Privacy

The Portsmouth Grammar School maintains a database of alumni, parents, friends, and supporters in order to stay in touch with our community and keep you updated about news, events, careers initiatives and fundraising activities

Some of our database (but not all) choose to join our online community by registering on this website and creating an online profile. In both instances (individuals with offline database records and individuals with online profiles), we collect and store personal information (or “data”) about you. We are committed to protecting and respecting your privacy and this Policy sets out what information we collect about you, where and how we use (“process”) it.
THIS POLICY
The school will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
QUERIES AND COMPLAINTS
If you have any comments or queries on this policy, we recommend that in the first instance you direct these to the Bursar, who can be contacted by email as follows:
Name: Mr John Read Email address: j.read@pgs.org.uk Contact number: 023 9236 4250 Contact address: The Portsmouth Grammar School, High Street, Portsmouth, Hampshire, PO1 2LN
The school has also appointed a Data Protection Officer or DPO. The DPO advises the school about issues to do with data protection, but can also help you, if you have a problem.
Our Data Protection Officer is: GDPR Sentry Limited Email address: support@gdprsentry.com Contact number: 0113 804 2035 Contact address: 4 Highcliffe Court, Greenfold Lane, Wetherby, West Yorkshire, LS22 6RG
If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school complaints procedure. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns/ (or call 0303 123 1113), although the ICO recommends that steps are taken to resolve the matter with the school before involving the regulator

WHY THE SCHOOL NEEDS TO PROCESS PERSONAL DATA
In order to carry out its ordinary duties to staff, pupils and parents, the school needs to process a wide range of personal data about individuals (including current, past and prospective staff, pupils or parents) as part of its daily operation. Some of this activity the school will need to carry out in order to fulfil its legal rights, duties or obligations, including those under a contract with its staff, or parents of its pupils.

Other uses of personal data will be made in accordance with the school’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals and provided it does not involve special or sensitive types of data. The school expects that the following uses will fall within that category of its (or its community’s) “legitimate interests”:
WHAT TYPE OF PERSONAL INFORMATION WE COLLECT

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

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

WHERE WE COLLECT INFORMATION FROM

We collect personal information when you:
•   visit this website
•   create or update your online profile
•   post content on to this website or other websites and social media sites managed by The Portsmouth Grammar School
•   take part in an event
•   attend a meeting with us and provide us with information
•   contact us in any way including online, email, phone, SMS, social media or post
•   open an email sent from this website
•   send a message via the direct messaging system on this website
•   leave The Portsmouth Grammar School [and we transfer some basic details about you from the main The Portsmouth Grammar School [database in to our [alumni] database

HOW LONG WE KEEP PERSONAL DATA
The school will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason
HOW WE USE YOUR INFORMATION
The school will use the contact details of parents, alumni and other members of the school community to keep them updated about the activities of the school, or alumni and parent events of interest, including by sending updates and newsletters, by email and by post.
Unless the relevant individual objects, the school will also:
1. Share personal data about parents and/or alumni, as appropriate, with organisations set up to help establish and maintain relationships with the school community, such as the Parents Forums.
2. Contact parents and/or alumni by post and email in order to promote and raise funds for the school and, where appropriate, other worthy causes.
3. Should you wish to limit or object to any such use, or would like further information about them, please contact the Development Director or Bursar in writing.

You always have the right to withdraw consent, where given, or otherwise object to direct marketing or fundraising. However, the school is nonetheless likely to retain some of your details (not least to ensure that no more communications are sent to that particular address, email or telephone number)

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

•   providing you with the information or updates that you have asked for
•   sending you communications (with your consent if required) that may be of interest, including invitations to events, newsletters and fundraising campaigns
•   delivering our obligations under any contract between us
•   seeking your views on the services or activities we carry out, so that we can make improvements
•   updating our database records and ensuring we know how you prefer to be contacted
•   analysing your engagement with our website and other content to help us improve our services for you
•   running our mentoring programme/ club activities/ reunion events/ sports fixtures

OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION

The use of your information for the purposes set out above is lawful because one or more of the following applies:
•   you have given us your consent for the information to be used
•   it is necessary for us to hold and use your information to carry out our obligations under a contract entered into with you
•   it is necessary for our legitimate interests to hold and use your information and we are not impacting your privacy by doing so

UPDATING YOUR CONSENT PREFERENCES

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

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

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

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

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

If you want to contact us about your consent preferences please contact the Development Office on development@pgs.org.uk or 023 9268 1385 .

HOW WE KEEP YOUR INFORMATION SAFE

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

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

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

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

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

WHO HAS ACCESS TO YOUR INFORMATION?
In accordance with Data Protection Law, some of the school’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers.
This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the school’s specific directions.

•   Third parties who provide services for us, for example such as, collecting or processing data and sending mailings. We select our third-party service providers with care. We provide these third parties with the information that is necessary to provide the service and we will have an agreement in place that requires them to operate with the same care over data protection as we do
•   Third parties if we run an event in conjunction with them. We will let you know how your data is used when you register for any event
•   Web hosting, email hosting, analytics and search engine providers that enable us to run our community database and improve our website and its use
KEEPING YOUR INFORMATION UP TO DATE

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

COOKIES

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

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

The list below explains the cookies we use and why:
Cookie Description   Name   Purpose
Session Cookie   Home | Portsmouth Grammar School (pgs.org.uk) PyroCMS
Used to remember you as you travel from page to page in a single session (without leaving the website) in order to provide a continuous and unified experience
Functional Cookie   Google Captcha – various, including: NID, AND, 1P_JAR 7 consent   Used to remember your login details when you return to the website after previously logging out, by storing them in your browser. This cookie is turned off by default and is only activated when you select the ‘Remember Me’ check box during login.

OPTING OUT OF COOKIES

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

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

USE OF AGGREGATED DATA

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

How long we keep your information for

The School shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed .
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
For full details of the school’s approach to data retention, including retention periods for specific personal data types held by the school, please refer to The PGS Storage and Retention of Records and Documents Policy which is available on request.
Where we rely on your consent to contact you for direct email marketing/ fundraising purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. This will usually be for [two] years. We may periodically ask you to renew your consent.

If you ask us to stop contacting you, we will keep a record of your contact details and limited information needed to ensure we comply with your request.

YOUR RIGHTS
1.Rights of access Individuals have various rights under Data Protection Law to access and understand personal data about them held by the school, and in some cases ask for it to be erased or amended or have it transferred to others, or for the school to stop processing it – but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Development Director or Bursar.
The school will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information, but actually fulfilling more complex requests may take 1-2 months longer). The PGS Privacy Notice for the School Community 6 The school will be better able to respond quickly to smaller, targeted requests for information made during term time. If the request for information is manifestly excessive or similar to previous requests, the school may ask you to reconsider, or require a proportionate fee (but only where Data Protection Law allows it).
2. Requests that cannot be fulfilled You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals, or information which is subject to legal privilege (for example legal advice given to or sought by the school, or documents prepared in connection with a legal action).

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

You also have the following rights:
•   to request rectification of information that is inaccurate or out of date.
•   to erasure of your information (the “right to be forgotten”).
•   to restrict the way in which we are dealing with and using your information.
•   to request that your information be provided to you in a format that is secure and suitable for re-use (the “right to portability”).
•   in relation to automated decision making and profiling.
All of these rights are subject to certain safeguards and limits or exemptions. To exercise any of these rights, you should put your request in writing to the Development Director or Bursar. [
If an individual believes that the school has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should utilise the school complaints procedure.
You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns/ (or call 0303 123 1113), although the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator

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This Policy was last updated in August 2024