Young person and their parent/guardian privacy notice

Introduction

The Jon Egging Trust (‘JET’) collects and processes personal data relating the young people it works with to enable the accurate administration, service delivery and tracking of students through the Blue Skies and Inspirational Outreach programmes. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

Who are we?

The Jon Egging Trust is a registered charity in England and Wales (1156265) and in Scotland (SC048666) and a company limited by guarantee (8908969). We are also registered with the Information Commissioner’s Office (ICO) ZA456145.

Our registered address is:
Acre House
11/15 William Road
London
NW1 3ER

What information do we collect?

We collect the following information via the JET Education Programme Enrolment Consent Form:
• Name, date of birth and gender of student
• Name of parent/guardian and relationship to child
• Address and postcodeName, date of birth and gender of student
• Home and mobile numbers of parent/guardian
• Email address of parent/guardian
• Emergency contact name, relationship and contact number
• Details of any medical conditions and medications
• Dietary requirements and food allergies

Images of young people may also be taken during Blue Skies programme and Blue Skies Inspire Package activities for their individual work record (portfolio) to be presented to them at the end of the programme and used for the graduation. Where consent is given, images may also be used by JET in the public domain to promote our work.

The following additional information is shared with JET by the school. We act as a data controller of this information. The terms of this arrangement are written into a Controller to Controller Agreement with the school.
• PPG (Pupil Premium Grant)
• LAC (Looked after child)
• SEND (Special Educational Need/Disabilities)
• Traumatic event
• Ethnicity/Nationality
• E2L – English as a second Language
• Service child
• Young carer
• Grades/achievement – on target/above/below
• Attendance (Blue Skies only)

How do we collect information about you?

We collect data by specifically asking for it on our enrolment form and from information provided by the school under the terms of our Controller to Controller Agreement with them.

Where do we store your data?

Data is stored on our IT system and specialist database on servers based inside the European Economic Area (EEA). The member of staff working directly with the young people keeps a paper copy of emergency contact and medical details to take to sessions in the event of an emergency. This is destroyed at the end of the programme.

Why do we process personal data?

We have a legitimate interest in processing personal data related to the young people enrolled on our programmes and their emergency contacts. Processing data on our young people allows us to:
• Maintain accurate records for administrative, operational and service development needs
• Keep students safe by being aware of food allergies, medical details and emergency contact details
• Assess the quality and impact of our services
• Support student learning
• Monitor and report on student progress

We also have a legitimate interest in processing the information shared by the school as this information allows us to access funding for programmes where we are able to demonstrate that we are working with particular target groups of children. It also allows us to report on the impact of our work.

We also have a legitimate interest in taking images of young people on our programmes as part of the assessment and documentation process. These images form part of a young person’s individual work record (portfolio) to be presented to them at the end of the programme. Images are not used in the public domain and copies held by JET are destroyed at the end of the programme. Parents/legal guardians may object to this processing based in legitimate interests by ticking the opt-out box on the Young Person Image Consent form.

Where we rely on legitimate interests as a reason for processing data, we have considered whether those interests are overridden by the rights and freedoms of the young people on our programmes, their parents/guardians and emergency contacts and we have concluded that they are not.

We process medical and health information to ensure the safety and well-being of young people on our programmes. As this is Special Category Data, the additional lawful basis for processing this is that the processing is necessary for the purposes of occupational medicine as well as preventative medicine and the provision of health care and treatment.

Ethnicity is also Special Category Data. The additional lawful basis for processing this is that it is necessary for archive, statistical and research purposes.

We ask parent/guardians for your consent to keep in touch with you after the programme has been completed as we would like to know about the progress and achievements of your child during and after they have finished school. You are under no obligation to provide your contact details or consent to being contacted. The telephone number(s) you provided as emergency contacts will not be used for this purpose.

We ask parent/guardians for your consent to take images (photos and videos) of your child taking part in activities on our programmes to be used in a range of materials to promote JET in the public domain.

You may withdraw your consent to be contacted or for JET to take and use images of your child in the public domain at any time by contacting us in writing: info@joneggingtrust.org.uk or The Jon Egging Trust, PO Box 17617, Redditch B97 9RU

We may also need to process data to respond to and defend against legal claims.

We will not use your data for any purpose other than those explained above.

Who has access to your data?

Youth programmes staff involved in programme delivery and staff involved in monitoring and reporting of outputs and service development (Area Directors and CEO) have access to the data. Staff in JET’s Operation Team have access to the database for operational reasons.

To ensure the health and safety of the young people, participant names and any relevant medical and/or dietary information may be shared with our delivery partners at their request, prior to any activities at their establishments. We have data sharing agreements in place with these establishments to ensure that data is stored securely, only used for the purpose of safeguarding the young people and is destroyed at the end of the programme.

Our IT support is provided by an external contractor (Rejuvenate). They have access to our document storage and email system only under staff supervision and with prior consent and only when it is necessary to troubleshoot IT operating problems. They have no direct or unsupervised access to personal data.

How do we protect your data?

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 authorised employees in the performance of their duties. We also have appropriate technical measures in place to ensure the security of your data.

We do not engage third parties to process personal data on our behalf.

How long do we keep your data?

When the young person has completed or leaves the programme, medical, parent/guardian and emergency contact information will be deleted before the start of the following academic year. Name, date of birth and details of participation in the programme (dates, location and nature of programme) will be kept indefinitely to allow us to maintain a record of individual participation in our programmes and offer a reference for young people who may request one.

Information shared by the schools will be anonymised once the young person reaches the age of 18 and they leave maintained education so that we may conduct analysis of our service users and programme impact and use this information to evaluate our programmes and access funding.

Where consent has been given to keep in touch with you after the programme has been completed, we will keep this information until you withdraw your consent.

Where consent has been given to take and use photos of your child in the public domain, consent continues with no time limit, unless consent is withdrawn. However, the majority of images are used for about five years. They are then moved into the image archive for possible future use. When consent is withdrawn, images of that child are deleted from the digital image library, archive and website. However, we cannot withdraw images already published in hard copy but we will not make any reprints of that publication/material containing images for which consent has been withdrawn.

Your rights

Under data protection legislation, young people and their parents/guardians have a number of rights. You can:
• Access and obtain a copy of your data on request (subject access request)
• Require JET to change incorrect or incomplete data
• Require JET to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
• Object to the processing of your data where JET is relying on its legitimate interests as the legal ground for processing
• Ask JET to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override JET’s legitimate grounds for processing data
• Complain to the ICO

If you would like to exercise any of these rights, please contact our Data Protection Lead:
• Email: info@joneggingtrust.org.uk
• Telephone: 0300 123 3044
• Post: The Jon Egging Trust, PO Box 17617, Redditch B97 9RU

If you have a concern or complaint about the way we are collecting or using yours or your child’s personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/

What if you do not provide personal data?

Certain information has to be provided to enable us to administer our programmes effectively and to ensure the health and safety of your child while participating in our activities. If you do not provide this information,
we are unable to enrol your child on our programmes.

Last updated 21/10/2019