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PRIVACY NOTICE
 
WHO WE ARE

The Merchistonian Club (the Club) whose address is 294 Colinton Road Edinburgh, EH4 2DZ is an unincorporated business, social and sports club established for the former pupils of Merchiston Castle School. The Club is a data controller for the purposes of the relevant legislation “Data Protection Law”.

This privacy notice is intended to cover only the activities of the Club. Any activities undertaken by Merchiston Castle School are subject to a separate privacy notice published on the School’s website here.
 
WHAT THIS PRIVACY NOTICE IS FOR
 
This policy is intended to provide information about how the Club will use (or "process") personal data about individuals including: current and past pupils of Merchiston Castle School and their parents, carers or guardians (referred to in this policy as "parents")

This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Past and current pupils and parents are all encouraged to read this Privacy Notice and understand the Club’s obligations to its entire community.

This Privacy Notice applies alongside any other information the Club 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 Club’s other relevant terms and conditions and policies, including:
  • any contract between the Club and the current and past parents of pupils of Merchiston Castle School;
Anyone who works for, or acts on behalf of, the Club (including staff, volunteers, governors and service providers) should also be aware of and comply with this Privacy Notice, which also provides further information about how personal data about those individuals will be used. 
 
 
RESPONSIBILITY FOR DATA PROTECTION
 
  • The Club has appointed the School’s Bursar as Compliance Officer.

    who will deal with all your requests and enquiries concerning how the Club uses your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.

    data-protection@merchiston.co.uk, 0131 312 2200, The Bursar, Merchiston Castle School, 294 Colinton Road, Edinburgh, EH4 2DZ
 
WHY THE CLUB NEEDS TO PROCESS PERSONAL DATA

In order to carry out its ordinary duties to past and current pupils, parents and staff of Merchiston Castle Shcool, the Club needs to process a range of personal data about individuals as part of its daily operation.

Some of this activity the Club will need to carry out in order to fulfil its legal rights, duties or obligations – including those under a contract with parents of its past pupils.

Other uses of personal data will be made in accordance with the Club’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.

The Club expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:
  • Maintaining relationships with current and past pupils and parents and the wider School community, including direct marketing of events being run by the School
  • Organising Club events and sporting opportunities for current and past pupils and parents
  • For the purposes of donor due diligence, and to confirm the identity of prospective donors and their background and relevant interests;  
  • To make use of photographic images of past pupils in Club publications, on the Club website and (where appropriate) on the Club’s social media channels
 
TYPES OF PERSONAL DATA PROCESSED BY THE CLUB

This will include by way of example:
  • names, addresses, telephone numbers, e-mail addresses and other contact details;
  • during their time at Merchiston Castle School, details of past pupils’ general and sports interests, positions held, achievements and prizes awarded, and their intended education destination or employment upon leaving the School.
 
HOW THE CLUB COLLECTS DATA

Generally, the Club receives personal data from the individual directly. This may be via a form, electronic survey, bi-annual Merchistonian membership update or simply in the ordinary course of interaction or communication (such as email).

For current pupils and parents of Merchiston Castle School, personal contact data will be supplied by the School under a data share agreement between the Club and the School.
 
 
WHO HAS ACCESS TO PERSONAL DATA AND WHO THE CLUB SHARES IT WITH


Occasionally, the Club will share personal information relating to its community with Merchiston Castle School staff under the terms of the data share arrangement, to promote, support and create opportunities for current School pupils.

For the most part, personal data collected by the Club will remain within the Club, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).

Finally, in accordance with Data Protection Law, some of the Club’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the Club’s specific directions.
 
 
HOW LONG WE KEEP PERSONAL DATA

The Club will retain personal data securely and in line with the lifetime membership category of past pupils. For past pupils, up-to-date contact and interest details will be sought every two years.

If you have any specific queries about how our retention policy is applied, or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Club Secretary.

A limited and reasonable amount of information will be kept for archiving purposes, for example; to maintain an historical record of pupils attending Merchiston Castle School and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").
 
 
KEEPING IN TOUCH AND SUPPORTING THE CLUB AND SCHOOL

The Club will use the contact details of parents, past pupils and other members of the school community to keep them updated about the activities of the Club, or School and parent events of interest, including by sending updates and newsletters, by email, website postings and by post.

Should you wish to limit or object to any such use, or would like further information about them, please contact the Club Secretary in writing. You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the Club is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number).
 
 
YOUR RIGHTS
  • Rights of access, etc.
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. 

Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Club Secretary email: merchistonians@merchiston.co.uk .

The Club will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).

The Club will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, the Club may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).
  • Requests that cannot be fulfilled
You should be aware that the right of access is limited to your 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 (for example legal advice given to or sought by the Club, 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 personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy Notice. All such requests will be considered on their own merits.
  • Consent
Where the Club is relying on consent as a means to process personal data, any person may withdraw this consent at any time. Eamples where we do rely on consent are: certain types of uses of images, certain types of fundraising activity. Please be aware however that the Club may not be relying on consent but have another lawful reason to process the personal data in question 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. a purchase of goods, services or membership of the Club).
  • Whose rights?
The rights under Data Protection Law belong to the individual to whom the data relates. However, the Club will often rely on parental authority or notice for the necessary ways it processes personal data relating to pupils – for example, under the parent contract, or via a form. Past and current pupils and parents should be aware that this is not necessarily the same as the Club relying on strict consent (see section on Consent above).
 
 
DATA ACCURACY AND SECURITY

The Club 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 Club Secretary email: merchistonains@merchiston.co.uk of any significant changes to important information, such as contact details, held about them.   

An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why the Club may need to process your data, of who you may contact if you disagree.

The Club will take appropriate technical and organisational steps to ensure the security of personal data about individuals and access to Club and School systems. All staff and committee members will be made aware of their duties under Data Protection Law and receive relevant training. 
 
 
THIS POLICY

The Club 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.
 
 
QUERIES AND COMPLAINTS

Any comments or queries on this policy should be directed to the Club Secretary using the following contact details telephone 0131 312 2262 or email merchistonians@merchiston.co.uk

If an individual believes that the Club has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the Club procedure and should also notify the Bursar at Merchiston Castle School. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk), although the ICO recommends that steps are taken to resolve the matter with the Club before involving the regulator. 

May 2018
 


 

 

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