Supporters and Alumni Privacy Notice

The IOU needs to collect and process personal data in order to process your admission, respond to your queries, provide academic services, manage operations effectively, and meet regulatory and legal requirements. The IOU’s legal title is International Open University registered in The Gambia.

This document explains how we use the personal data of supporters and alumni. It includes information required by the General Data Protection Regulation (EU Regulation 2016/679) and related data protection legislation.

We have separate privacy notices for Enquirers and Website Users (Enquirers and Website Users Privacy Notice) and for Students (Students Privacy Notice).

Policy

1. The IOU is the data controller in relation to the processing activities described below. This means that the IOU decides why and how your personal information is processed.
2. Our legal basis for processing your personal information is that it is in the IOU’s legitimate interests of maintaining a relationship with you, and promoting our vision, mission and values. We will ask for your consent to contact you with certain kinds of communication.
3. This document applies to you if you have achieved a qualification with the IOU, are a member of our Alumni Association, are a supporter and volunteer or have been identified as a potential supporter of the IOU. It details:
   1. what kind of information the IOU collects about you when you become an alumnus, supporter, volunteer or are identified as a potential supporter
   2. How the IOU will use information we collect about you
   3. Whether the IOU will disclose your details to anyone else
   4. Security and retention of personal data
4. If you studied at the IOU and gained a qualification, we use some information from your student record to communicate with you, as a member of the IOU’s Alumni Association. This includes information such as your name, date of birth, contact details and educational history with the IOU. This information is copied across from your student record and used to create a record on the IOU’s alumni database. We keep records of your participation in academic programs and also use the data in numerical form for our statistical and marketing analysis.
5. Most of the information we hold comes directly from you – this includes data you may have given to the IOU when you were a student and subsequently, for example we add information about any contact we have with you, any donations you make to us, responses to alumni surveys etc. …
6. We also hold records on individuals who are not alumni of the IOU but who have been identified as being sympathetic to the mission of the IOU or have a known affinity to it. This includes supporters and volunteers who have become actively engaged with the IOU. The data we hold may include:
   1. Name, title, gender, date of birth
   2. Contact details (incl. postal address, email address, phone numbers)
   3. Education details (qualifications gained and qualification year, also past modules and module years)
   4. Communications sent to you by the IOU or received from you
   5. Donations to the IOU (if donating by Direct Debit or standing order your bank details). We do not store credit or debit card details.
   6. Other charitable or philanthropic activity relevant to the work of the IOU
   7. Legacy details
   8. Volunteering on behalf of the IOU (for example mentoring)
   9. Events you have attended (including meetings with IOU staff)
7. We utilise a variety of sources to augment, update and validate the information we hold on supporters, volunteers and alumni as well as to help us identify those likely to have an interest in the IOU. These include the internet search engine results and social media websites such as facebook, twitter and Instagram.
8. The IOU does not buy lists of individuals from third parties and does not share or sell personal data to others.
9. We use your information to communicate with you about the IOU. This includes invitations to events, news and updates from the IOU, fundraising materials and information about how you can continue to support the IOU.
10. The IOU uses your data to communicate alumni activities, to request support for fundraising programs and for the promotion of benefits and services for supporters and alumni. These can include invitation to events etc.
11. If you contact us with a question, comment, compliment or complaint then we will keep a record of this correspondence and any associated documents so that we have the information available in the event of a follow-­up, dispute or investigation.
12. If we make changes to our policies which may affect you, we will contact you to inform you of the changes.
13. We may use your personal data to invite you to become involved with us in raising funds and growing our supporter base. If you participate in an event that we have organised, we may ask you to provide information to make sure we can manage the event safely and efficiently.
14. Alumni and fundraising materials that we might share with you include information about our activities and their impact, our news, events and fundraising appeals, and other ways you can become involved with us. We will share this information and news and the alumni newsletter with you by email.
15. The IOU has a duty to make sure that it spends donations wisely, and that means doing research and analysis to inform its decisions. The IOU may carry out due diligence on potential donations.
16. The IOU wishes to send the most effective messages that it can in the most efficient way possible. In order to work out who to contact, what to say and when to get in touch, the IOU carries out the following activities -­ tracking emails to see which messages have the highest response rates an whether there are messages that resonate with particular groups of people. This is done by logging whether emails sent have been opened, deleted and interacted with (e.g. by clicking on links in the emails). Although the IOU only uses this information to look at general patterns, it is still personal data as it is linked to an email address; the IOU also analyses information such as locations and postcodes of supporters, and whether donations have been given regularly. This helps the IOU to tailor appropriate communications to alumni and supporters and to improve their experience as IOU supporters; the IOU undertakes research to help it identify people who may be able to support it with a larger gift; using information alumni have provided and and publicly available records such as land records; and the IOU may also collect information on supporters’ interests, e.g. hobbies or articles about them in newspapers or magazines.
17. The IOU uses this information to inform its approach and develop a clearer understanding of areas of affinity between the IOU and supporters and alumni. This helps the IOU tailor its communications, ensuring it is contacting potential supporters about fundraising opportunities which may be of interest to them.
18. When you make a donation or other payment to the IOU, we will use your payment and contact details, payment amount and date of payment, to process that payment and take any appropriate administrative action.
19. Your personal data may be shared with us by a third party to whom you have indicated that you wish to support the IOU and to whom you have given consent to do so. You should always check a third party’s data protection or privacy policy when you provide information to appreciate how they will process it.
20. We may disclose your information to third-­party service providers and agents for the purposes of providing services to us, or directly to you on our behalf. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
21. Generally, information you provide to us is stored on our secure servers or on our cloud ­based systems which are located in different regions in Europe and America.
22. If you are based in the European Economic Area (‘EEA’) and we transfer your data outside of the EEA, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as set out in this policy. These steps include imposing contractual obligations on the recipient of your personal data, or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection.
23. We believe that the bond we have with our volunteers, supporters and alumni is a potentially life-­long one. We therefore retain your data until such time as you request its removal. We will always maintain a record on our database containing at least your biographical and education details for statistical purposes and to ensure we do not inadvertently contact you in the future.
24. You have various rights regarding your personal data. For information about your rights or in order to exercise those rights, you may contact the Data Protection Officer whose details appear below.
    You have the right to:
    • access the personal information we hold about you -­ a “subject access request” enables you to receive a copy of your data and to check that we are lawfully processing it.
    • correct inaccuracies in the information we hold about you -­ enables you to ask us to correct any incomplete or inaccurate information we hold, though we may verify the accuracy of the new data you provide to us.
    • request erasure of your personal data – enables you to ask us to delete or remove your data under certain circumstances, for example, if you consider that there is no good reason for us continuing to process it, where we may have processed your information unlawfully or where we are required to erase your personal information to comply with the law. We may not always be able to comply with your request of erasure for specific reasons of which you will duly be informed.
    • request that we stop sending marketing communications to you. You may also have the right to
    • restrict the processing of your personal data in certain ways – you may request that we suspend the processing of your personal data, firstly, if you want us to establish the data’s accuracy; secondly, where our use of the data is unlawful but you do not want us to delete it; thirdly, 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; or fourthly, you have objected to our use of your data but we need to verify whether we have overriding legitimate reasons to use it.
    • obtain a copy of your personal data in a filing system
    • object to certain processing of your personal data by us – where we (or a third party) are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as feel it impacts on your rights and freedoms. In certain situations, we may assert that we have compelling legitimate grounds to process your data which override your rights and freedoms.
    • request a transfer of your data to a third party – we will provide to you, or a third party on your behalf, your personal information in a structured, commonly used, machine readable format. This right only applies to automated data which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • withdraw consent where we are relying on consent to process your personal data – but this will not affect the lawfulness of processing carried out before you withdraw consent. If you withdraw your consent, we may not be able to provide certain services or products to you. Should this happen, we will advise you at the time you withdraw your consent.
    • request a review by a human of any automated decision.

25. If you have any concerns about the way in which we have processed your personal data, you should consult your local supervisory or similar authority for more information. You can change your communication preferences by contacting the Data Protection Officer whose details appear below.
26. If you have any queries about this policy or about the way in which IOU collects or processes personal information, or requests to exercise your rights as a data subject, please contact IOU’s Data Protection Officer:
    Email: dataprotection.officer@iou.edu.gm
    Post: Data Protection Officer, Student Affairs Division.

This document will be updated from time to time in order to ensure that it complies with data protection legislation.