of the emails we send allow us to understand where communications have been read or unopened. Where emails are unread, we may then ask people if they wish to hear from us via that medium.

For more information on log files and Cookie policy please visit: https://www.edinburghacademy.org.uk/17/cookie-policy

4. The purposes for which the Academy will make use of Accie/donor personal data

The personal data stored and processed by the Academy (depending on how you engage with the Academy) may include:

·         Biographical information such as name, title, date of birth and gender;

·         Your contact details including address(es), email address(es) and phone number(s);

·         Information about your time at the Academy;

·         Your professional activities; current interests and preferences;

·         Your business and career details including your philanthropic propensity and capacity to aid meaningful fundraising;

·         Records of communications sent to you by the Development Office or received from you.

 

If you do not wish your data to be used in any of the ways listed above or have questions about this, please contact the Development Office.

5. The Academy may use your personal data, to support the following activities:

5.1. Our range of communications with Accies and friends

We aim to keep people informed about our work or our activities and the positive impact this has on students and the Academical community. This might include sending you e-newsletters, publications (Supporting EA Magazine, Chronicle, The Academical etc.), invitations to events, meetings and to highlight suitable volunteering opportunities.

We offer a postal/email messaging forwarding service for Accies whereby we will pass on communications on your behalf until permission for you to connect directly is received e.g. organising a class reunion and wish assistance issuing invitations, or where you have lost contact with an Accie.

5.2. Keeping you up to date via email

Where you have provided your email address to us, we will make use of that to contact you for the specific purposes, which you have consented to. In every event or invitation email we send, we will give you the opportunity to opt-out from receiving further emails, until such time as you may decide to ask for us to contact you again via that medium.

5.3. Keeping you up to date via post

We may reach out to you, by posting materials that you have requested or expressed an interest in. Where we may have lost touch with people, we may, where it is acceptable in terms of your and our interests, try and reach you by post. If you decide you do not want to receive post from us, please tell us.

Where appropriate, we may employ the use of National Change of Address supress and update services for participating countries (“NCOA”). These services allow us to cut down on wasted mailing costs and help ensure the accuracy of our address data. We may also employ the use of Postcode Lookup services, to enable our data to be as accurate as possible.

5.4. Keeping you up to date via telephone

Where you have provided a contact number, we may reach out to you via telephone to provide updates on Academy projects and life, events and if desired, discuss donations. If you decide you do not want to receive communications in this form, please tell us.

5.5. Understanding the career progression of our Accies

From time to time, we can lose track of where people work as their careers progress. The Development Office undertake some research to understand where people have moved onto in their careers; we may then use that information i.e. business contact details to reach out to you, normally via post, to ask if we can update your details and continue to stay in touch with you.

6. Fundraising

We may, where appropriate, ask you to help us raise money or donate money to The Edinburgh Academy, via The Edinburgh Academy, or The Edinburgh Academy Foundation, but always in accordance within the regulations and best practise guidelines set out by the bodies including the Scottish Charities Regulator OSCR, the Independent Fundraising Standards & Adjudication Panel for Scotland 

Also we may use your personal data for some or all of the following, depending on individual circumstances and how you engage with us:

·         To create an account for you upon leaving the Academy, contact us independently, or have an external connection with us;

·         For administration purposes (for example, we may contact you about a donation you have made or an event you have expressed an interest in or registered to attend);

·         To facilitate payments made by credit card, direct debit or bank/wire transfer;

·         To reclaim gift-aid from the tax authority;

·         For the purposes of credit risk reduction or fraud prevention;

·         To ask for your permission to use the story of your experience with The Edinburgh Academy to promote our work (via printed or online publications);

·         For internal record keeping, including the management of any feedback or complaints.

 

7.  Research

We want to make sure we use the Academy’s resources as effectively as possible to help us engage with our community of Accies and supporters appropriately. In order to achieve this, we may undertake a range of desk-based background research. This will help us to gain a better understanding of your interests and how you engage with us, which in turn will help us to decide whether an approach to you is likely to be of interest. Such research helps us to better target our conversations about fundraising and therefore generate philanthropic funds cost-effectively.

When conducting research, we always do this in-house, with Development Office staff who work within set guidelines and standards. Open source materials are used i.e. publicly available sources and or subscription based sources, including social media, directories such as the electoral register, and business and financial reference sources. The Development Office do not undertake what is commonly referred to as third party wealth profiling.

We may employ data mining and predictive modelling techniques to forecast the probability of successful support approaches.

From time to time, we may undertake research using the records held by the Development Office to understand demographic, philanthropic, and business trends. We do this to help understand whether we are reaching people efficiently and effectively, and/or to help ensure that relevant communications are sent to you.

If you do not wish your data to be used in any of the ways listed above or have questions about this, please contact the Development Office.

8. Who will make use of your personal data?

8.1. Within the Academy

On a day-to-day basis, your personal data will be used by staff within the Academy, Careers department, the Development Office and the Edinburgh Academical Club for the purpose of running events or connecting with you.

Some personal data may be passed to the Academy’s Finance Office for audit, accounting and regulatory purposes, or to the Edinburgh Academy Foundation or Access EA.

8.2. Outwith the Academy i.e. to third parties

The Academy will never share your personal data with another charity or similar third party to use for their own purposes, unless we are required to do so by law, e.g. where served with a court order or for the purposes of prevention of fraud or other crime. The Academy will never sell your personal data.

The Academy may from time to time, pass some of your personal data to third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our  behalf.  Those tasks can include event ticket and donation payment processing, the management of mailing and distribution, campaign management, crowdfunding or event management.

On the occasions that we use third party service providers, we will only disclose the minimum information necessary to deliver that service, and there will always be a contract in place to ensure that the selected service provider will only make use of your information for the purposes set out by the Academy and that they have in place measures to protect and keep your details secure.

In some instances, the Academy will pass some of your details on to a third party, with your permission, for publicity purposes or to register your association with the Academy. This may include placing details of your name in the Academy Donor Roll.

In addition to the above, the Academy may disclose certain personal data to external bodies as categorised below. At all times, the amount of information disclosed, and the manner in which it is disclosed, will be in accordance with the provisions and obligations of European and UK data protection legislation. Please note this is not an exhaustive list.

Disclosure to for the purposes of	Details
Courts of law and Tribunals	The Academy will provide personal data to a named entity or person, when instructed to do so by Court Order or decree, unless a successful challenge to such an order is made.
Government agencies and local authorities, with statutory powers to obtain information from the Academy as an educational institution and/or a registered charity.	For the purposes of meeting external regulatory requirements.
HM Revenue and Customs (“HMRC”)	To reclaim gift aid.
Law enforcement agencies	The Academy may provide personal data to law enforcement agencies, where there is just cause, for the: prevention and detection of crime; apprehension and prosecution of offenders; assessment or collection of any tax or duty or imposition of a similar nature; or any matters pertinent to national security.   Prior to the release of personal data to the Police or a relevant authority, for the purposes noted, above, the Academy will first satisfy itself that a request is legitimate and that the disclosure of the personal data is lawful. In this regard, the Academy will make reference to the provisions from relevant data protection legislation.
Media outlets	The Academy may pass on personal data to the media in terms of press releases, which may provide details of a person’s relationship and/or work at the institution.

9. Details of transfers of personal data to countries outwith the EEC

The Academy may transfer Accie/donor details outwith the UK, for the purpose of organising events to which individuals have opted to attend.  Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or alternatively by using specific contracts approved for use in the UK which give personal data protection equivalent to what is available in the UK. Please contact us if you want further information.

10. How long will the Academy make use of your personal data to support Accie and development activities?

Unless individuals direct otherwise, the Academy’s relationship with Accies, friends, donors and other stakeholders is considered to be life-long. The Academy will retain your personal data to support the Accies/Development activities outlined herein, until you ask us to do otherwise.

Please note that in some circumstances, so that the Academy can continue to meet its other legal obligations it may be required to retain personal data in accordance with tax and accounting rules, and charity law including holding accurate data for maintaining key records.

The Academy follows best practice records retention periods, and the Academy’s retention policy is available upon request. 

Version 2 - 10-08-2023