Privacy

Holy Child Killiney maintains a database of [alumni/ friends/ supporters/ parents] in order to stay in touch with our community and keep you updated about news, events, careers initiatives and development activities.

Some of our database (but not all) choose to join our online community by registering on this website and creating an online profile. In both instances (individuals with offline database records and individuals with online profiles), we collect and store personal information (or “data”) about you. We are committed to protecting and respecting your privacy and this Policy sets out what information we collect about you, where and how we use (“process”) it.

We may change this Policy from time to time. If we make any significant changes we will advertise this on the website or contact you directly with the information. Please check this page occasionally to make sure you are happy with any changes.

If you have any questions about this Policy or concerning your personal information, please contact Caroline O' Brien at cobrien@holychildkilliney.ie, HCK, Military Road, Killiney, Dublin, Ireland, 01 282 3120.

For the purposes of the General Data Protection Regulations (GDPR) the Data Controller is Holy Child Killiney.

What type of personal information we collect

The information we have about you depends on where we collect it, but may include:

First name
Last name
Email
Address
Photographs
Gender
Date of birth
Family relationships
Years at Holy Child Killiney
Higher education and work details
Participation in our events, emails, competitions, surveys and other activities
Donations made to Holy Child Killiney
Geo-location data (your geographical location based on your IP address)
Log-ins and activity on the website
A record of payments made via the website (but we do not store your credit/ debit card details as these are processed securely externally by a third-party payment provider) which could include event tickets, shop purchases or online donations
Consent options and communication preferences
Content (such as announcements, stories, photos, documents, comments, events, jobs) that you post on this website or provide to us by other means
Messages that you send to other community members via the direct messaging system when logged in to this website

Where we collect information from

We collect personal information when you:

visit this website
create or update your online profile
post content on to this website or other websites and social media sites managed by Holy Child Killiney
take part in an event
attend a meeting with us and provide us with information
contact us in any way including online, email, phone, SMS, social media or post
open an email sent from this website
send a message via the direct messaging system on this website
leave Holy Child Killiney and we transfer some basic details about you from the main Holy Child Killiney database in to our [alumni] database.
Publicly available information.
Respond to information requests from us.

How we use your information

We will use your personal information in a number of ways, always with a legal basis for processing your data. These may include:

providing you with the information or updates that you have asked for
delivering our obligations under any contract between us
seeking your views on the services or activities we carry out, so that we can make improvements
updating our database records and ensuring we know how you prefer to be contacted
Donations/Financial information is stored and processed to maintain accurate financial records for the school and to comply with the Charities Regulator and Revenue Commissioners guidelines.
analysing your engagement with our website and other content to help us improve our services for you
running our mentoring programme/ club activities/ reunion events/ sports fixtures
Maintaining a record of the school’s relationship with members of its community, donors and prospective donors
Sending publications (e.g. newsletters, development updates, e-zines)
Event invitations and alumnae networking.
Invitations to support student development (to include careers talks and work placements).
Fundraising (including mail, email and telephone appeals).
Administrative purposes including routine financial management and administration including issuing receipts for donations, processing tax relief for donations received, addressing donation requirements determined by the Revenue Commissioners etc.
Profiling, wealth screening and research in order to improve our understanding of our alumni, supporters and community, inform our fundraising strategy and target our communications more effectively.

Our legal basis for processing your information

Whenever the school is engaged in processing personal data, we ensure that each processing activity relies upon an appropriate lawful basis. This means that one or more of the following will apply:

you have given your consent to processing for one or more specific purposes;
processing is necessary for compliance with a legal obligation to which the school is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the school;
processing is necessary for the purposes of the legitimate interests pursued by the school or by a third party.

The principal legal bases underlying the processing of personal data undertaken by the school development office are set out below.

Legitimate Interest This means using your information is necessary for the School's legitimate interests (you have the right to object at any time to this processing and it is not allowed if your interests and fundamental rights override our legitimate interests).
Specifically, the School has a legitimate interest in:

Publicising and promoting the School in effective ways. This may include using photographs of you at our school events in promotional material.
Raising funds to benefit school life, improve the School infrastructure and provide fee-support via bursaries and scholarships.
Maintaining relationships with alumnae and the school community, including fundraising activity.
Maximising opportunities for pupils past and present to benefit from the expertise of our wider community of supporters.
Enabling former pupils to keep in touch with their school friends and teachers, socialise and network professionally.
Confirming the identity of prospective donors and their background and donor due diligence.

Necessary for contract We may use your information to perform our obligations under a contract with you, for example, to send you tickets for an event you wish to attend.
Legal obligation We may use your information in order to comply with a legal obligation, for example, to comply with Revenue rules and ensure that any large donations are legally given.
Performance of a task carried out in the public interest   For example when we use your information to facilitate the efficient operation of the School.
Consent   We may ask for your consent to use your information in certain ways as an alternative to relying on any of the bases above. For example, we may ask for your consent before taking or using some photographs and videos if the photograph or video is more intrusive and we cannot rely on legitimate interests. (You can revoke this consent at any time. Please speak to the school if you would like to withdraw any consent given.)

Updating your consent preferences

If you have an online profile on this website you can update your consent options by logging-in and clicking on “My Settings” in your profile. Scroll down to find your ‘Consent options’ where you will see a list of consents and the options “opt-in”, “opt-out” and “unspecified”.

Via ‘My Settings’ you can also choose to hide your profile from Google, limit access to your profile so that it’s only viewable to your connections and adjust some of the automatic notifications that you receive from this website. Please note that your name (but not full profile) may appear in various places around the community website, such as a ‘Recent Joiners’ box and in ‘Search’ results irrespective of the privacy settings you have selected.

If we are using consent as our legal basis for processing your data, we must have an explicit “opt-in” from you for this specific type of processing.

If we are using legitimate interests as our legal basis for processing your data, we will process your data responsibly in a way that you would reasonably expect, and you can opt-out at any stage.

If you click ‘unsubscribe’ at the bottom of one of our emails sent you will be automatically opted-out of these types of email communications in the future.

If you want to contact us about your consent preferences please contact Caroline O Brien at cob@holychildkilliney.ie.

How we keep your information safe

We understand the importance of keeping your personal information secure and take appropriate steps to safeguard it.

Your data is stored on a dedicated, secure cloud server hosted by Amazon Web Services (AWS) in the EU and managed by our website provider, ToucanTech. Industry standard firewalls, anti-virus, encryption and back-up methods are in place, as well as strict data handling protocols.

We always ensure only authorised persons have access to your information, which means only our approved employees and contractors, and that everyone who has access is appropriately trained in data management.

If you have an online profile for this website you are responsible for keeping your login details (email and password) confidential and we ask that you do not share your password with anyone.

No data transmission over the internet can be guaranteed to be completely secure. So, whilst we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.

Who has access to your information?

Third parties who provide services for us, for example [insert details such as, collecting or processing data and sending mailings]. We select our third-party service providers with care. We provide these third parties with the information that is necessary to provide the service and we will have an agreement in place that requires them to operate with the same care over data protection as we do

Third parties if we run an event in conjunction with them. We will let you know how your data is used when you register for any event

Web hosting, email hosting, analytics and search engine providers that enable us to run our community database and improve our website and its use

Third parties in connection with restructuring or reorganisation of our operations, for example if we merge with another business. In such event, we will take steps to ensure your privacy rights will be protected by the third party

Who has access to your data

For the most part, Personal Data collected by the School Development Office will remain within the School and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).
Under certain very limited circumstances we may need to share your data with other parties (see HCK’s Data Protection Policy for full details). In each case there will always be a legal basis underlying any such sharing.
For example, our accountants may access some personal data when they audit our accounts. Similarly the revenue commissioners may require some sharing of personal data when confirming the validity of charitable donations. Every data controller who requires access, however limited, to some of the personal data processed by the school is bound by the terms of the relevant data protection legislation.
We may share your data, if relevant, with the Holy Child Killiney Alumnae Association. The HCKAA will, with your consent, use your data for the purposes of maintaining your relationship with the school.
In other examples, some of the school’s processing may require support from specialist service providers. For example, the school may use remote IT back-up and restore services to maintain data security and integrity. We may also avail of third party services in:

To communicate by email – e.g. e –zines.
To use online payment systems to book and organise events and to make online donations.
Event management/marketing
To manage the Development Office activity by using a CRM database.
To use fundraising consultants and advisors.

In cases such as these, where we use specialist data processors, we will always prioritise your data privacy through for example, ensuring that the appropriate security guarantees have been provided and that there is a signed processing agreement in place.
In some limited circumstances, your information may be processed outside the European Union, for example where we store information on computer servers based overseas; or we communicate with you when you are overseas. Under EU law this third country transfer can only take place where there are privacy safeguards in place. For further details see the school’s Data Protection Policy.

Other than this, we will not share your information with other organisations without your consent.

Keeping your information up to date

Please would you let us know if your contact details change. Online members can update your details directly by logging-in to the website and clicking on ‘My Settings’ under your profile. You can also update your details by contacting us at mharrison@holychildkilliney.ie.

Cookies

Some information and data may be automatically collected through the use of cookies on this website. Cookies are small text files employed on the website to recognise repeat users and allow us to observe behaviour and compile aggregate data in order to improve the user-experience we provide for our website visitors.

The law states that we can store cookies on your machine if they are essential to the operation of the website, but that for all others we need your permission to do so.

The list below explains the cookies we use and why:

Cookie Description	Name	Purpose
Session Cookie	[Holychildkilliney]_Member_Code [Holychildkilliney]_PyroCMS	Used to remember you as you travel from page to page in a single session (without leaving the website) in order to provide a continuous and unified experience
Functional Cookie	[Holychildkilliney]_Identify	Used to remember your login details when you return to the website after previously logging out, by storing them in your browser. This cookie is turned off by default and is only activated when you select the ‘Remember Me’ check box during login.

Opting out of cookies

If you do not wish to receive cookies from us or any other website, you should be able to turn cookies off on your web browser: please follow your browser provider’s instruction in order to do so. Unfortunately, we cannot accept liability for any malfunctioning of your computer or its installed web browser as a result of any attempt to turn off cookies.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Use of aggregated data

Where data can be aggregated and anonymised, our website provider (ToucanTech) might use this for research purposes without restriction. For example, they may monitor traffic patterns, site usage, response rates and data trends to help make improvement to the website software. They are entitled to do this because the resulting data will not personal identify you and will therefore no longer constitute personal data for the purposes of data protection laws.

How long we keep your information for

We will hold your personal information for as long as it is necessary for the relevant activity. .

If you ask us to stop contacting you, we will keep a record of your contact details and limited information needed to ensure we comply with your request. If you ask us to remove your personal data from our database we will delete all the information we hold out apart from your name and the dates that you attended Holy Child Killiney and archive your record in our database.

Your rights

You have the right to request details of how we use your personal information through making a subject access request. Such requests have to be made in writing by contacting [details].

You also have the following rights:

to request rectification of information that is inaccurate or out of date;
to erasure of your information (the “right to be forgotten”);
to restrict the way in which we are dealing with and using your information;
to request that your information be provided to you in a format that is secure and suitable for re-use (the “right to portability”);
in relation to automated decision making and profiling.

All of these rights are subject to certain safeguards and limits or exemptions. To exercise any of these rights, you should contact Caroline O' Brien at the above address.

If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Irish Data Protection Commission. Contact details and other information can be found at their website www.GDPRandYOU.ie.

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This Policy was last updated in May 2019.