1. INTRODUCTION

This Privacy Notice is issued on behalf of Westminster Theological Centre (WTC). References to “we”, “us” or “our” in this Privacy Notice relate to how WTC is responsible for processing your data.

WTC is a charity registered in England and Wales, (Charity number 1123573), and a company limited by guarantee, (Company number 6506007). Our website is owned and operated by WTC whose registered address is:

16-17 Clarence Parade
Cheltenham
GL50 3PA

The Trustees of WTC are the Data Controllers and are responsible for general data protection matters and complaints arising with respect to day-to-day matters.

WTC has appointed a Data Protection Lead who is responsible for overseeing questions in relation to this Privacy Notice. Queries related to data protection should be directed to the Data Protection Lead. (Section 15: How to Contact Us.)

The purpose of this Privacy Notice is to give you information on how WTC collects and processes your personal data which, either you have provided to us, or we obtain. This Notice applies to the personal information we collect about you directly or that we collect from third parties. 

The Privacy Notice sets out:

● What information we collect, and from whom
● How we use that information
● Student Data
● Alumni
● Direct Marketing
● Lawful Basis
● How long we keep your data
● How your information is protected
● How we share your data
● International transfers of personal data
● Cookies
● How you can control your data
● Summary of your rights in relation to the information we hold about you
● Contact Us
● How to complain

This website is not intended for children, and we do not knowingly collect data relating to children.

2. WHAT DATA DO WE COLLECT?

We collect the personal information you give us when you:

● provide us with your contact details such as name, address, email address, phone numbers, date of birth and gender
● become a Patron
● leave a legacy
● correspond with us
● sign up for free resources
● apply to be a student
● attend an event or Hub Open Evenings
● provide financial information to us including about donations, fundraising and gift aid
● order products and services from us
● use our products, services and website
● provide a testimonial or a review on our website
● communicate with or contact us
● enter any of our surveys
● interact with us on social media platforms
● sign up to one of our newsletters or other communications
● request a call back through our website.

When we request information from you, this will be explained in the relevant forms or pages, or over the telephone. You may choose to provide additional information when you interact with us or to a third party who refers you to us. We store customer feedback and information on our customer databases.

We will collect data you give us when you apply for a job with WTC. This may include:

● your bank account details and tax and residency status
● references from previous employers or educational institutions
● contact details for you and any next of kin
● your qualifications
● information concerning your health and medical conditions
● information about your race, ethnicity, and sexual orientation
● details of unspent criminal convictions.

2.1. Special Category Data

Where data processing relates to Special Categories of Data the following processing conditions apply:

● Explicit Consent has been given by the data subject
● Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.

2.2. Social Media Users

We use social media channels (including Facebook, WhatsApp, Vimeo and Instagram, the “Social Media Companies”) to publish information about the charity. If you follow or otherwise engage with our social media channels, we will collect Usage Data to analyse how users interact with those channels. If you use social media to send us messages or posts, we may use your Profile Data to communicate with you. When you interact with our channels, the Social Media Companies will also process your personal data for the purposes set out above as Joint Controllers. For more information, we would encourage you to review the privacy notices published by the Social Media Companies.

3. HOW DO WE USE YOUR DATA?

All personal data is stored securely in accordance with the DPA 2018 (the UK’s General Data Protection Regulation). We use your data to provide the best possible products and services to you.

This includes:

● providing and managing your access to our site
● administering and managing our relationship with you, such as responding to communications
● personalising and tailoring your experience on our site.
● supplying our programmes of study
● responding to communications from you
● sending transactional and service messages in relation to an event
● analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience
● complying with legal or regulatory requirements
● helping us establish, exercise, or defend legal claims
● producing statistical returns e.g. for HESA, research and statistical analysis and to meet statutory or other obligations.

In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you without your consent for us to be able to use such data.

4. PROCESSING OF ADDITIONAL PERSONAL DATA FOR STUDENTS

All personal data is stored securely in accordance with the DPA 2018 (the UK’s General Data Protection Regulation). We use your data to:

● deliver and administer your enrolment, including complying with the UK immigration regulations, education, record the details of your studies and determine/confirm your academic achievements (e.g. results)
● administer the financial aspects of your relationship with us and manage the granting of bursaries and other discretionary payments
● administer student related policies and procedures including appeals, complaints, grievances and disciplinary matters. Provide you with any additional support you may require based on your identified needs
● film and record certain lectures. Please note that students are not the subject of these recordings, although they may be visible and any discussion between lecturers and students as part of the activity may be recorded
● administer student numbers, including your student ID number for HESA
● register you with our validating university
● facilitate the use of our College Data Management System (CDMS) to access learning modules and submit assignments including uploading your photograph
● so you can participate, if you so agree, in approved market research activities (e.g. surveys, focus groups, workshops) about your WTC experience, including the National Student Survey
● receive communications about our community, your studies and your experience as a student
● continue your relationship with us following your study (further information is shown below for Alumni)
● fulfil our legal obligation to respond to Freedom of Information requests. Information will be redacted before disclosure to reduce the risk of any individuals being identifiable from it
● provide information and data for publications about us, which will be redacted to reduce the risk of any individuals being identifiable from it unless you consent to be identified.

5. ALUMNI

The information we hold comes directly from our alumni. We will use alumni details to manage alumni interaction with us and to contact alumni by post, email, phone, text and/or social media, complying with any preferences alumni have expressed. We contact alumni to:

● keep alumni informed of WTC news, and the achievements and advances being made by the WTC, its students, staff, and alumni
● inform you about the benefits of being an alumnus/a of the WTC, including discounts and services
● invite you to events hosted by WTC, partner organisations, or your fellow alumni (for example reunions)
● offer opportunities for you to engage with WTC as an ambassador, volunteer, friend and supporter. This may include asking you for your financial support through making a gift to one of the projects which help to deliver WTC’s mission of creating and sharing knowledge, or asking you to give your time to help students.

6. DIRECT MARKETING

We may, from time to time, supply you with email newsletters, alerts etc. that you have subscribed to. (You may unsubscribe or opt-out at any time by clicking the ‘unsubscribe’ link in the email or by contacting Us. (Section 15: How to Contact Us).

Once you have submitted your preference to us, we may use these for marketing, which may include contacting you by email, telephone, or text message with information, news and offers on our products and services. We will not, however, send you unsolicited marketing or spam, and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the DPA 2018, GDPR, and the Privacy and Electronic Communications Regulations.

7. LAWFUL BASIS

Under GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following applies:

● You have given consent to the processing of your personal data for one or more specific purposes
● Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract
● Processing is necessary for compliance with a legal obligation to which we are subject
● Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.

We rely on our legitimate interests for the following reasons:

● Keeping our records up to date
● Developing, marketing and charging for our products and services
● Running our websites and keeping them safe and secure
● Presenting our content and communications in the most effective and sustainable manner for you and your devices
● Helping you use our websites, including obtaining products or services
● Measuring how you use our websites and improving their content and accessibility
● Measuring and understanding how effective our marketing is
● Complying with legal and or regulatory requirements
● Identifying student trends
● Understanding products, services and the student experience
● Providing insight and analysis into how our social media channels are used and how they are performing.

8. HOW LONG DO WE KEEP YOUR DATA?

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Our retention of your personal data is linked to your actions. Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Notice, or until you request that the information be deleted (Section 14: Summary of your rights).

In some instances, we may need to send your information to third parties outside the UK. You are deemed to accept and agree to this by using our site and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the UK GDPR. Such steps may include, but not be limited to, the use of legally binding contract terms between us and any third parties.

Even if you ask us to delete your personal information, we reserve the right to retain your personal data where such retention is necessary for compliance with a statutory obligation, (for example to maintain a copy for legal, tax or regulatory purposes). In such an event, we will do so only as long as necessary to fulfil those statutory obligations.

9. HOW DO WE PROTECT YOUR DATA?

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our site.

All your data is stored electronically in a secure database or a locked filing cabinet, and can only be accessed by authorised people. All users of our system are trained in GDPR.

Where we engage third parties to process personal data on our behalf, they do so upon writing, and are contracted to implement appropriate technical and organisational measures to ensure the security of data.

10. HOW DO WE SHARE YOUR DATA?

We are committed to not sharing your data, and will only do this if it is in your legitimate interest to ensure we provide you with the support and information required to make an informed decision about a service(s) or product(s).

We will not sell your data to any unconnected third parties.

We may contract with third parties to supply products and services to you on our behalf. These may include payment processing and search engine facilities.
We may share your information within WTC for research and analysis.

In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We currently contract with: