Fair processing notices - Fair Processing Notice - Stoke-on-Trent Holiday Activities and Food Programme (HAF)

How we use your data

How we use your personal information:

Stoke-on-Trent City Council has partnered with Eequ LTD as part of the governments Holiday Activity and Food (HAF) programme, to deliver activities and healthy meals during holiday periods to children and young people from reception to year 11 (inclusive), who are eligible for benefit related free school meals.

Eequ is an online booking system, that will be used to help us and The Hubb Foundation to coordinate and manage our HAF programme within Stoke-on-Trent. The Hubb Foundation have their own Privacy Policy that can be found on their website – https://www.thehubbfoundation.com/privacy-policy/

At Stoke-on-Trent City Council we take your privacy seriously and will only keep and use your personal information for reasons the law requires or allows. We are a data controller for the personal information we hold about you in relation to the HAF programme.

In order to provide the activities to you and your family, it is necessary for us to collect and hold personal information about you and your child/ren. Eequ will collect personal data from families and activity providers to ensure the smooth running of the programme. To comply with data protection legislation, we must be sure you understand how we will use this information.

Information collected from you will include:

  • Participant details including: name, gender, DOB
  • Parent/carer details including: name, and contact information
  • FSM Eligibility
  • Home Address
  • School
  • Special educational need or disability
  • Any health or other needs related to help keep children safe
  • Provider details

Stoke-on-Trent City Council and Eequ will handle personal data in accordance with the UK General Data Protection Regulation and Data Protection Act 2018 and other relevant legislation and will not disclose your data to any other third party, unless allowed or required to do so by legislation. For further details about the processing of your personal data please see the Council’s Data Protection webpage How we use your personal information | Stoke-on-Trent and Eequ’ s Privacy Policy Eequ Privacy Policy.

 

Who is processing my data?

All personal data held, is processed in accordance with data protection law. The Data Controller for the information outlined in this notice is Stoke-on-Trent City Council.

Eequ is working as a Data Processor and will process your information on behalf of the Council.

 

How we will use the information we hold about you?

We will collect information about you (where applicable) to:

  • Determine the eligibility of children for the HAF programme
  • Effectively manage and co-ordinate the HAF programme
  • Share any medical or personal data (e.g. food allergies, additional needs) to help keep children safe during activities
  • To contact you with service updates relating to the HAF programme
  • To monitor service delivery, ensuring it is meeting intended purpose and outcomes
  • To ensure timely and appropriate responses to safeguarding concerns and emergencies, enabling the protection of individuals from harm by having accurate, up-to-date information readily available for intervention and support

 

What is the legal basis for us to process your data?

This information processing is considered to be part of Stoke-on-Trent City Council’s public task. The processing and sharing of personal data in this way is required for the purpose of co-ordinating the HAF programme effectively, as outlined in the Department for Education (DfE) HAF guidance:

Department for Education HAF guidance

 

The legal basis for processing the data is in the public interest or in the exercise of official authority (Article 6.1e UK GDPR).

 

Who we will share your information with?

We may share your information with partner organisations, including:

  • Activity providers where parents/carers have signed their child/young person up to engage in an activity.
  • Council, voluntary and community groups to provide the support required.
  • Anonymised data will be shared with the Department for Education for the purpose of submitting the Holiday Activity and Food submissions, which are a requirement of the funding received by Stoke-on-Trent City Council.

 

We will not normally share your information with organisations other than our partner organisations without your consent, however, there may be certain circumstances where we would share without consent such as where we are required to do so by law, to safeguard public safety, and in risk of harm or emergency situations. Any information which is shared will only be shared on a need to know basis, with appropriate individuals. Only the minimum information for the purpose will be shared.

 

How long do we keep your records?

We will only retain your personal HAF data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of managing your HAF booking needs or DfE reporting requirements. We will retain your personal HAF data so that you can book future activities without the need to re-enter information. Data collected for the HAF programme during checkout will be kept until the Termination of the Data Processing Agreement in place with Eequ.

Eequ's Privacy Policy details how Eequ may retain your personal data for the purpose of using the booking platform for other non-HAF activities: Eequ Privacy Policy

All information will be held securely and destroyed under confidential conditions.

Who to contact if you have questions

Your rights:

You have a number of rights under data protection law, including the right to request your information and to request the information be amended or erased if incorrect.

If you wish to speak to us in relation to this service please contact commissioningandpartnerships.sp@stoke.gov.uk in the first instance.

If you want to exercise your rights under information law, please contact the Information Rights Team at foi@stoke.gov.uk or Information Rights Team, Floor 2, Civic Centre, Glebe Street, Stoke-on-Trent ST4 1HH or you can complete the online form on the Council's website: Feedback/Information Request Form | Stoke-on-Trent

If you wish to complain about how your personal information has been handled by Stoke-on-Trent City Council, please contact the Information Rights Team in the first instance using the details above. If you are not satisfied you can complain to the Information Commissioner’s Office at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Tel: 0303 123 1113 or you can visit their website at Information Commissioner's Office (ICO)

For any general enquiries you can contact the council by phone on 01782 234234, via email to enquiries@stoke.gov.uk or by writing to us at Civic Centre, Glebe Street, Stoke-on-Trent, ST4 1HH.

 

Providing accurate information:

It is important that we hold accurate and up to date information about you in order to assess your needs and deliver the appropriate services. If any of your details have changed, or change in the future, please ensure that you inform us as soon as possible so that we can update your records