As part of the graduate outcomes survey process, University College Dublin (UCD) collects and processes personal data relating to recent graduates. UCD is committed to being transparent about how it collects and uses these data to ensure it is meeting the data protection obligations. UCD strives to maintain compliance with the Irish Data Protection Act 2018 and the General Data Protection Regulation (GDPR), which entered into force across EU Member States on 25th May 2018.
DARO supports UCD through contact with alumni, students, supporters and those who may become potential supporters of the University. We do this by offering a range of academic, social and networking events. For example, we provide publications of interest, access to University Library resources and employment and skills advice for graduates. We also fundraise to support the University’s strategic objectives
To do this, DARO maintains a database that contains personal data collected by the University and by DARO during UCD’s relationship with students, alumni, donors, supporters, prospective supporters and non-alumni friends of UCD.
DARO collects a range of information about you (Personal Data). This may include:
- Details of past student education (e.g. your College(s), the courses you have completed, your subjects, dates of study, details of any awards, scholarships or other accolades achieved during your University years)
- Unique personal identifiers and biographical information (e.g. student number, name, title, date of birth)
- Your contact details (and we update these whenever you let us know that they have changed)
- Details about your family (e.g. your marital status, the name of your partner or spouse, children etc) to help provide the best alumni experience. For example, so we can tailor communications and event invitations to you
- Your current interests and activities
- Your career highlights and other life achievements
- Details of what correspondence we have sent to you and any responses we have received from you
- Details of alumni interactions with the University, including:
- Your membership of clubs, societies, and alumni groups
- Your attendance at University events
- Other contact with us or our partners (as listed below)
- Details of benefits and services provided to you, including those set out at https://www.ucd.ie/alumni
- Your relationships with other alumni or supporters of the University and DARO
- Personal data provided by you for a specific purpose (e.g. disability and dietary preferences for event management purposes)
- Your communication preferences, to help us provide tailored and relevant communications
- Non-financial support that you provide the University (e.g. details of volunteering roles, participation in panel discussions, as a speaker, mentoring etc)
The legal bases for the processing of your data are:
- That you have provided consent for the processing for one or more specified purposes
- Processing necessary for compliance with a legal obligation: For the purposes of maintaining the National University of Ireland (NUI) electoral register for Seanad Éireann, from time to time NUI and UCD will transfer personal data about listed graduates to each other in circumstances where either party has been informed that a graduate is deceased, or where a UCD graduate has updated their contact address;
- DARO may process the information outlined in this Data Collection Notice in pursuit of our legitimate interests in:
- Communicating with students, staff, alumni, friends, and current and potential supporters with an interest in the University about UCD for example, e-zines, alumni magazines, social media, events etc.
- Updating alumni on their legal entitlement to vote in the elections to Seanad Éireann
- Providing benefits and services to students, staff, alumni and supporters (for example library access/adult education courses/post graduate studies/gym membership etc);
- Furthering the University’s educational charitable mission (which includes fundraising through UCD Foundation and securing the support of volunteers);
- Supporting the University to achieve its strategic and operational goals.
Whilst DARO relies on legitimate interest as the legal basis for processing data where this is not overridden by the interests and rights or freedoms of the data subjects concerned it recognises that it is not the only lawful ground for processing data. In addition to the use of legitimate interest, we may also sometimes process your data on alternative grounds – for example, because you have given us consent to do so or connected with the performance of the University’s statutory objects and functions under the Universities Act 1997 and related legislation.
Your data is used by us for several interdependent purposes in support of alumni relations communications and events and fundraising.
- Updating alumni on your legal entitlement to vote in the elections to Seanad Éireann
- To keep you up to date with news and progress regarding UCD and its community by sending you publications (e.g. alumni magazines, e-zines)
- Conducting surveys, including research on when and whether donations or funding appeals may be of interest to you or areas of the University that you may like to volunteer in
- Providing services and benefits of being an alum, including access to University facilities, discounts and alumni email accounts
- Sending you details of volunteering opportunities
- Inviting you to alumni and other University events like professional career development or reunions
- The promotion of other opportunities and services available to you (e.g. offers and opportunities available through the University’s network)
- Internal record keeping, including the management of any feedback or complaints
- Communications to you may be sent by post, telephone, SMS or electronic means (principally by email), depending on the contact details we hold, and the preferences expressed by you about the types of communications you wish to receive.
- Sending you tailored proposals, appeals and requests for donations including direct marketing, telephone and e-mail fundraising
- Wealth analysis and research to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications more effectively
- Administrative purposes (e.g. to process a donation you have made or to administer an event you have registered for or attended)
We share categories of past student data (excluding financial or gift information) which is relevant with UCD and its Colleges. We work closely with the Colleges to provide our shared alumni and supporters with a coordinated and centralised communications approach through DARO. Except for the College of Business which has access to our DARO database and its own Alumni Relations team to support its past students. In addition, the Schools of Law and Medicine also have access to their past students’ information on our DARO database. Colleges and schools have access to only their specific students on the alumni database, and we maintain other electronic and paper records. Any transmission of data to or from the Colleges about their alumni is managed through agreed processes which comply with relevant data protection legislation.
Additionally, we share data of our alumni (which does not include financial data) on a considered and confidential basis, where appropriate, with:
- Affiliated organisations and individuals which support and provide services to alumni and supporters, such as:
- University Clubs and Societies
- volunteer partners closely related to us (e.g. development and advisory board members, alumni societies, alumni group representatives, reunion class champions)
- educational units associated with the University that award scholarships
- Third parties engaged by the University to provide Fundraising and Communications related services, such as:
- Third Party Agencies who provide us with data about Alumni and Supporters
- Consultants advising us on individuals’ capacity to donate to support UCD’s Fundraising Strategy and an individual’s potential to donate based on a considered judgement
- To enable more effective communication with you, we may engage with other contractors who provide services to us that improve our engagement with you or who may provide services to you on our behalf
- Banks who carry out financial transactions on behalf of UCD Foundation for example, through UCD Foundation uploading direct debit uploads
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. We take reasonable and adequate organisational and technical measures to ensure that your personal details are secured.
All personal information is treated confidentially and with respect for the benefit of the University and its members in accordance with the Data Protection Act and GDPR.
Any personal information we obtain will be held securely on the DARO database. This is hosted within the EU and is fully SAS 70 Type II Certified and PCI DSS compliant. We take appropriate steps to ensure that we only record and store information which is relevant, that we keep securely, that is accurate and up to date.
Personal information will not be disclosed to external organisations other than those acting on the instructions of the University or UCD Foundation. Where this is the case, a written contract or appropriate data sharing agreement will be put in place between the University or UCD Foundation and the third party to set out the purposes for which the information can be used and the security measures that must be in place.
We do not sell your personal data to third parties under any circumstances or permit third parties to sell on the data we have shared with them.
We also facilitate communication between individual alumni, but in doing so we do not release personal contact details without prior permission.
We may also disclose relevant contact details to fellow alumni who are arranging reunions or other alumni events if we believe they may be of interest to you.
Any transfers of your data overseas (outside of the European Economic Area), for example to an international alumni organisation or UCD Chapter, as set out above, are protected either by an ‘adequacy decision’ by the European Commission (declaring the recipient country as a ‘safe’ territory for personal data) or by standard contractual clauses adopted by the European Commission (which give obligations for the recipient to safeguard the data) or, based on DARO’s self-assessment of the risks involved with the transfer and its determination that the data will be adequately protected during and after the transfer.
As a data subject, you have a number of rights. You can:
- Ask us for access to, or rectification of your data held on DARO databases
- Restrict processing (pending correction or deletion)
- Object to communications
- Ask for the transfer of your data electronically to a third party (data portability)
- Opt out at any stage by emailing email@example.com or firstname.lastname@example.org
UCD’s Data Protection Officer is responsible for monitoring compliance with relevant legislation in relation to the protection of personal alumni data.
If you wish to amend the type of alumni communications you receive or the way in which the DARO contacts you, please contact: email@example.com
If you have any concerns or queries about this policy, or about how we hold and use your alumni data, please contact firstname.lastname@example.org
You have the right to lodge a complaint to email@example.com
We always handle your personal data securely and minimise its use, and there is no overriding prejudice to you by using your personal information for these purposes. In addition, there is no statutory or contractual requirement for you to provide us with any personal data.
Where you exercise your right to erasure, UCD through Registration will continue to maintain a core set of personal data (name, subject(s), matriculation and graduation details, unique University identification number and date of birth) to ensure UCD does not contact you inadvertently in future, and to maintain your academic record for archive purposes.
UCD Foundation may also need to retain some financial records about you for statutory purposes (e.g. Tax back, anti-fraud and accounting matters).
If you have any concerns about any personal data that may be held by your College, you will need to contact the College separately.
If you would like to exercise any of these rights, please contact the Office of the DPO by emailing firstname.lastname@example.org. If you believe that the organisation has not complied with your data protection rights, you can complain to the Data Protection Commissioner, which is the DP specific complaints handling body in Ireland.