Privacy Policy

Last updated: July 2024

1. Introduction

1. 1 We, The British Friends of Harvard Business School (with 'we', 'our' or 'us' being interpreted accordingly) are committed to protecting your privacy and personal information. Personal information relating to you from which you can be identified that we collect or which you provide is called personal data ('Personal Data').

1. 2 This privacy policy ('Privacy Policy') tells you about the Personal Data we collect; how we handle or process such Personal Data and who we may share it with. This Privacy Policy also provides information on your legal rights in relation to your Personal Data.

2. Changes to this Privacy Policy

2.1 We may change this Privacy Policy from time to time—when we do we will inform you via our website or other means of contact such as email.

3. What Personal Data do we collect and use?

3.1 The Personal Data that we collect and use includes the following:

(a) name, postal address, email address and class year of each donor, along with confirmation of whether each donor is a UK tax payer;

(b) name, previous name, nationality, occupation date of birth, address and class year of trustees, along with information regarding other trusteeships and/or directorships held, and information collected during background checking;

(c) full details from each application – a British Friends of Harvard Business School Scholarship Award (including, name, postal address(es), email address, telephone number (s), citizenship and passport, demographic information, marital status, educational background, employment history and personal statements, salary details, financial resources and liabilities and demographic details.

(d) name and email address of each event attendee, along with records of events previously attended;

as well as any other Personal Data that you may provide to us from time to time.

4. How your Personal Data is collected

4.1 We collect Personal Data in various ways as follows:

(a) through your relationship and communications with us with us, for example, if you get in touch to discuss a possible donation, or to book a place at an event;

(b) through applications for the British Friends of Harvard Business School Scholarship Award; and

(c) from publicly accessible sources, for example, Companies House where required by law (for example, to perform background checks on trustees.

4.2 Please also note that in limited circumstances some of the Personal Data you supply and that we may process include what is known as 'special category' or 'sensitive' data about you if it is provided to us, for example, health information regarding allergies provided before you attend a dinner.

5. What we use your Personal Data for

Other than as stated above, we may use your Personal Data for one or more of the following purposes:

(a) to acknowledge receipt of donations;

(b) to keep records of donations, and adding names to alumni giving lists which are published online and in our annual dinner leaflets;

(c) to send annual dinner (or other event) invitations;

(d) to select British Friends of Harvard Business School Scholarship Award recipients, and inform the Harvard Business School about same;

(e) to administer scholarships and keep records of scholarships awarded;

(f) to conduct background checks on trustees;

(g) to claim Gift Aid on donations;

(h) to provide you with direct marketing communications about what we are doing as well as services and/or campaigns which may be of interest to you by email or phone. If required under applicable law, where we contact you by email, social media and/or any other electronic communication channels for direct marketing purposes, this will be subject to you providing your express consent. You can object or withdraw your consent to receive direct marketing from us at any time, by contacting us using the email address below;

(i) to enforce and/or defend any of our legal claims or rights; and/or

(j) for any other purpose required by applicable law, regulation, the order of any court or regulatory authority.

6. The lawful grounds on which we collect and process Personal Data

6.1 We process your Personal Data for the above purposes relying on one or more of the following lawful grounds:

(a) where you have freely provided your specific, informed and unambiguous consent for particular purposes;

(b) where it is necessary to perform a contract we have entered with you or to take steps at your request before entering into a contract;

(c) where we need to use your Personal Data for legitimate purposes relevant to us being able to process and record donations and Gift Aid claims, assess award applications, maintain records of our operations and activities, and promote our organisation and its events. We will always seek to pursue these legitimate interests in a way that does not unduly infringe on your other legal rights and freedoms and, in particular, your right of privacy;

(d) where we need to protect your vital interests or those of someone else (such as in a medical emergency); and/or

(e) where we need to collect, process or hold your Personal Data to comply with a legal obligation.

6.2 If we process 'special category' or 'sensitive' data as referred to under paragraph 4.2 we will only do this with your explicit consent; or, where needed to comply with applicable social security or social protection laws; or, to protect your vital interests (or those of someone else) in an emergency; or, where you have already publicised such information; or, where we need to use such sensitive data in connection with a legal claim that we have or may be subject to.

7. Our Legal Obligations regarding your Personal Data

7.1 We collect and process your Personal Data in accordance with applicable law. This includes, without limitation, the EU General Data Protection Regulation (2016/679) ('GDPR') and the UK Data Protection Act 2018 together with other applicable UK laws that regulate the collection, processing and privacy of your Personal Data such as any domestic law incorporating the GDPR into UK law (together, 'Data Protection Law').

8. Disclosing your Personal Data to third parties

8.1 We may need to disclose your Personal Data to certain third-party organisations who are handling that data only on our behalf and in accordance with our instructions under contract (called 'data processors') in the following circumstances:

(a) companies and/or organisations that act as our service providers (e.g. IT suppliers or data hosting companies) or professional advisers; and

(b) companies and/or organisations that assist us in running events (e.g. event venues).

8.2 We may also disclose your Personal Data to third parties who make their own determination as to how they process your Personal Data and for what purpose(s) (called 'data controllers'), such as:

(a) Harvard Business School.

The third-party data controllers external to us with whom we deal as described above will handle your Personal Data in accordance with their own chosen procedures and you should check the relevant privacy policies of these companies or organisations to understand how they may use your Personal Data. Since these controller organisations

are acting outside of our control, we have no responsibility for their data processing practices.

8.3 We may also disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

8.4 In all cases we always aim to ensure that your Personal Data is only used by third parties for lawful purposes and in compliance applicable Data Protection Law.

9. International Transfers

9.1 We may transfer your Personal Data to Harvard Business School in the United States of America, which is a territory outside the United Kingdom and the European Union whose laws are currently not considered to meet the same legal standards of protection for Personal Data as set out under Data Protection Law.

9.2 However, in order to safeguard your Personal Data, we only conduct such a transfer under a contract or another appropriate mechanism which is authorised under Data Protection Law. This is to make sure that your Personal Data is safeguarded in accordance with the same legal standards that apply to us in the United Kingdom.

10. How long we retain your Personal Data for

10.1 We only retain Personal Data identifying you for as long as you have a relationship with us; or as necessary to perform our obligations to you (or to enforce or defend contract claims); or as is required by applicable law.

10.2 We have a data retention policy that sets out the different periods we retain data for in respect of relevant purposes in accordance with our duties under Data Protection Law. The criteria we use for determining these retention periods is based on various legislative requirements; the purpose for which we hold data; and guidance issued by relevant regulatory authorities including but not limited to the UK Information Commissioner's Office (ICO).

10.3 Personal Data we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it.

11. Security that we use to protect Personal Data

11.1 We employ appropriate technical and organisational security measures to protect your Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

11.2 We also endeavour to take all reasonable steps to protect Personal Data from external threats such as malicious software or hacking. However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of all data sent to us (including Personal Data).

12. Your personal data rights

12.1 In accordance with your legal rights under applicable law, you have a 'subject access request' right under which can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to as well as

certain other information.

Usually, we will have a month to respond to such a subject access request. We reserve the right to verify your identity if you make such a subject access request and we may, in case of complex requests, require a further two months to respond. We may also charge for administrative time in dealing with any manifestly unreasonable or excessive requests for access. We may also require further information to locate the specific information you seek before we can respond in full and apply certain legal exemptions when responding to your request.

12.2 Under Data Protection Law you also have the following rights, which are exercisable by making a request to us in writing:

(a) that we correct Personal Data that we hold about you which is inaccurate or incomplete;

(b) that we erase your Personal Data without undue delay if we no longer need to hold or process it;

(c) to object to any automated processing (if applicable) that we carry out in relation to your Personal Data, for example if we conduct any automated credit scoring;

(d) to object to our use of your Personal Data for direct marketing;

(e) to object and/or to restrict the use of your Personal Data for purpose other than those set out above unless we have a legitimate reason for continuing to use it; or

(f) that we transfer Personal Data to another party where the Personal Data has been collected with your consent or is being used to perform contact with you and is being carries out by automated means.

12.3 All of these requests may be forwarded on to a third-party provider who is involved in the processing of your Personal Data on our behalf.

12.4 If you would like to exercise any of the rights set out above, please contact us at the address below.

12.5 If you make a request and are not satisfied with our response, or believe that we are illegally processing your Personal Data, you have the right to complain to the Information Commissioner's Office (ICO) – see https://ico.org.uk/.

13. Contact

If you have any queries regarding this Privacy Policy or wish to make a further request relating to how we use your Personal Data as described above, please contact:

Lenka Roper

BFHBS Administrator

Email: info@bfhbs.org