Privacy Policy

Protecting your privacy and your data is important to us. At all times we aim to respect any personal information you share with us, or that we receive from other organisations, and keep it safe. This Policy explains how we hold and use personal information and your rights and options in relation to it.

If you have any questions about this policy please contact us using the details in the “Contact us” section below.

Who we are

We are the Royal Anniversary Trust (the Trust, registered charity number 1,000,000). We also have a wholly owned subsidiary, Anniversary Trading Ltd (registered company number 14136842) that carries out commercial activities for the charity. The Royal Anniversary Trust and Anniversary Trading Ltd are the controllers of the personal information that is collected.

Our work

The Royal Anniversary Trust was established in 1990 to celebrate and promote excellence, innovation and impact in the UK tertiary education sector. Our main function historically has been to administer, assess and recognise winners of the Queen’s Anniversary Prizes for Higher and Further Education, now known as the Queen Elizabeth Prizes for Higher and Further Education (the Prizes).

Who we collect data from

The Trust collects and uses certain types of personal information about the following categories of individuals:

  • Heads of universities and colleges across the UK and their team members involved in Prizes applications;
  • Academic and expert Readers and panellists who provide assessment of the Prizes;
  • Trustees and other volunteers involved in governance and delegated committees;
  • Employees and Contracted Associates
  • Consultants commissioned by the Charity to enact the management of its affairs;
  • Professional advisers and service providers including third party solicitors and auditors and providers of bookkeeping, banking and investment advice and management services;
  • Advisers, evaluators, trainers and supporters working with the Charity on research projects and the dissemination of research outcomes through conferences, seminars and multimedia publications.

How we collect information about you

  • When you give it to us directly – For example, personal information that you give us by filling in forms or communicating with us by phone, email or letter or filling in a survey.
  • When it is provided to us via third parties – Your personal information may also be shared with us by third parties including our partners; sub-contractors that provide us with technical, payment and delivery services; analytics providers and search information providers. Typically, this will be via third-party platforms, such as awards management programmes or stakeholder engagement databases, to collect and manage personal data on our behalf for use in the ways that you have given consent. To the extent that we have not done so already, we will notify you when we receive personal information about you from these third parties and tell you how and why we intend to use that personal information.
  • When it is available publicly – Your personal information may be available to us from external publicly available sources.

What personal information do we process?

We may collect, store and use the following kinds of personal information:

  • Name and contact details, including postal address, telephone number, email address and, where applicable, social media identity;
  • Photographs, video or audio recordings;
  • Biographical information, such as your occupation or employment history, your academic areas of expertise or research, including formal qualifications;
  • Information about your computer / mobile device and your visits to and use of our websites, including for example your IP address.
  • For employees or contracted associates: name, address, home and/or mobile numbers, email address, emergency contact details or next of kin details, information captured in any cv or application provided to us including experience, qualifications, employment history, membership of professional bodies.

Do we collect/ share sensitive personal information?

Data privacy law identifies certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health or ethnicity. In limited cases, we may collect and/or use your sensitive personal information (also known as special category data). Normally we will only do so where we have your explicit consent, but there may be other circumstances permitted under data privacy law.

Any sensitive personal data is normally only gathered to allow us to ensure your safety and comfort for example if you are attending one of our events and share information with us about your specific dietary requirements or any access requirements. We also use this kind of data to make sure our panels of Readers and assessors are diverse and inclusive and for us to monitor our progress on this against our diversity objectives.

For employees and contracted associates, we may collect personal information to enable us to fulfil our legal obligations to you as an employer. This may include information on your health in order to best support you in your work and make any reasonable adjustments that you require. We will also collect financial information in order to pay you and legally process functions such as tax, national insurance, pensions, student loans payments etc.

How and why we use your personal information

Your personal information, however provided to us, may be used for the purposes specified in this policy, including:

  1. To provide you with services or information which you request to process payments from you such as donations (including Gift Aid);
  2. To communicate with you to keep you up to date generally on programmes and events run by the Royal Anniversary Trust.
  3. To process applications and assessments for the Queen Elizabeth Prizes for Education and to invite and make arrangements for your attendance at key events associated with the Prizes.
  4. To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  5. To improve your interactions with our websites, for example by ensuring that content is presented in the most relevant and effective manner for you and for your computer;
  6. To report on the results and impact of our work;
  7. As part of our efforts to keep our websites and our internal operations safe and secure;
  8. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  9. To undertake donor due diligence;
  10. To administer your employment application;
  11. To maintain our accounts and records to support and manage employees, volunteers and contracted associates.
  12. To deal with enquiries and/or complaints made by or about you;
  13. To audit and/or administer our accounts;
  14. To satisfy legal obligations which are binding on us, for example arising from contracts entered into between you and us or in relation to regulatory, government and/or law enforcement bodies with whom we may work;
  15. Prevention of fraud, misuse of services or money laundering; and/or enforcement of legal claims
  16. In specific instances, we share personal information with The Royal Household or they with us, solely for the practical purposes of organising and administrating events held at Royal venues or attended by members of the Royal Family.

Filming and photography at events

Please note that we (or our service providers) or third party (including project partner) event hosts may film or photograph those attending or taking part in our events.

We may use the footage or photographs for publicity and marketing/ fundraising purposes. For example, in print and/or digital material including social media, or via external advertising and press outlets, all of which may be made available to the public.

Communications: social media / digital

We may use your contact details to provide you with information about our work which we consider may be of interest to you or which you have agreed to play an active role in (e.g. application for or assessment of Queen Elizabeth Prizes for Education.) You can opt-out of receiving communications from us at any time using the details in the “Contact us” section.

Depending on your settings or the privacy policies for social media platforms like Facebook, X, Instagram and LinkedIn, you may receive targeted advertisements about the Charity through our use of social media audience tools.

Our website may also use web beacons or pixels through third-party service providers that allow us to track conversions and activity on our website.

We may work with third party suppliers who may also set cookies on our website, for example, e.g. Facebook, Twitter, YouTube etc. which we use to display video content). These third-party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.

In addition to the campaign communications that you receive from us, we may also communicate with you by post, telephone and e-mail in relation to administrative matters. On occasion, we will also contact you about an event that you have signed up to participate in.

Will we share your personal information?

Unless stated in this Policy, we do not share (unless we have your consent to do so), sell or rent your personal information to third parties for their own marketing purposes.

Sharing with moderation companies

Please note that for some projects we use third party moderation companies – where we do this, those companies will be granted access to our social media platforms and will read and review some or all posts made to ensure that the content abides by our community guidelines. Inappropriate content may be removed or hidden, and the individuals who posted may be blocked from further interaction on the channels.

Other sharing purposes – We may also disclose your personal information to selected third parties in order to achieve the purposes set out here, including:

  • We may share your personal information with our charity partners, where necessary and appropriate to coordinate our projects;
  • We may share your personal information with selected research agencies to help us to evaluate the impact of the work that the charity is carrying out;
  • Where the transfer is to a secure data processor, which carries out processing of your personal information on our behalf pursuant to a contract;
  • Where we are required by law to do so, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation;
  • Where our charitable projects are transferred to a new or separate legal entity/charity.

International transfers

We do not transfer your personal data outside the UK.

Security of and access to your personal information

We have put in place proportionate and appropriate security measures to safeguard your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed.
For example, your personal information is only accessible by appropriately trained staff and contractors, and stored on secure servers. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

The transmission of information via the internet is never completely secure, and although we do our best to protect it, we cannot guarantee the security of personal information transmitted via the internet.

Our legal basis for processing your personal information

The Charity must rely on a lawful basis to collect and use your personal information. Data privacy law specifies six such grounds, and we consider the following to be relevant to our use of personal information:

  1. Where you have provided your consent – for example, to send you direct marketing by mail or email.
  2. Where it is necessary so that we can comply with a legal obligation to which we are subject – for example where we are obliged to share your personal information with HMRC to process a Gift Aid declaration.
  3. Where it is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract. For example, if you are assisting with or otherwise involved in one of our projects under a contract.
  4. Where there is a legitimate interest in us doing so.

Legitimate interests

Personal information may be collected and used if it is reasonably necessary to achieve a legitimate interest (as long as that processing is fair, balanced and does not unduly impact your rights).

Where we rely on legitimate interests, depending on the activity, these may include the following:

  • Charity governance, including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes;
  • Administration and operational management, including responding to solicited enquires, providing information, research, donor due diligence, events management, the administration of our projects and employment and recruitment requirements;
  • Fundraising and campaigning, including administering campaigns and donations, and sending material by post (and in some cases making telephone calls), analysis, targeting and segmentation to develop communication strategies and maintaining communication suppressions;
  • Research we conduct to help us understand our impact across our key areas work, and to support continuous improvement and the wider objectives of the Trust.

How long do we keep your personal information?

Whatever your relationship with us, we will only store your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements.

Usually this will be for a specified amount of time in accordance with our internal retention policy. For everyone except employees and contracted associates this length is never more than ten  years which allows us to contact institutions eligible to apply for the Prizes and any suppliers or partners who work with us on delivering those Prizes, for five biennial Prizes rounds and for all assessors and Readers of the Prizes to work with us for our agreed tenure of up to a maximum of ten years, in line with Charity Commission guidance for honorary roles.

For employees and contracted associates the retention period will be for your period of application to and employment by the Trust and for ten years after that such that the Trust may be able to provide professional references for you once you have left our employment and in order for us to comply with our legal obligations as your employer.

For applicants for employment or consultancy work with the Trust who are not ultimately appointed, application details will be held for a maximum of 12 months retention period.

Once the retention period has expired, personal information will be confidentially disposed of or permanently deleted.

If you object to further contact from us, we will keep some basic information about you on a “suppression list” in order to avoid sending you unwanted communications in the future.

Your rights

You have a number of legal rights under data protection laws in relation to your personal information. These rights include:

  • Right to object – you have the right to object to processing where we are (i) relying on the legitimate interests as a legal basis, (ii) using your personal information for direct marketing or (iii) using your personal information for statistical purposes.
  • Right to withdraw consent – where we are using your personal information on the basis of your consent, you can withdraw that consent at any time.
  • Right of access – you can ask for confirmation of what personal information we hold about you and request a copy of that personal information. Provided we have successfully confirmed your identity (we need to be sure we are only releasing your personal information to you), we will provide you with your personal information subject to any exceptions that apply. This is sometimes called a “subject access request” and can be done by writing to us at the email or postal address in the “Contact us” section below.
  • Right of erasure – in some cases, you can ask us to delete your personal information from our records (or to anonymise it). We may retain some limited personal information in order to ensure you are not contacted by us in the future.
  • Right of rectification – if you believe our records concerning you are inaccurate, you have the right to ask us to update them. You can ask us to check the personal information that we hold about you if you are unsure.
  • Right to restrict processing – in certain situations you have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.
  • Right to data portability – where we are processing your personal information using automated means on the basis of consent, or to perform a contract, you may ask us to transfer it to another service provider in a usable format.

To exercise any of these rights, please send us a description of the personal information in question, along with an explanation of the rights you wish to exercise, using the contact details in the “Contact us” section below. In some cases, we may ask for proof of identification or further information before we can process your request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please note that these rights only apply in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ – or please contact us using the details in the “Contact us” section below if you are unsure.

Changes to this Policy

We keep this policy under regular review and may update it from time to time, so we recommend that you check it regularly.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your interactions with the Trust.

Third-party links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

Contact us (including complaints)

If you have any questions or concerns (including complaints) about this Policy or about the way in which your personal information is being used please let us know by contacting us in the following ways:

by email: info@royalanniversarytrust.org.uk
by post: The Royal Anniversary Trust, Sanctuary Buildings, 20 Great Smith St, London SW1P 3BT.

You are entitled to make a complaint at any time to the Information Commissioner’s Office, the UK regulatory authority for data privacy (https://ico.org.uk/global/contact-us/). We would be grateful for the opportunity to resolve your concerns before you approach the ICO, so we recommend that you contact us in the first instance.