Data protection policy 2.0

Wesley College Alumni – Data Protection Policy Approved by Wesley College Dublin Version: 1.0 Date: February 2026

1. Introduction Wesley College Alumni operates under the governance of Wesley College Dublin (“the College”). Wesley College Alumni is committed to protecting the privacy and personal data of its alumni, supporters, members and website users, and to complying with its obligations under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018 (Ireland) (“DPA”).

This Data Protection Policy explains how personal data is processed, protected and governed in the context of Wesley College Alumni activities, including the alumni website, which is currently hosted on the ToucanTech platform.

2. Scope This Policy applies to all visitors to the Wesley College Alumni website and to other cases where personal data is provided to Wesley College in the context of its Alumni activities. For example, this Policy covers applications for membership of our alumni community, attendance at Alumni events and interactions with donors and supporters.

This Policy is intended to bind all staff, volunteers and authorised representatives who process personal data on behalf of Wesley College Alumni.

3. Data Protection Principles The processing of personal data relating to Wesley College Alumni and its activities is required to comply with the principles set out in Article 5 of the GDPR i.e. Personal data shall be: a. Processed lawfully, fairly and transparently; b. Collected for specified, explicit and legitimate purposes; c. Adequate, relevant and limited to what is necessary; d. Accurate and kept up to date; e. Retained for no longer than necessary;

f. Processed in a manner that ensures appropriate security and confidentiality.

4. Lawful Basis for Processing Personal data is processed only where at least one lawful basis applies, including: a. Consent; b. Performance of a contract; c. Compliance with a legal obligation; d. Legitimate interests of Wesley College Alumni and Wesley College, provided those interests are not overridden by the rights of the data subject; e. Tasks carried out in the public interest.

It is incumbent on the relevant controller (whether it is Wesley College or any Wesley College Alumni foundation that may be established in due course) to ensure that the appropriate lawful basis is identified and documented for all processing activities. For example, Wesley College will usually rely on the legitimate interests’ basis to contact members of the Alumni community to inform them of activities likely to be of interest to them. However, anyone in receipt of such contact is entitled to opt-out of further communication by contacting Alumni@wesleycollege.ie in which case the College will record their contact preferences for future reference.

The ToucanTouch platform also allows individuals to manage their own consent and other privacy settings.

While Wesley College Dublin is currently the relevant controller of personal data held by it which relates to members of its Alumni community, if a separate foundation or other legal entity is established to manage Alumni matters, Wesley College will rely on the legitimate interests basis to share relevant personal data with that entity and that entity will thereafter abide by the provisions of this Policy.

5. Member Directories Members of our Alumni community may choose to appear in a secure online Alumni directory. Participation is optional and visibility settings can be managed by the member at any time. Information made available through member directories is for personal use only and must not be used for unsolicited commercial communications or shared with third parties.

Member Directories are only available to those who have registered and declared that they will comply with the Terms of Membership.

Wesley College is not responsible for any unauthorised use of member data by other Alumni or by third parties as those entities have their own legal obligations as independent controllers if they attempt to use the personal data for any purposes not permitted by this Policy.

5. Data Storage and Security Personal data is stored securely using the ToucanTech alumni management platform, in accordance with the Data Processing Agreement between ToucanTech and Wesley College. Appropriate technical and organisational measures are in place to protect personal data against unauthorised access, loss, alteration or disclosure.

If you are provided with access credentials to access the Alumni management platform, you are responsible for maintaining the security of those credentials as you, and not Wesley College, will be responsible for the activities undertaken on your account. If you believe your account has been compromised, please contact Alumni@wesleycollege.ie as soon as possible.

Access to personal data is restricted to authorised personnel who require access for legitimate operational purposes.

6. Data Retention Personal data is retained only for as long as necessary for the purposes for which it was collected, in line with Wesley College Dublin retention policies.

Alumni data is generally retained for as long as an individual wishes to remain engaged with Wesley College Alumni, subject to periodic review and any legal or administrative obligations.

7. Data Subject Rights Individuals have the right to: a. Access their personal data; b. Request rectification of inaccurate data; c. Request erasure of personal data; d. Restrict or object to processing; e. Data portability, where applicable; f. Complain to the Data Protection Commission (see dataprotection.ie).

Requests may be made using the contact details below and will be handled in accordance with GDPR requirements. Wesley College Alumni does not engage in automated decision making that produces legal effects.

8. Personal Data Breaches Any personal data breach will be assessed promptly. Where required by law, breaches will be reported to the Data Protection Commission and affected individuals without undue delay.

9. Review This Policy will be reviewed periodically.

Contact Details Dr Quentin Heaney Wesley College Alumni Wesley College Dublin Email: alumni@wesleycollege.ie Last updated: February 2022