Data Protection Statement

We use your data to keep in touch with you as life-long members of Emmanuel, as supporters and as friends, in order to keep you informed about our activities and developments, to provide services to you, and to identify ways in which you can support Emmanuel, through donations and other forms of financial and non-financial support.

This statement explains how Emmanuel College (“we” and “our”) handles and uses data we collect about Emma members and supporters, and others connected with the College (“you” and “your”).


How your data are used by the College

Your data are used by the College for a number of interdependent purposes, including relations with members, friends and supporters; communications; and fundraising. These include:

  1. maintaining a record of your academic progress and achievements of the College and the University of Cambridge and elsewhere,
  2. retaining a record of your academic, career or other life achievements in order to promote and improve the reputation of the College and help you to network with other College members effectively,
  3. including you in College and University events that we believe will be of interest to you, including alumni and other events, volunteering opportunities, and other ways you can contribute to the life of the College,
  4. providing you with information about the development of the College, including major initiatives and programmes relating to either academic endeavour or to the provision of services and facilities to members and the wider public,
  5. encouraging you to make a financial contribution to the College and/or the University, and processing any such contributions,
  6. helping us to plan our fundraising effectively.

Communications may be sent by post, telephone or electronically, depending on the contact details we hold and the preferences expressed by you about the types of communications you wish to receive. If you are a new contact for Emmanuel College, we will ask you at the outset how you would like to receive news and other communications from us. If you already receiving such communications, you are able to change your preferences (or ask us to stop sending you news and other communications completely) by contacting the Development Office. You may request changes at any time.

If you have concerns or queries about any of these purposes, or how we communicate with you, please contact us at the address given below.


The data held by the College

We believe that most members understand the complex and many interactions of the College with the University of Cambridge. Personal data of our members is shared with the University routinely throughout any course of study, and it is our strong preference to continue such collaborative working thereafter.

We have a separate database from the University, but we also have access to the University’s database: additionally, we maintain other electronic and paper records. Any transmission of data to or from the University is managed through agreed processes which comply with UK data protection legislation. The University has its own data protection statement and procedures.

The Appendix outlines the content of most records, made up of information provided by you, the University or obtained from reputable sources.

Where data are included from sources external to the University and the College, we only use data from our partners (as outlined below) or other reputable sources. We may use automated or manual analyses to link data together to help us identify your interest and potential for supporting the College and the University.

Before seeking or accepting donations we may conduct due diligence, including reviewing publicly available personal data relating to criminal convictions and offences.


When the College shares your data with others

Depending on constraints set by you, and which you may change at any time, we may share any of the above categories of data with the University.

Additionally, we share data on a considered and confidential basis, where appropriate, with:

  • Cambridge in America (the University’s affiliate alumni and supporters’ office in the US) and the board of the American Fund for Emmanuel,
  • volunteer partners closely related to the College (e.g. members of the Emmanuel Society’s Committee, Emmanuel ambassadors, development board members).

We also provide data under contract for specified time-limited purposes, including:

  • those providing services to you on our behalf or services to the College (our “data processors”) such as the telephone campaign coordinator,
  • third party agencies who provide us with data in the public domain about alumni and supporters, as outlined in the Appendix.

We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them.

We also facilitate communication between individual members (of the College or the University), but in doing so we do not release personal contact details without prior permission.

Any transfers of your data overseas or to international organisations, as set out above, are protected either by an adequacy decision by the European Commission or by standard data protection clauses adopted by the European Commission (which are available from our Data Protection Officer) or, before 25 May 2018, by a self-assessment of adequacy.


Your rights

The legal basis for processing your personal data is that it is necessary for the purposes of our legitimate interests, where we have concluded that our interests do not impact inappropriately on your fundamental rights and freedoms, except where elsewhere in this statement we have indicated otherwise. You may ask us to explain our rationale at any time.

You have the right: to ask us for access to, rectification or erasure of your data; to restrict processing (pending correction or deletion); to object to communications or direct marketing; and to ask for the transfer of your data electronically to a third party (data portability). In some cases we may be obliged to continue processing your data despite a request from you to stop doing so. If that is the case we would discuss it with you.

We will retain your data indefinitely or until you request us to do otherwise. When changes are made to this statement, we will publish the updated version to our website and notify you by other communications channels as we deem appropriate or necessary.

You retain the right at all times to lodge a complaint about our management of your personal data with the Information Commissioner’s Office.


Questions and further statutory information

The controller for your personal data is Emmanuel College Cambridge CB2 3AP.

The person responsible for data protection at the time of issue, and the person who is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, is the Bursar, Dr M J Gross, bursar@emma.cam.ac.uk.

Please contact us at the address given above if you have any concerns or questions about the above information. Where you have specific requests relating to how we manage your data, we will endeavour to resolve these, but please note that there may be circumstances where we cannot comply with your specific request.

Where you exercise your right to erasure, we will continue to maintain a core set of personal data (name, subject(s), matriculation and graduation details, unique University identification number and date of birth) to ensure we do not contact you inadvertently in future, while still maintaining our record of your academic achievements. We may also need to retain some financial records about you for statutory purposes (e.g. Gift Aid, anti-fraud and accounting matters).

If you have any concerns about your personal data held by the University, you will need to contact the University separately.


APPENDIX

We collect and process your personal data, as specified below, for a number of purposes, including:

A. maintaining a record of your academic progress and achievements of the College and the University of Cambridge and elsewhere:

We retain personal data (provided by you or by the University of Cambridge, or created by us), including:

  1. your current name and any previous names you have had,
  2. unique personal identifiers (e.g. student number, CRSID, date of birth),
  3. your current and previous contact details,
  4. matriculation and graduation details and records of your academic qualifications,
  5. other details of your academic progress or achievement (e.g. College or University awards or prizes).

B. retaining a record of your academic, career or other life achievements in order to promote and improve the reputation of the College and help you to network with other College members effectively:

We retain personal data (provided by you), including:

  1. details of your achievements since you completed your course(s) of study,
  2. membership of College and external clubs and societies (including alumni groups),
  3. your previous and current employment status (including retirement), including job title, sector, income and work contact details, dates of employment.

When you provide this information, we will always check with you before publishing achievements in our public literature. We may supplement information from other public sources that we consider to be reliable (e.g. your public social media profile(s), Queen’s Honours List, Companies House, high profile news reports or articles) and may check their accuracy with you from time to time.

C. including you in College and University events that we believe will be of interest to you, including alumni and open events, volunteering opportunities, and other ways you can contribute to the life of the College:

We retain personal data (provided by you or by the University of Cambridge, or created by us), including:

  1. known relationships with other members (past or present) of the University of Cambridge or any of the Colleges;,
  2. your previous attendance at College or University events,
  3. information about your areas of personal interest,
  4. personal data relating to your attendance at events and your personal preferences (e.g. dietary or accommodation requirements or requests),
  5. records of any communications (verbal or written) we have had with you, including the purpose and outcome of those communications.

When you provide this information, we will assume (unless you notify us otherwise) that we can use this information for other purposes outlined in this statement. We may supplement information from other public sources that we consider to be reliable (e.g. your public social media profile(s), University publications, high profile news reports or articles) and may check their accuracy with your from time to time.

D. providing you with information about the development of the College, including major initiatives and programmes relating to either academic endeavour or to the provision of services and facilities to members and the wider public:

We retain personal data (provided by you or by the University of Cambridge, or created by us), including:

  1. any communication preferences confirmed by you,
  2. ways in which you have supported the College.

By providing us with email addresses and telephone numbers, we have taken this to be consent to use those channels to contact you for this and other purposes outlined in this statement, unless you have outlined to us your preferred communication channels. When you provide this information, we will assume (unless you notify us otherwise) that we can use this information for other purposes outlined in this statement. By providing us with your telephone number, based on our previous experience of calling members and friends of the College, we have taken this to signify (unless you notify us otherwise) that you are happy to receive phone calls up until 10pm local time.

E. encouraging you to make a financial contribution to the College and/or the University, and processing any such contributions:

The College’s income consists of gifts and benefactions, income derived from prudent investment of any endowment and student fees. We value any financial contribution from our members and, accordingly, retain personal data (provided by you or by the University of Cambridge, or created by us), including:

  1. the purposes and amounts of any donations or other support previously provided to the University or the College by you,
  2. the method(s) of payments used and related payment references,
  3. your tax status and Gift Aid declaration.

Some of this financial information needs to be retained for statutory purposes for a number of years (e.g. Gift Aid, anti-fraud and accounting matters). When you provide this information, we will assume (unless you notify us otherwise) that we can use this information for other purposes outlined in this statement.

F. helping us plan our fundraising effectively:

The College undertakes research to stratify and segment our fundraising approaches. This is so that we can tailor our approaches to you in line with our understanding of your ability to support us. This results in us creating personal data including:

  1. your estimated income or asset worth (where this is not provided by you),
  2. your potential capacity to make a gift, within the college’s segmentation process. This is determined by a combination of your giving history, your attendance at College and University events, and your other interactions with the College since you graduated, including any positive or negative indications from you about your capacity or willingness to give to the College,
  3. gifts you have made to other charitable organisations.

Our research includes incorporating information from public sources that we consider to be reliable (e.g. your public social media profile(s), Queen’s Honours List, Companies House, high profile news reports or articles). In using these sources, we have considered the potential intrusion of your privacy. In most cases, our assessment above aims to exclude you from unwelcome or inappropriate approaches so as not to compromise your ongoing relationship with us.

We may use external contractors or consultants to assist us in this research. Where we do so, any sharing of your personal data is on the strict understanding that they may not repurpose it, pass it on to other third parties, or retain it. We do not sell your personal data under any circumstances.

If you have concerns or queries about any of these purposes, or how we communicate with you, please contact us.