Your Privacy

Your Privacy2018-09-12T16:19:34+00:00

We may update these privacy notices so please check back to see changes. We will notify you of changes by positing a notice on our homepage and changing the ‘last updated’ date on the notice itself.

Sutton Trust privacy statements and related documents

Here you will find our privacy policies for various areas of our work. Click on the relevant tab for more details. To find out your rights, or to file a query or complaint, click here.

  1. What we collect

We only collect a minimal amount of personal information. This includes information you give when signing up to our newsletter (name, e-mail address, job title) or communicating with us. This also includes information about individuals who are (or are employed by) stakeholders, for example an MP, chief-executive of a not-for-profit organisation, journalist, or comparable individual. This information includes name, job title, organisation, and contact information (e-mail).

We collect this information through various means including:

  • yourself;
  • from our research into stakeholders with an interest in topics relevant to the Sutton Trust’s aims using public sources such as websites;
  • from our research into journalists using public sources such as websites;
  • recommendations from other stakeholders;
  • recommendations from staff members of the Sutton Trust;
  • business cards received at events
  1. Why we collect it
Our use of your personal information Our legal basis for processing your personal information
We use your personal information to send you our e-newsletter, which includes all our marketing communications such as our research programme, including details of recent reports or blogs; our events and activities; job opportunities. We will only contact you in this way if you have given us your consent to do so.  If you withdraw your consent for us to contact you with this information, we will no longer use your contact details in this way.
We use your personal information to organise events; to update stakeholders on relevant policy events and reports; to communicate with journalists on relevant news, events and reports. It is in our legitimate interest to inform stakeholders of the work we are doing. Stakeholders may find our reports/events informative and useful in shaping the discussion on these issues. Also at times we may want the input of stakeholders into the policy debate. If you are a stakeholder and you are receiving communications from us, but do not wish to do so anymore, then let us know at info@suttontrust.com and we will no longer contact you in this way.
We use your personal information where it is publicly available including party affiliation, individual interests (according to publicly available reports or from Hansard) and previous voting record to segment what information we send to stakeholders. This activity is in our legitimate interest so that we are only sending information to you that would be of interest.
We use your personal information to conduct research reports (i.e. using publicly available information on Members of Parliament). This activity is in our legitimate interest to conduct relevant and proper research to further our aim of improving social mobility. Some personal information will be provided to us by the individual strictly for research purposes on the basis of consent.
We use website usage data and user data (such as your IP address and details of your browser and device) to provide products and services; to enable certain website functions; to better understand how visitors use this website; and to present timely and relevant information to visitors. This activity is in our legitimate interest to help ensure the website operates properly.

Where we have a contractual relationship with you, we may process your personal information as necessary for the performance of that contract or prior to entering into it.

  1. What we do with your data

For our research, all data held internally is anonymised, apart from where the information on the individual is publicly available (i.e. Members of Parliament). When published, all results are anonymised and any personal information is retained internally.

Occasionally, where we partner with other organisations, we may share information with them (for example, if you register to attend an event being jointly organised by us and another charity). We’ll only share information when necessary and we will never share your contact information (e.g. email or telephone).

  1. Where we keep it

Your data will be retained and stored confidentially and processed in accordance with the Data Protection Act (1998) and General Data Protection Regulation (2018) principles.

Your data will be stored on The Sutton Trust’s shared drive. We are based in the UK and store our data within the EU.

We may use the following third-party service providers named below to process and store your data:

  • Mailchimp (The Rocket Science Group, LLC), which we use to manage email marketing subscriber lists and send emails to our subscribers. Read their privacy policy.
  • Google Analytics, which we use to measure the performance of this website. We do this to find out things such as the number of visitors to the various parts of the site. Search queries and results are also logged anonymously in Google Analytics to help us improve our website and search functionality. Read their privacy policy. You can opt-out of Google Analytics cookies altogether by opting-out of the browser add-on.
  • Automattic, Inc., whose WordPress software (and associated add-ons) we use to manage the content of this website. Read their privacy policy.

      5.  How long we keep it

The Trust will store information only for the purposes for which it was collected and continually review our retention periods to ensure that personal data is not stored unnecessarily.

Personal data associated with research will be stored for 10 years, unless it is still considered necessary for research purposes. For all our personal data we will perform an annual check to ensure that:

  • stakeholders are still working at the organisations and in relevant roles within those organisations to justify inclusion on our data-base;
  • media contacts are up to date and relevant;
  • personal data associated with research is up to date, and still needed for research purposes (for example we would retain information on individuals who still hold the prominent positions which our research examines, such as those who remain Members of Parliament, as this information would be vital for future analysis. However, if that individual is no longer an MP or a candidate for parliament, they would be deleted from our database).

If not, your personal information is deleted.

  1. Social Media

Our websites include social media features, such as the ‘Facebook Like’ button. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website.

We also maintain presences on social media platforms including Facebook, Twitter, LinkedIn and Instagram. We use a third-party provider, Buffer to manage our social media interactions. You can find more information on Buffer’s privacy policy.

Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

  1. Links to third-party websites

Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

We keep our privacy notice under regular review. This privacy notice was last updated on: 29 August 2018.

Sutton Trust programmes are run in partnership with universities and third sector organisations.

This means the information you provide on your application form will be stored by both The Sutton Trust and the delivery partner you take the programme with e.g. university, Fulbright. The delivery partner you apply to may share their own data privacy notice with you.

Throughout this policy we use language which can be defined as:

  1. Programmes: the Sutton Trust programme or activity that you have applied to for example, UK Summer School or Pathways to Law
  2. The Sutton Trust: references to ‘we’, ‘us’ or ‘our’ means the Sutton Trust of 9th Floor Millbank Tower, 21-24 Millbank, London SW1P 4QP. We are the data controller for the personal data relating to you that we collect and hold
  3. Delivery partner: delivery partners are organisations that are involved in running the programme for example a university, work experience provider or corporate partner
  4. Evaluation partner: an evaluation partner is an organisation or individual who the Trust contracts to evaluate the programme by looking at data including your application form and survey responses

1. What we collect

The Sutton Trust will be what is called the “Controller” of the personal information that you provide to us in your application form. This includes collecting your basic personal information and eligibility for our programmes. To see a full list of the data we hold please see “The data we hold” annex.

  1. Why we collect it

We collect and process your data under the legal basis of legitimate interests. We collect and process your data for the following purposes:

  1. process your application
  2. assess your eligibility for the programme, in line with the specified criteria
  3. allow delivery partners to contact you their decisions and your place on the programme
  4. to ensure we can provide adequate support on the programme for any medical or additional needs
  5. evaluate the programme’s effectiveness

For purpose five,

If you do not provide this data we will be unable to provide you with the opportunity for taking part in the programme.

  1. What we do with your data

All the information you provide will only be used for the delivery or evaluation of the programme unless you give us consent to contact you for other purposes.

What we do Data categories Legal basis
We use eligibility, outcome and impact data to produce reports to show who is on our programmes and the effect the programme has had. These reports will always be in aggregate form – we will not say anything in our reports that could identify you as an individual 4, 5, 6, 9, 10 Our legitimate interests are that the Sutton Trust needs to evidence the reach and effectiveness of its programmes to funders, donors and trustees. As a social mobility charity, The Trust also aims to demonstrate the impact of its programmes on social mobility over time
We will share your data with delivery partners, evaluation partners and with tracking services. We will have data sharing agreements in that confirm that those third parties with whom we share your personal information will process your information in compliance with all data protection laws 1, 4, 6 Our legitimate interests are to provide you with the opportunity to gain a place on the programme and ensure we can provide adequate support
We, our evaluation or delivery partners, will ask you to complete surveys and will link these to the data you provide in this application 1, 2, 4 Our legitimate interests are that the Sutton Trust needs to evidence the reach and effectiveness of its programmes to funders, donors and trustees. As a social mobility charity, The Trust also aims to demonstrate the impact of its programmes on social mobility over time
The Trust will send you information about additional opportunities with the Sutton Trust e.g. other programmes, financial bursaries and Trust updates 1, 2, 4 We will only contact you with this information if you provide us with explicit consent. You can withdraw consent at any time
The Trust will allow our delivery partners to contact you about additional opportunities e.g. other programmes 1, 2, 4 We will only contact you with this information if you provide us with explicit consent. You can withdraw consent at any time
The Trust can share your name, date of birth, postcode, school and contact details with university partners for admissions purposes. This includes seeing if you have applied to that university to highlight your eligibility for contextual offers and bursaries. Universities may then contact you to give you further information. Please tick if you would like this opportunity 1, 2, 4, 5, 6 We will only contact you with this information if you provide us with explicit consent. You can withdraw consent at any time

3a. Delivery partners

To deliver the programme, The Trust and delivery partner will share your full application e.g. we will share with the university you have applied to or vice versa. We will also share your contact details and access needs with other delivery partners to deliver the programme. i.e. if your programme includes a work experience placement, we will share your information with the placement provider

Our delivery partners may assess your eligibility for the programme using their own systems and may share your data with funding and research bodies to demonstrate the impact and reach of the programme. They are responsible for compliance in storing and processing your data once The Trust has shared it as they also become a “controller”. They may be in touch to share their own procedures with you.

3b. Evaluation partners

The Trust will share your data with our evaluation partners so they can evaluate the effectiveness of the programme. This will include:

  • The programme criteria that you meet e.g. free school meal status, school performance, first generation, in care status
  • Responses to surveys
  • Name*
  • Date of birth*
  • Postcode*

*This data will only be shared if it is needed to match your application to your survey responses, this will be in instances where you fill in a paper survey that needs to be matched to your application record. We will anonymise data sets, wherever possible.

Our evaluation partners will be under contract as a data “Processor”, meaning that they cannot use your data for their own purposes. They are appointed each year and will vary depending on the programme. To see a list of the evaluation partners the Trust currently works with please click here (have link to webpage)

3c. Impact data

The Trust will look at where you go to university and what jobs you do in the future. We do this so that we can measure the impact that our programmes have on participants and ensure the programme is meeting its aims of increasing access to selective universities and careers.

Impact data will be collected by the Higher Education Access Tracker (HEAT) or our evaluation partners and we will share the following information to access the data sets:

  • Name
  • Date of birth
  • Postcode
  • Programme attended
  • The programme criteria that you meet e.g. free school meal status, school performance, first generation, in care status

To see a list of the data sets the Trust may access, please see the annex at the bottom of this statement.

  1. Where we keep it

4a. Your data will be retained, stored confidentially and processed in accordance with the Data Protection Act (1998) and General Data Protection Regulation (2018) principles.

We take the security of your data very seriously and ensure appropriate technical and organisational measures are in place to protect it against unauthorised or unlawful processing, and against accidental loss, destruction or damage. Your data will at a minimum always be password protected and the number of staff who can access this will be restricted to those for whom access is strictly necessary for the relevant processing.

4b.  Third party IT service providers

We store your data on a CRM system called Salesforce and the Trust’s shared drive. IT providers will have access to personal information stored on these systems. IT providers will be under contract as a data “Processor”, meaning that they cannot use your data for their own purposes.

We are based in the UK and store our data within the EU. Some organisations which provide services to us may transfer personal data outside of the EU, but we will only allow them to do if your data is adequately protected. For example, Survey Monkey and Form Assembly who host our online surveys are US based companies. We have processing agreements in place with these organisations to ensure your data is adequately protected.

  1. How long we keep it

The Trust will store your full application for one academic year following the completion of the programme to respond to queries that may arise during this period. Following this, The Trust will delete your application but will store the information needed to track your education outcomes, this includes your name, date of birth, school, postcode and contact details to send surveys. We will also keep information on your eligibility for the programme. This data will then be stored based on the two categories below:

5a. Successful applicants

If you gain a place on our programme, we will retain your name, date of birth, programme attended and educational outcomes under legitimate interests for lifelong alumni relations, please see the alumni privacy policy here. If you choose to stay on our alumni network, we will retain your contact information for these purposes.

5b. Unsuccessful applicants

If you did not gain a place on our programme, we will delete all identifiable information we store after collection of your impact data and will retain an anonymised version of your eligibility for the programme and educational outcomes until we no longer have a legal basis to do so.

We keep our privacy notice under regular review. This privacy notice was last updated on: 12 September 2018.

Annex – The data we hold

  Category Source Specific data held
1 Basic personal details Application form Name, date of birth, gender
2 Contact details Application form Email address(es), physical addresses, phone number(s)
3 Special categories of data Application form Ethnicity, disability, medical history, in care status, special educational needs
4 The Sutton Trust programme Application form Programme applied to, course applied to
5 Education data Application form School, academic performance and academic interests
6 Eligibility for our programmes Application form School, postcode, first generation status, Free School Meal status, in care status
7 Parental information Application form Contact details, education data, employment data, eligibility for benefits
8 Teacher information Application form Name, job title, work email, reference
9 Outcome data Surveys Responses to survey questions, attitudes towards higher education, feedback on the programme
10 Impact data Education data sets University enrolment, course enrolment, degree classification, career choice

Higher Education Access Tracker (HEAT), National Foundation for Educational Research (NFER), The Bridge Group, Education Research and Analysis (ERA), Centre for Evaluation and Monitoring (CEM)

Department of Education attainment data held on the National Pupil Database, UCAS records and/or HESA student records, Destination of Leavers from Higher Education survey

Higher Education Funding Council for England (HEFCE), Department for Education, Higher Education Statistics Agency (HESA), University and Colleges Admissions Service (UCAS), Higher Education Access Tracker (HEAT), East Midlands Widening Participation Research and Evaluation Partnership (EMWPREP), Connexions, or the National Data Service.

Brightside
Causeway Education
Durham University
Edinburgh University
Hull York Medical School
Imperial College London
King’s College London
London School of Economics
Nottingham Trent University
Queen Mary
Royal Veterinary College
University College London
University of Bristol
University of Cambridge
University of Exeter
University of Leeds
University of Leicester
University of Liverpool
University of Manchester
University of Nottingham
University of Oxford
University of Roehampton
University of St Andrew’s
University of York
US-UK Fulbright Commission
Warwick University

Sutton Trust alumni programme privacy notice

  1. Purpose of this statement

As an alumnus of the Sutton Trust, you are important to us. We value our relationship with you and would like to send you relevant communications, offering beneficial services, thanking you for your support, sharing future opportunities for providing support which may be of interest to you, and measuring the impact of the programmes we run.

We are committed to protecting your personal information and being transparent about what we do with it. This Privacy Notice sets out the information that we collect about you in respect of our core and alumni programmes, why and how we use that information in relation to our core and alumni activities, the legal basis upon which we process that information, your rights regarding that information and how you can update it.

In this policy, references to ‘we’, ‘us’ or ‘our’ means the Sutton Trust of 9th Floor Millbank Tower, 21-24 Millbank, London SW1P 4QP. We are the data controller for the personal data relating to you that we collect and hold.

  1. What personal data we collect and hold about you and why

We collect, use and hold a range of data about you, and we refer to this as “personal information” or “personal data” throughout this policy. Annexe A details the categories of personal information that we collect about you, which includes data like your personal and contact details, communications and volunteering preferences, your Sutton Trust programme, your suitability for our programmes and your attainment, your professional details, your relationship to other alumni and your current and potential support for the Sutton Trust.

In this policy, all of the personal information described above is also referred to as “Alumni Personal Information“, and is distinct from the cookie information that we collect about you, referred to below:

  • Cookie data: We collect information about how you use and navigate our website, via the use of cookies. For more information about the cookies we use, please see section 9 of this policy (below).
  1. How we obtain your data

Most of the data we hold is from the information you provided to the Sutton Trust when you registered for your programme, or is information you provided when you created or edited your alumni profile (through our online platform, “Sutton Trust Alumni” or our previous digital software). You may also have provided information over email, post, over the phone, or in conversation. Where relevant and feasible, and in a manner appropriate to the way in which the data is collected, at the point when Alumni Users update their data outside of Sutton Trust Alumni, for example over email or other digital means, over the phone, or in person, the following points will be made: that the Sutton Trust is collecting your personal information; the reasons for our collection of your data; your rights in relation to our collection of data ; and the location of our full privacy statement.

We sometimes obtain information about you from publicly available sources. For example, social networking sites, company websites, publications like Who’s Who, dedicated business websites (e.g. Companies House) or publications and articles in the media (e.g. Queen’s Honours List), and may use trusted external companies to do this on our behalf.

If you agree to us sharing your personal information with our alumni programme delivery partners, they will share additional personal information with us about your engagement with them. We have provided more information about the data that we share with, and receive from, our partners in section 5 below.

We also analyse personal data we collect about you to create additional information about you. For example, to assess your level of engagement, your likelihood and capacity to donate or volunteer and potential areas of interest for future communications. We use this information to help us to improve the alumni relations programme, including our fundraising programme.

  1. How we store and use your information

The personal information you provide to the Sutton Trust, including to Sutton Trust Alumni, and via other means described in section 3 above, will be used in the ways described below.

Our use of your personal information The categories of data we use Our legal basis for processing your personal information
We use the categories of your Alumni Personal Information listed to contact you with information about alumni events, news, volunteering opportunities, fundraising campaigns, and other opportunities. Some of the content we include in this marketing will be from our partners. We will occasionally use your background information to send targeted messages to you – for example based on your interests or where you live.
  • Personal details
  • Contact details and communications preferences
  • Your Sutton Trust programme
  • Your suitability for our programmes
  • Professional details
  • Volunteering preferences
  • Your support for the Sutton Trust
  • Your engagement with the Sutton Trust and our programme partners
  • How you could support us in the future
We will only contact you in this way if you have given us your consent to do so.  If you withdraw your consent for us to contact you with this information, we will no longer use your contact details in this way.
We use the categories of your Alumni Personal Information listed to design and deliver the network and services which make up the alumni relations programme (events, news, volunteering opportunities, messages from our partners, other opportunities). For example we may use your Alumni Personal Information to analyse the feasibility of holding events in a specific location by looking at your current city; or we might use your Alumni Personal Information to improve our alumni volunteering programme by sending targeted messages based on your previous support for us.
  • Contact details and communication preferences
  • Your Sutton Trust programme
  • Your suitability for our programmes
  • Professional details
  • Volunteering preferences
  • Your support for the Sutton Trust
  • Your engagement with the Sutton Trust and our programme partners
  • How you could support us in the future
We are using your Alumni Data in this way because it is in our legitimate interest. We need to use this information to allow us to design and deliver the programme to suit the needs of the Trust’s alumni community, and to build greater engagement with our volunteering and fundraising opportunities. If you no longer wish to engage with our alumni programme, however, we will not process your information in connection with this purpose.
We use the categories of your Alumni Personal Information listed to give you access the services which make up the alumni relations programme (events, news, volunteering opportunities, other opportunities).
  • Personal details
  • Contact details and communication preferences
  • Your Sutton Trust programme
  • Professional details
  • Volunteering preferences
  • Your engagement with the Sutton Trust and our programme partners
In order for you to events, volunteer, receive relevant messages related to the delivery of these services (e.g. event booking confirmations, correspondence related to volunteering opportunities you sign up for), be informed of opportunities or participate in our alumni fundraising programme, we need to use your Alumni Personal Information. We are using this information under the basis of the contract that is enacted in order for you to use our services.
We use the categories of your Alumni Personal Information listed to enable you to access and utilise Sutton Trust Alumni.
  • Personal details
  • Contact details and communication preferences
  • Your Sutton Trust programme
  • Your suitability for our programmes
  • Professional details
  • Volunteering preferences
  • Relationships
  • Your support for the Sutton Trust
  • Your engagement with the Sutton Trust and our programme partners
  • How you could support us in the future
In order for you to activate your Sutton Trust Alumni account, receive relevant messages, update your profile, and receive relevant messages related to your preferences and interests, we need to use your Alumni Personal Information. We are using this information under the basis of the contract that is enacted in order for you to use our services.
We use the categories of your Alumni Personal Information listed to develop, deliver and evaluate our fundraising programme.  This mainly involves our smaller regular giving campaigns. It also includes our work to identify donors who could make more substantial gifts. We will assess the feasibility that you may be able to make substantial gifts by assessing details such as your postcode, job title, and information from publicly available sources. This helps to ensure that communications and approaches are relevant and timely, it allows us to target our resources effectively, and it provides an improved experience for our supporters. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would, so that we can improve social mobility.
  • Personal details
  • Contact details and communication preferences
  • Your Sutton Trust programme
  • Professional details
  • How you could support us in the future
We are using your Alumni Data in this way because it is in our legitimate interest. We need to use this information to allow us to design and deliver a fundraising programme, so that we can continue to work to improve social mobility in the United Kingdom. We also need to be able to evaluate our fundraising programmes using your data. If you no longer wish to engage with our fundraising programme, we will not process your information in connection with this purpose.
We use the categories of your Alumni Personal Information listed to evaluate and improve the Sutton Trust’s core and alumni relations programmes.
  • Personal details
  • Contact details and communication preferences
  • Your Sutton Trust programme
  • Professional details
  • Volunteering preferences
  • Your engagement with the Sutton Trust and our programme partners
This activity is in our legitimate interest in order to improve the effectiveness of our programmes to funders, donors and trustees. As a social mobility charity, The Trust also aims to demonstrate the impact of its programmes on social mobility over time.
We also use your cookie data to analyse and improve the functionality of our website. This activity is in our legitimate interest to help ensure the website operates properly in order to help our programme to be effective in meeting its aims

5. Sharing your data

5a. Delivery partners
To deliver your programme, The Trust will have shared your full application with the university you applied to. We will have also shared your contact details and access needs with other delivery partners to deliver the programme. i.e. a work experience placement provider.

We also work with select partners to deliver parts of the alumni relations programme. If you choose to interact with these partners and give your (separate and additional) consent for us to do so, some of your personal information will be shared with those partners. This will include:

  • Your name
  • Your email address
  • Your current address
  • Any education history you have shared with us (degree, university, subject)

We do this in order to make the process of signing up for their services easier. In addition, our partners will tell us about your engagement with the opportunities and services they offer. This could include your attendance at events, the type of content you are interested in, or jobs you have applied for.

These partners will assess your eligibility for the programmes they run using their own systems. They will ask you for additional data, and are separately responsible for compliance in storing and processing the data The Trust has shared with them, in addition to any additional data you supply to them. They will be in touch to share their own procedures with you. If you have consented to us sharing your personal information with our delivery partners, and you subsequently change your mind or would like to exercise any of your rights in relation to the personal information that they hold about you, you will need to contact them to do so.

The partners we are currently working with are included in Annex B.

5b. Sutton Trust programmes partners

The Trust will share your data with our evaluation partners so they can evaluate the effectiveness of the programme.

As part of the alumni relations volunteering programme, some individuals who work for the partners who deliver our core programmes (for instance our Summer Schools) will also have accounts on Sutton Trust Alumni. This group of partners will contact you on the Sutton Trust Alumni portal regarding specific opportunities should you indicate that you are interested in hearing from them, either as part of the process of signing up to Sutton Trust Alumni, by making changes to your personal profile, or by indicating by email, phone, or in conversation with them that you would be interested in those opportunities.

Our partners will assess your eligibility for the programmes they run using their own systems. They are responsible for compliance in storing and processing your personal information, and they will be in touch to share their own procedures with you.

The partners we are currently working with are included in Annex B.

5c. Evaluation partners

The Trust will share your data with our evaluation partners so they can evaluate the effectiveness of the alumni relations programme, and the Sutton Trust’s core programmes (the programme to which you originally applied, for example a Summer School). Our evaluation partners are appointed each year and will vary depending on the programme. A list of the evaluation partners the Trust currently works with are included in Annex B.

We, or our partners, will ask you to complete surveys and will link these to the data you provide to us on Sutton Trust Alumni. We will also link the data you provide to additional educational data sets to evaluate your future educational and career outcomes. This will include looking at where you go to university and what jobs you do in future. We do this so that we can measure the impact that our programmes have on participants and ensure the programme is meeting its aims of increasing access to selective universities and careers.

We will not say anything in our reports that could identify you and will not use your data in a way that would affect you individually. We have data sharing agreements in place to ensure that your data is protected and partner organisations will adequately protect your data. The current data sets we will link to are included in Annex B.

5d. Tracking

The Trust looks at where you go to university and what jobs you do in the future. We do this so that we can measure the impact that our programmes have on participants and ensure the programme is meeting its aims of increasing access to selective universities and careers. Tracking will be undertaken by the Higher Education Access Tracker (HEAT) and we will share the following information to access the data sets:

  • Name
  • Date of birth
  • Postcode

A full list of the data sets the Trust may access are available in the Annex.

5e. Other users of the Sutton Trust Alumni platform

Sutton Trust Alumni is designed to foster connections between alumni of the Sutton Trust’s programmes. As such, many of the Alumni Personal Information you supply will be displayed to other users of the platform, including our partners who have access to the platform, as mentioned earlier. You have control over what information you would like to be shared and you can update this at any time by updating your personal profile (called ‘My Profile’), or by getting in touch with us.

5f. Third party IT service providers

We use a third-party IT service provider, Hivebrite to host and maintain the Sutton Trust Alumni portal and a CRM system called Salesforce. They will have access to personal information stored on Sutton Trust Alumni in their role as our IT service provider, but are not permitted to use your personal information for their own purposes, other than measuring the effectiveness of their services, and must only process your personal information in accordance with our instructions. Some of our third-party providers also utilise the services of other parties – for example Hivebrite uses Google analytics to track displays of traffic on the site. We require all third parties and their partners to respect the security of your personal data and to treat it in accordance with the law.

We are based in the UK and store our data within the EU. Some organisations which provide services to us may transfer personal data outside of the EU, but we will only allow them to do if your data is adequately protected. For example, Survey Monkey and Form Assembly who host our online surveys are US based companies. We have processing agreements in place with these organisations to ensure your data is adequately protected.

  1. Storing and deleting your data

We hope that your relationship with the Trust will be a lifelong one, and in recognition of the lifelong nature of your relationship with the Trust, we will store and use your Alumni Personal Information for as long as you remain an alumnus of the Sutton Trust and we continue to run our alumni programme, or until we no longer have a basis upon which we can legally store or use your information (see section 2 for more information about the bases upon which we use your personal information).

You have certain rights in relation to your personal information, including the right to ask us to stop using information about you.  There is more information about your rights in section 10 of this policy (below).  If you no longer wish to be a part of the Sutton Trust alumni programme, or a member of Sutton Trust Alumni, please contact us via the details provided below.

Please note that the personal information we collect in relation to Sutton Trust Alumni is processed differently to how your student application data is processed. As indicated in the Sutton Trust’s student privacy statement, some of that data will be retained and processed by the Sutton Trust under the legal basis of such processing being in Sutton Trust’s legitimate interests. Please see the student privacy statement for information about how personal data collected in relation to your student application is processed by us. This statement is accessible at https://www.suttontrust.com/alumni/alumni-your-privacy/

The data we collect about you via our cookies is retained in accordance with our Cookie Policy

  1. How we keep your personal information up-to-date

The Sutton Trust has a legal obligation under data protection legislation to keep the personal information it collects accurate and up-to-date. We keep your information accurate as follows:

  • By giving you the opportunity at any time to contact us to correct or change your information;
  • By using information publicly available to us;
  • If you contact our team we might ask you to confirm certain details;
  • When we receive undelivered mail or email.
  1. How we protect your personal information

We take the security of your data very seriously and ensure appropriate technical and organisational measures are in place to protect it against unauthorised or unlawful processing, and against accidental loss, destruction or damage. Alumni Data will at a minimum always be password protected and the number of staff who can access Alumni Data should be restricted to those for whom access is strictly necessary for the relevant processing.

  1. Cookies

We collect information about your visits to Sutton Trust Alumni and the Sutton Trust website using cookies (the latter is anonymised). The information is invaluable to us to improve our website and ensure you are shown relevant content. Due to the way in which the site is built, you cannot turn off cookies. By signing up to the site, you are agreeing to our use of cookies. More information about how we use cookies on the Sutton Trust website and how you can prevent this can be found in our Cookie Policy.

  1. Your rights

You have certain rights in relation to your personal information. You have the right to request that we:

  • provide access to any personal information which we hold about you;
  • update any of your personal information which is out of date or incorrect;
  • delete any personal information which we hold about you;
  • restrict the way that we process your personal information (including the right to prevent us making automated decisions using your personal information, and the right to request that we stop processing your information for marketing purposes);
  • provide your personal information to a third party provider of services;
  • provide you with a copy of any personal information which we hold about you; or
  • consider any valid objections which you have to our use of your personal information.

We will consider all such requests and will try to respond to your request within 5 working days (and in any event within any time period required by law). Please note, however, that certain personal information will be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any

If you would like to exercise any of your rights in relation to your personal information, please email or write to us using the contact details in this policy. We do not apply a charge for providing you with your personal information or responding to your requests.

If we do hold information about you we will:

  • give you a description of it.
  • tell you why we are holding it.
  • tell you who it could be shared with.
  • let you have a concise and clear copy of the information.

We want to make sure that your personal information is accurate and up to date and we will be happy to correct or remove information you think is inaccurate.

If you have any concerns about the processing or use of data for these purposes or would like a copy of the data you have supplied directly to us, requests should be made in writing to info@suttontrust.com.

If you decide in the future that you no longer want your information to be used in any evaluation, please contact the Sutton Trust by e-mailing info@suttontrust.com or phoning 020 7802 1660.

If you have any complaints about the way your data has been handled you can contact the supervisory authority in the UK, the Information Commissioner’s Office, on 0303 123 1113. They are open Monday to Friday between 9am and 5pm.

  1. Changes to legislation

If our practices change, or there are changes to the law, we may need to amend or update this privacy policy. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

  1. Terms of Use

Your use of Sutton Trust Alumni is subject to the Terms of Use which we expect all users to abide by, and which directly inform our approach to content moderation. These are outlined separately below.

We keep our privacy notice under regular review. This privacy notice was last updated on: 18 May 2018.

Annex A

The personal information we collect and hold about you includes:

  Category Specific data held
1 Personal details Your name, date of birth
2 Contact details and communication preferences Your email address(es), physical addresses, LinkedIn and Facebook URL, phone number(s), and how you have indicated you would like to receive updates from us
3 Your Sutton Trust programme The programme itself (e.g. ‘Summer School’), the partner institution (e.g. the University of Bristol), and the year in which you did your programme
4 Your attainment How you performed on your Sutton Trust programme, your performance at university, your graduate destination
5 Your suitability for our programmes Your school, postcode, first generation status, and whether you were on Free School Meals or in care when you participated in your Sutton Trust programme
6 Professional details Where you work or have worked, the positions you have held, the industries you have worked in, the skills you have gained, and when you started or ended working in those roles
7 Volunteering preferences Which volunteering roles you have indicated you are interested in
8 Relationships Your relationships to other alumni, supporters and friends
9 Your support for the Sutton Trust Your past donations and the details of any volunteering roles you have had;
10 Your engagement with the Sutton Trust and our programme partners Your event attendance, your direct communications with us, your engagement with our communications, your use of Sutton Trust Alumni – for example the groups or events you join, or when you message other users
11 How you could support us in the future Our view of your likelihood and capacity to donate or volunteer in the future.


Annex B

Current delivery partners

Bright Network

Current programme partners

Fulbright Commission, current university partners

Evaluation partners

Higher Education Access Tracker (HEAT), National Foundation for Educational Research (NFER), The Bridge Group, Education Research and Analysis (ERA), Centre for Evaluation and Monitoring (CEM)

Data sets we link to

Department of Education attainment data held on the National Pupil Database, UCAS records and/or HESA student records, Destination of Leavers from Higher Education survey

Funding bodies that universities may report to:

Higher Education Funding Council for England (HEFCE), Department for Education, Higher Education Statistics Agency (HESA), University and Colleges Admissions Service (UCAS), Higher Education Access Tracker (HEAT), East Midlands Widening Participation Research and Evaluation Partnership (EMWPREP), Connexions, or the National Data Service.

Please review these terms of use (“Terms of Use”) carefully prior to using our Sutton Trust Alumni platform. 

These Terms of Use are effective as of 14 May 2018.

What is in these Terms of Use?

These Terms of Use set out the rules for using our platform, Sutton Trust Alumni, (the “Network”). The links below will take you to specific information on each section:

  1. By using the Network you accept these Terms of Use. 1
  2. Who we are and how to contact us. 2
  3. Other terms that apply to you. 2
  4. Changes to these terms. 2
  5. Changes to the Network. 2
  6. Your user account on the Network. 2
  7. Your use of our Content on the Network. 
  8. User Content on the Network. 3
  9. Prohibited uses of the Network. 4
  10. Reporting prohibited conduct or User Content. 4
  11. Privacy and Confidentiality. 5
  12. Our liability to you. 5
  13. Account Termination Policy. 6
  14. Links to Other Networks. 6
  15. Your use of our names and trade marks. 6
  16. Governing Law. 6
  17. Severability; Entire Agreement. 7
  1. By using the Network you accept these Terms of Use

By accessing or using Sutton Trust Alumni (the “Network”), or by logging into the site with your allocated User ID, you agree to be bound by these Terms of Use.

Please review these Terms of Use carefully prior to using the Network.  If you do not agree with these Terms of Use, please do not use the Network.

The Network comprises a suite of online services provided by the Sutton Trust, including but not limited to:

  • A directory
  • Events
  • Groups
  • Volunteering opportunities

These Terms of Use govern your use of each component of the Network.

You must be at least 18 years to use the Network. By using the Network, you acknowledge and agree that you are able to enter into and comply with these Terms of Use.

  1. Who we are and how to contact us

The Network is owned and operated by the Sutton Trust (“We” or “Us“). We are a charity registered in England and Wales under charity number 1146244 and have our registered office at The Sutton Trust, Millbank Tower, 21-24 Millbank, London, SW1P 4QP.

We are registered with and regulated by the Charity Commission.

To contact us, please email info@suttontrust.com, or  telephone our customer service line on +44 (0207) 802 1660.

The Sutton Trust may contact you by email in relation to your participation, especially where an issue comes up in relation to these Terms of Use. Any advice we give/request we make should be adhered to, as we are responsible for enforcing the community standards and creating a constructive environment for everyone who is a member of the Network.

  1. Other terms that apply to you

These terms of use refer to the following additional terms, which also apply to your use of our site:

  1. Changes to these terms

Please note that these Terms of Use are subject to change from time to time. Any changes will be posted to this page. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on [DATE].

Your use of this Network or any Network Content after any changes have been made will constitute your agreement to the modified Terms of Use.

  1. Changes to the Network

We may update and change the Network from time to time to reflect changes to our users’ needs and our priorities, and to help ensure that the Network remains relevant and useful to our users. We will try to give you reasonable notice of any major changes.

However, the Network is made available free of charge and We do not guarantee that our Network, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the Network for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

  1. Your user account on the Network

You agree to provide accurate and complete information when creating or updating your account.  You are solely responsible for the activity that occurs on your user account, and you must keep your account password secure.  You agree to notify us immediately at info@suttontrust.com of any unauthorized use of your account or other breach of security.  You may not use another’s account without permission.

User accounts may not be shared, transferred, or sold to other parties, nor are they to be used by or made available to any person or entity except the registered user.

We may terminate your account if you violate any provision of these Terms of Use or fail to comply with requests concerning your account.

Your use of our Content on the Network.

a) The Network and any data, text, files, information, usernames, images, graphics, photos, profiles, audio and video clips, sounds, works of authorship, applications, links, and other content or materials (collectively, the “Network Content”) belong to Sutton Trust and are protected by intellectual property laws. As between you and the Sutton Trust, the Sutton Trust owns all rights in the Network and the Network Content.

b)You may use the Network and the Network Content only in the manner and for the purposes specified in these Terms of Use. Except as specifically permitted by these Terms of Use, you may not modify, transmit, produce, distribute, display, sell, license, broadcast, or otherwise make available in any form or by any means any part of the Network or the Network Content without our express written permission.

c) The Network Content is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the Network Content. Although we make reasonable efforts to update the information on the Network, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.

8. User Content on the Network

a) You retain ownership of all of your rights in any content created, posted, or shared by you, on or through the Network and any personal data, (the “User Content”). The Sutton Trust does not claim ownership of your User Content.

b) By uploading User Content to the Network, you agree and confirm that: (i) you own your User Content; (ii) the posting and use of your User Content on or through the Network will not infringe on the rights of any third party; (iii) you are responsible for paying any royalties, fees, and any other monies owed by reason of your User Content.

c) You acknowledge and agree that the Sutton Trust has no obligation to display, monitor, or take any action with respect to Network Content or User Content, and that that we have not verified or approved any User Content on the Network. You acknowledge that the views expressed by other users on the Network do not necessarily represent our views, values or beliefs.

d) Certain areas of the Network provide tools for the exchange of ideas and information between users, including in the form of direct messaging. The Sutton Trust is not responsible or liable for any content, including User Content, that is posted or distributed pursuant to such user to user exchanges. The views and opinions expressed by users are theirs alone, and are not endorsed by, and should not be ascribed to the Sutton Trust.  You are solely responsible for all User Content you post, and you assume all risks relating to its use by others and others’ reliance on its accuracy.

e) The Sutton Trust may at any time edit the Network and to edit, remove, delete or refuse any User Content for any reason without notice to users. If User Content violates the standards required by these Terms of Use, the Sutton Trust may terminate the applicable user’s account and right to use the Network, or take any other action we consider appropriate. You agree that the Sutton Trust will have no responsibility or liability in connection with your use of any User Content.

9.  Prohibited uses of the Network

a) You may not post violent, nude, partially nude, discriminatory, unlawful, infringing, hateful, disturbing, pornographic, or sexually suggestive photos or other content via the Network, and you must not encourage or incite others to do so. We will not tolerate racism, sexism, homophobia or other forms of hate-speech, or contributions that could be interpreted as such. Criticising people on the basis of their race, religion, sex, gender, sexual orientation, disability or age is unacceptable and will not be tolerated in any context.

b) You may not defame, stalk, bully, abuse, harass, threaten, impersonate or intimidate people or entities and you must not post private or confidential information via the Network, including your or any other person’s credit card information, social security or alternate national identity numbers, non-public phone numbers or non-public email addresses.

c) You may not use the Network for any illegal or unauthorized purpose. You agree to comply with all laws, rules and regulations applicable to your use of the Network and your User Content, including copyright laws.

d) You must not interfere with, damage or disrupt the Network or servers or networks connected to the Network, including by transmitting any worms, viruses, spyware, malware or any other code of a destructive or disruptive nature. You may not access, without our authority, any part of the Network or any software used in its provision.

e) You must not create accounts with the Network through unauthorized means, including but not limited to, by using an automated device, script, bot, spider, crawler or scraper.

f) You must not attempt to restrict another user from using or enjoying the Network and you must not encourage or facilitate violations of these Terms of Use.

g) You may only make limited and reasonable commercial or political uses of the Network and Network Content. You may promote jobs, advertise your company or campaign, or ask other Users of the Network for help and to assist with volunteering opportunities, but you may not unreasonably or excessively profit (financially or politically) from the use of the platform. We reserve the right to remove or edit any User Content we deem to be unreasonable in this respect, and to restrict or terminate the access of any user account that we deem (in our sole discretion) to be in breach of this provision.

h) You must not reproduce, duplicate, copy or re-sell any part of the Network in contravention of the provisions of our Terns of Use.

i) Other prohibited activities include, but are not limited to:

  • use for the purposes of harming or attempting to harm minors;
  • use that inaccurately implies endorsement, approval, or sponsorship by the Sutton Trust (or any individual officer or employee of the Sutton Trust);
  • use that can be confused with official communications of the Sutton Trust or its officers or employees; and
  • print or electronic mass mailings (sometimes known as “spamming”), solicitations for commercial Networks.
  1. Reporting prohibited conduct or User Content

All users are encouraged to report any content which they feel is inappropriate, particularly in relation to Section 9: (Prohibited Uses of the Network). This can be done by emailing info@suttontrust.com, including brief details of the content you object to and where it has been posted. If possible include a link to where the content appears on the network.

We aim to respond to your complaint within five working days, including our decision and the action we will be taking. Please be aware that complaints about content made outside of office hours may be subject to a delay on our target response time. If content is found to be offensive the user who posted the content will be contacted to let them know their post has been deleted, and to remind them about our community standards.

11.  Privacy and Confidentiality

a) We agree to use your User Content in compliance with the privacy policy of the Network [LINK], together with any Network-specific data use policies, privacy statements and privacy notices (collectively, “Privacy Policies”).

b) We will treat your User Content as confidential information in accordance with the Sutton Trust policies, and only use and disclose it in accordance with these Terms of Use and the Privacy Policies.

12. Our liability to you

The Network and all its content are provided “as is” and without warranties of any kind, express or implied.

We do not seek to exclude or limit in any way our liability to you where it would be unlawful to do so.

If you are a business/commercial user or you use the Network for any commercial purposes, we will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with: (i) use of, or inability to use, the Network ; or (ii) use of or reliance on any content displayed on our Network; (iii) our termination or restriction of your access rights to use the Network. In particular, we will not be liable for any: loss of profits, sales, business, or revenue; business interruption; loss of anticipated savings; loss of business opportunity, goodwill or reputation; or any indirect or consequential loss or damage.

  1. Account Termination Policy

The rights granted to you hereunder will terminate automatically upon any breach by you of these Terms of Use, unless the Sutton Trust otherwise specifically agrees in writing, but the other provisions of these Terms of Use will survive any such termination.

We reserve the right at any time in our sole discretion to cease providing any Network Content, to change or discontinue any aspect or element of the Network, or to cease making the Network available.

  1. Links to Other Networks.

The Sutton Trust may provide links to websites operated by third parties, including but not limited to, websites operated by the Sutton Trust, as a convenience for our users.  The Sutton Trust does not endorse or accept responsibility for the content or the use of third-party websites.  If you use third-party sites, you do so solely at your own risk. Links do not imply that the Sutton Trust is affiliated or associated with any linked site.

  1. Your use of our names and trade marks.

Except as specifically permitted by these Terms of Use, you may not use or register any name, logo, trade mark or insignia of the Sutton Trust or subdivisions for any purpose except with our prior written approval and in accordance with any restrictions required by the Sutton Trust.

  1. Governing Law.

Please note that these Terms of Use, their subject matter and their formation are governed by English Law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction in relation to any claim or dispute that arises from or relates to your use of the Network, save that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland.

[If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales]
  1. General

If any provision of these Terms of Use is held to be invalid or unenforceable, that provision, to the extent unenforceable, shall be struck, and shall not affect the validity or enforceability of the remaining provisions.

Your rights under these Terms of Use are personal to you and may not be transferred to anyone else.

Headings are for reference purposes only and in no way define or limit the scope or extent of any provision of these Terms of Use.

The Sutton Trust ’s failure to act with respect to a breach by you or others does not waive our right to act with respect to subsequent or similar breaches.

Except as otherwise expressly provided in these Terms of Use, nothing herein shall be deemed to confer any rights or benefits onto anyone else.

These Terms of Use set forth the entire understanding and agreement between you and the Sutton Trust with respect to your use of the Network.

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

In this policy, references to ‘we’, ‘us’ or ‘our’ means the Sutton Trust of 9th Floor Millbank Tower, 21-24 Millbank, London SW1P 4QP. We are the data controller for the personal data relating to you that we collect and hold.

  1. What we collect

We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.

Specifically, we hold the following types of data:

  • personal details such as name, address, phone numbers;
  • name and contact details of your next of kin;
  • your photograph;
  • your gender, marital status
  • information of any disability or other medical information you have disclosed;
  • right to work documentation;
  • information gathered via the recruitment process such as that included in a CV, cover letter, or application form;
  • references from former employers;
  • details on your education and employment history etc;
  • criminal convictions (only if the role involves a DBS check).

You provide several pieces of data to us directly during the recruitment exercise.

In some cases, we will collect data about you from third parties, such as employment agencies and former employers when gathering references.

Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.

  1. Why we collect it

The law on data protection allows us to process your data for certain reasons only.

The information below categorises the types of data processing we undertake and the lawful basis we rely on.

Activity requiring your data Lawful basis
Carrying out checks in relation to your right to work in the UK Legal obligation
Making reasonable adjustments for disabled employees Legal obligation
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion Our legitimate interests
Making decisions about salary and other benefits Our legitimate interests
Making decisions about contractual benefits to provide to you Our legitimate interests
Assessing training needs Our legitimate interests
Dealing with legal claims made against us Our legitimate interests
Preventing fraud Our legitimate interests

2.1) Special categories of data

Special categories of data are defined as being data relating to your:

  • health
  • sex life
  • sexual orientation
  • race
  • ethnic origin
  • political opinion
  • religion
  • trade union membership
  • genetic and biometric data.

We carry out processing activities using special category data:

  • for the purposes of equal opportunities monitoring
  • to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

  • you have given explicit consent to the processing
  • we must process the data in order to carry out our legal obligations
  • we must process data for reasons of substantial public interest
  • you have already made the data public.

2.2) Failure to provide data

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

2.3) Criminal conviction data

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interest to process this data.

  1. What we do with your data

Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR.

Data is shared with third parties for the following reasons: to support and advise on best practice within the HR function and occasionally executive search firms when recruiting roles at a Director level.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

3.1) Automated decision making

Automated decision-making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

  1. Where we keep it

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

  1. How long we keep it

We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months once the recruitment exercise ends.

If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.

If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

We are committed to protecting your personal information and being transparent about what we do with it. This Privacy Notice sets out the information that we collect about you in respect of our fundraising programme, why and how we use that information in relation to fundraising activities, the legal basis upon which we process that information, your rights regarding that information and how you can update it.

In this policy, references to ‘we’, ‘us’ or ‘our’ means the Sutton Trust of 9th Floor Millbank Tower, 21-24 Millbank, London SW1P 4QP. We are the data controller for the personal data relating to you that we collect and hold.

  1. What we collect

We only ask you to supply information that we need in order to provide the service you have requested. We will normally ask you to provide us with:

  • Your name
  • Your contact details

We may request or collect other information where it’s appropriate and relevant, for example:

  • Your bank details
  • Your reasons for supporting the Sutton Trust
  • Your profession
  • How you would like us to contact you
  • Your background details relevant to our work and your potential support

We collect personal information about you in several ways:

  • via our website
  • when you contact our staff team by mail, phone, email or live chat
  • when you donate to us through Just Giving. Using JustGiving means you’ll be covered by JustGiving’s privacy policy
  • when using our Alumni Network. Using our alumni network means you will be covered under our Alumni Privacy Policy, which can be accessed at https://www.suttontrust.com/your-privacy
  • When assessing your interest in and capacity to support our work, we may obtain information about you from publicly available sources. (See section 4 for more information on this)

We also collect anonymised information about your visits to our websites using cookies. The information is invaluable to us to improve our website and ensure you are shown relevant content. More information about how we use cookies and how you can prevent this can be found in our Cookie Policy.

We carry out background research into potential supporters to ensure communications are relevant and timely, to target our resources effectively, and to provide an improved experience for our supporters. These activities allow us to understand the background of people who support us and help us to make appropriate requests to supporters who may be able and willing to give more than they already do. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would, so that we can improve social mobility.

Such information is compiled using publicly available data about you, for example from social networking sites, company websites, publications like Who’s Who, dedicated business websites (e.g. Companies House) or publications and articles in the media (e.g. Queen’s Honours List), listed directorships or typical earnings in a given area.

  1. Why we collect it

We use your personal information to:

  • provide you with the service or information you’ve requested;
  • handle the administration of your gift or donation;
  • handle the administration of Gift Aid and Gift Aid declaration forms.;
  • provide you with useful information via newsletters about events and conferences.

We may also use publicly available data to assess your interest in and capacity to support our work prior to your supporting us.

We only contact you where we have legitimate interest to do so with appropriate communications or requests for support. We will only do so where necessary and reasonably expected to ascertain potential funding.

  1. What we do with your data

We use your personal information for the reasons outlined in section 2, above. We do not share or sell your data to any other charity or company for marketing purposes.

  1. Where we keep it

Your data will be retained and stored confidentially and processed in accordance with the Data Protection Act (1998) and General Data Protection Regulation (2018) principles.

Your data will be stored on The Sutton Trust’s shared drive. We are based in the UK and store our data within the EU. Your data will also be stored by JustGiving if you make a donation through them to the Sutton Trust. Using JustGiving means you’ll be covered by JustGiving’s privacy policy

  1. How long we keep it

We hope that your relationship with the Trust will be a lifelong one, and in recognition of the lifelong nature of your relationship with the Trust, we will store and use your personal information indefinitely, or until we no longer have a basis upon which we can legally store or use your information (see section 1 for more information about the bases upon which we use your personal information). In certain circumstances we have a statutory obligation to keep your personal information for a set period of time (normally six to seven years) and this mainly concerns financial information regarding your donations or Gift Aid contributions. After this period of time your financial data will be deleted.

You have certain rights in relation to your personal information, including the right to ask us to stop using information about you.  There is more information about your rights in section 8 of this policy (below).

The data we collect about you via our cookies is retained in accordance with our Cookie Policy.

  1. How we keep your personal information up to date

The Sutton Trust has a legal obligation under data protection legislation to keep the personal information it collects accurate and up to date. We keep your information accurate as follows:

  • By giving you the opportunity at any time to contact us to correct or change your information;
  • By using information publicly available to us;
  • If you contact our team we may ask you to confirm certain details;
  • When we receive undelivered mail or emai

We keep our privacy notice under regular review. This privacy notice was last updated on: 21 May 2018.

This site and it’s related sites (including Sutton Trust Alumni, our online alumni community) uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers. Please note that you cannot disable cookies on Sutton Trust Alumni. By signing up to that site, you agree to our use of cookies on it.

Data Protection principles

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  • processing is fair, lawful and transparent
  • data is collected for specific, explicit, and legitimate purposes
  • data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  • data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  • data is not kept for longer than is necessary for its given purpose
  • data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  • we comply with the relevant GDPR procedures for international transferring of personal data

Your rights

Under the Data Protection Act (1998) and General Data Protection Regulation (2018) you have the following rights in relation to the personal data we hold on you:

    1. be informed about the data we hold on you and what we do with it;
    2. of access to the data we hold on you. More information on this can be found in our policy on Subject Access Requests. You can make an enquiry using our Subject Access Request Form;
    3. for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
    4. to have data deleted in certain circumstances. This is also known as ‘erasure’;
    5. to restrict the processing of the data;
    6. to transfer the data we hold on you to another party. This is also known as ‘portability’;
    7. to object to the inclusion of any information;
    8. to regulate any automated decision-making and profiling of personal data

More information about your rights can be found on the ICO website

Making an enquiry

If you have any concerns about the processing or use of data for these purposes or would like a copy of the data we hold on you, requests should be made in writing to dataprotection@suttontrust.com using our Subject Access Request form.

We will consider all such requests and will try to respond to your request within 5 working days (and in any event within any time period required by law). Please note, however, that certain personal information will be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any.

If you would like to exercise any of your rights in relation to your personal information, please email or write to us using the contact details at the bottom of the page. We do not apply a charge for providing you with your personal information or responding to your requests.

If we do hold information about you we will:

  • give you a description of it.
  • tell you why we are holding it.
  • tell you who it could be shared with.
  • let you have a concise and clear copy of the information.

We want to make sure that your personal information is accurate and up to date and we will be happy to correct or remove information you think is inaccurate.

If you decide in the future that you no longer want your data to be used , please contact the Sutton Trust by e-mailing dataprotection@suttontrust.com or phoning 020 7802 1660.

Making a complaint

If you have any complaints about the way your data has been handled you should make a written complaint to dataprotection@suttontrust.com

Alternatively, you can contact the ICO on 0303 123 1113, or write to them using the address below. They are open Monday to Friday between 9am and 5pm.

ICO
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF