Privacy Policy

How We Use Your Information 

Privacy Notice for Alumni

If you have come to this page because you want to access your preferences centre please visit your profile on alumni.glion.edu or use the unsubscribe link in e-mails we send to you.

Background

Upon graduation, you become a member of the Glion alumni community and you are invited to activate your account on the alumni online platform where you can easily keep in touch with your fellow Glion alumni and manage your interactions with the School.

This notice is to help you understand how and why the School and in particular, our Alumni Engagement Team (AET) collect your personal data and what we do with it. It also explains the decisions that you can make about your personal data.

“We” or the “School” means Glion Institute of Higher Education including all individual campuses that are operated under the Glion Institute of Higher Education name. 

What is "personal data"?

Personal data is information that School holds about you and which identifies you or could identify you when combined with other data which the School either holds or is likely to obtain.

We may collect the following types of personal data about you:

• your title, name, gender, date of birth;
• your education record (i.e year of study and degree details). Qualifications from other universities may also be held; 
• your contact information (address, telephone, email, social media);
• your business details including positions, organisation, professional memberships and qualifications;
• your career highlights and other lifetime achievements;
• your outside interests and membership of groups;
• information from articles in the media about you;
• events you have been invited to and whether or not you have responded or attended;
• your donations of time, expertise or money;
• we will keep a record of interactions with you for future reference and to help tailor further communications with you (including history of requests sent to the School (campus visits, copy of transcripts, assistance to connect/network with 3^rd parties and history of contributions offered to the School such as donations, testimonials, opinion surveys etc); as part of this, some emails sent by the School may record whether the email has been opened and whether any links have been clicked on;
• any preferences provided by you for a specific purpose such as access requirements or other adjustments and dietary preferences for event management purposes and your communication preferences;
• photographs – including those we have taken (for example, at events or to accompany a published interview) and those which are in the public domain.
• bank details and other financial information, if you make any payments to the School.

The examples provided are not all-inclusive. School may also collect similar or related information and generally information that you have decided to share with us.

We will never directly collect personal data of others (e.g., family). If you provide us with such personal data you have the obligation to ensure they have granted consent to provide such personal data to School.

As with most websites certain actions you take will be recorded anonymously as cookies by the Alumni online platform including history of your connections and pages clicked/visited, history of the data/settings you change on your profile, history of your online posts (job offers, messages/chat, comments, others). Please see the Alumni platform website for further information on Cookies.

Where does the School get your personal data from?

A significant proportion of the information we hold on you is that which you provide to us. Some have been transferred from your student record (transfer from the School's student central and local databases to the alumni database upon graduation). We also collect information from you for example when you:

• activate your account on the alumni online platform;
• provide information through one of our websites for example via https://alumni.glion.edu;
• complete and return surveys or response forms such as GoogleForms opinion surveys (e.g. “Your opinion on our new website”, “Tell us what you think about Glion”);
• register to attend an alumni-related event;
• give us any info via email or other messaging channel, e.g. LinkedIn, Facebook, WhatsApp, SMS, phone calls etc.

We may also obtain personal data regarding you from third party sources such as organisations that assist us with pursuing our purposes described below, media articles, social networking posts or other public sources for example the world wide web. Internet searches also help us maintain the accuracy of the data listed above.

How and why does the School collect and use your personal data?

All such data will be processed in accordance with applicable laws and regulation and the School Data Protection Policy as amended from time to time in order to maintain an engaged alumni community.

In general terms, we process your personal data to improve your experience and engagement with the School as a member of our alumni community. The purposes for which we may use personal data we collect include:

• Administration
• to provide alumni email account;
• to verify an account and provide a personalised experience for you when you activate your account on the alumni online platform;
• event registration and organisation;
• to process and organise any volunteering activity you have agreed to undertake;
• to process information you provide for use on other Schools websites;
• to keep a record of communications between you and us;
• Volunteering 
• schemes to encourage people to enter higher education and student recruitment activities;
• internships and careers support for students and graduates;
• guest Lectures on campus
• mentoring;
• Fundraising
• improvements to the School's structure and facilities and student activities;
• scholarships for our students;
• Sharing memories: when meeting with alumni we sometimes share 'pass lists' which detail the first name, surname, degree and classification for other individuals who graduated from the same course in the same year. These lists are used to remind alumni about their student days; enabling them to reminisce. The information can also help the School to make contact with alumni we may have lost touch with. Individuals with whom the lists are shared are asked if they are in touch with anyone on the list and, if appropriate, asked to approach these individuals to establish if they would like to receive communications from the School.
• Reunions: on occasion members of the alumni community host reunions. To help the organiser establish who to invite the School provides some information including details of alumni from a selected year group and course, as requested by the organiser. Details provided include first name and surname (as it appears on the School’s alumni database), degree, course and year of graduation. Details usually indicates who the School is in contact with and who is deceased. 
• Market research and survey: we may commission third party agencies to ask you about your preferences on communication, the types of events or brand partnerships you would like to see etc.
• Research: to ensure that we do not make inappropriate requests in our fundraising and volunteering communications, we may carry out research to assess your likely ability and willingness to make gifts to or volunteer for the School. This research may include collecting and storing data relating to you that is in the public domain (such as career history, directorships, shareholdings and remuneration) as well as data that has been provided by you, including your interests, and School activity you have previously been involved with (donations, volunteering, event attendance etc.) This research is sometimes known as prospect research. This process allows the Alumni Engagement Team to use its resources efficiently and guard against unnecessary contact.
• Profiling and planning: we use your data (such as your postcode, subject of study, age, gender, employment details and level of engagement with the School) to help us plan our activities, and determine if we should contact you with certain communications, or information about particular activities. It helps us identify how our alumni are involved with the School, and which alumni activities are most popular. This research helps ensure our communications (including fundraising or volunteering requests) are relevant and of interest to you.
• Automated decision making: the Alumni team use various modelling tools that will automatically process your data to assess the likelihood of you being able to make a donation to the School or of becoming involved in alumni activities. 
• Due Diligence: please note that if you wish to make a gift to the School we may process your personal data, including information from the public domain, for due diligence purposes, in accordance with our then current policies.
• We will from time to time communicate with you by email, post and telephone to pursue the purposes mentioned above. In particular we regularly communicate with people for the following purposes:
• share news about the School (including its services and programs) and our alumni (including promotion of discounts and services for alumni from our “benefit program”);
• share updates or news from fellow alumni and/or the Alumni Association of Glion, 
• share relevant/exclusive study opportunities or job offers; 
• share contact requests from other alumni mainly for networking or career tips;
• invite you to events and reunions;
• invite you to support our fundraising activity;

invite you to volunteer for the School. This includes providing advice and guidance and giving support to students during their time at School and in their career including by offering position in the company you work for 

From time to time we will ask you to confirm your contact details and communication preferences. However, you can also manage your communication preferences online at any time on your profile page of the alumni online platform (https://alimni.glion.edu/alumni/portal2/profile). 

Our legal grounds for using your personal data

Contractual commitment

The School has made a contractual commitment to students, as lifetime members of the School, to provide services and activities for alumni. The School regards these services as an important and integral part of the School's long-term commitment to its students.

Therefore, the School will be processing data often on the basis that it is necessary to enable it to meet its contractual commitments to alumni.

Legitimate interest

Certain activities are also necessary for the purposes of the legitimate interest of the School and other third parties, including current students. Legitimate interests of the School and third parties focus around supporting educational activities and ongoing developmental activities for School alumni and others.

Where we have legitimate interests in processing your data, we will carry out a ‘balancing test’ to make sure our processing does not infringe your interests, rights and freedoms. We will only use the data in ways that you would reasonably expect. For instance, we have a legitimate interest in analysing the composition of our alumni group to help us decide what events or activities to run and in notifying you of alumni events we think you’ll be interested in.

Consent

Where any of these legal bases do not apply, your consent to process your personal data will be sought. If we ask for your consent to use your personal data you can take back this consent at any time. Any use of your personal data before you withdraw your consent remains valid.

Also, please note that the School will be processing some of your data because you have clearly made it publicly available, in particular on the internet.

Sharing information with others

For operational reasons and as is necessary and proportionate for intended purposes, School may share your information with other entities part of the Sommet Education Group. Within the School and the Sommet Education group, your data is shared with only those staff who need access for the purpose of delivering alumni activities.

For the purposes referred to in this privacy notice and relying on the basis for processing as set out above, we may also share your personal data with certain third parties: 

• the Alumni Association of Glion (AAG) which helps manage events that you attend or determine publications that you receive and that similarly we support in their own activities;
• other alumni: if you have activated your account on the alumni online platform, you can select what personal information will appear in your profile. 
• students, alumni, educational counsellors and potential employers: we facilitate communications with you, but in doing so we do not release personal contact details without prior permission Similarly if you want to get in contact with a former classmate we may be able to send a message to them on your behalf but will be unable to share their details with you;
• crime prevention or detection agencies (e.g. the police,); We may also need to share information with our legal advisers; 
• third parties conducting surveys: such organisations will use your details only for that purpose, and will then delete them. There is not requirement for you to take part in any of these surveys but participation assists the School, in offering you the best possible experiences in terms of career services, online services, assistance for networking, technical support, exclusive events and exclusive deals at partner companies.
• contractors, suppliers, agencies, or any other parties acting on School’s behalf (collectively, “External Parties”) where there is a legitimate reason for their receiving the information, including third parties who are contracted to provide services for us (for example mailing houses, event venue providers or EnterpriseAlumni, our online alumni community platform) and agent or students volunteers contracted to the School for alumni-related projects.
• School contractually requires External Parties processing alumni personal data on behalf of the School to follow this policy, whether they are utilizing School’s and/or their own electronic systems and data management tools. School employees are responsible for ensuring that any External Parties they work with in support of School operations comply with this policy. We make sure we have appropriate contracts in place with them.
• There might be certain situations where you will share personal data directly with service providers associated with School, where School does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such providers. In particular, the Alumni online platform may contain links to other websites. We are not responsible for the privacy practices and/or the content of such websites. 

We also want you to know that the School will never sell your personal data.

Sending information to other countries

Some of the personal data we process about you may be transferred to, and stored at, a destination outside Switzerland or the European Economic Area ("EEA"), for example where it is processed by staff operating outside the EEA or where personal data is processed by one of our suppliers who is based outside the EEA or who uses storage facilities outside the EEA. 

In these circumstances, your personal data will only be transferred on one of the following bases:

• a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; 
• the transfer is subject to one or more of the "appropriate safeguards" for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission); or
• there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).

How Do We Secure your personal data?

We implement appropriate physical, administrative and technical measures designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access or use, and all other unlawful forms of processing.  

School contractually requires that External Parties provide equivalent levels of protection when handling your personal data and only process the data in accordance with our instructions.

For how long do we keep your personal data?

We see being part of the alumni community as a lifelong relationship. Generally, the School will look to retain alumni personal data until the individual asks us to remove it from our records. We will routinely remind you of your right to have us remove your personal data.

If you decide to exercise your right to erasure or that you no longer wish to receive communication from the School please be aware that we still need to retain a minimal amount of personal data to maintain your academic record for archive purposes and ensure we do not contact you inadvertently.

What decisions can you make about your personal data?

School makes reasonable efforts to ensure that your personal data is reliable for its intended use. However, you are equally responsible for updating and checking the accuracy of the information provided to School. You can do this through the online platform at https://alumni.glion.edu.

Moreover, you are able to make various decisions about your personal data. Your rights are as follows:

• to obtain access to, and copies of, the personal data that we hold about you; 
• to require that we cease processing your personal data if the processing is causing you damage or distress;
• to require us not to send you marketing communications anymore;
• to require us to correct the personal data we hold about you if it is incorrect;
• to require us to erase your personal data; 
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
• to receive from us the personal data we hold about you, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Please note that:

• the above rights are not absolute, and we may be entitled to refuse requests where legal exceptions apply; 
• information request will be fulfilled free of charge unless in case of repetitive, manifestly unfounded or excessive requests or for further copies; and
• where our processing of your personal data relies on your consent and where you then withdraw that consent, it may affect the provision of the services.

Further information and guidance

School reserves the right to modify this notice as needed, for example, to comply with changes in laws, regulations, School practices and procedures, or to respond to new threats or new requirements imposed by data protection authorities. Please just visit this page if you want to stay up to date, as we will post any change here.

If you have questions about your personal data, contact glion@alumni-support.com or email the Data Protection Officer at: dpo@sommet-education.com 

If you are not satisfied with how we are processing your personal data, you can make a complaint to the relevant data protection authorities.

Last update: October 2019