Leeds City Council
Healthy Holidays Leeds Programme Privacy Notice
We are implementing a booking and eligibility checking system for the Healthy Holidays programme in Leeds, which is funded by the Department for Education (DfE) Holiday Activity and Food (HAF) Programme.
The programme provides food and activities to Free School Meal eligible children and young people over the Easter, Summer, and Christmas holidays.
The data controller for this project
Leeds City Council is the Data Processor and will collect and process all personal data you provide to us on behalf of the Department for Education as part of the project. The programme will be delivered by individual providers under the terms of the Funding Agreement between the provider and the Council. In delivering the programme, the providers will act as data processors for Leeds City Council.
The data we will collect
You will be asked to provide the following information:
- Your child’s personal details, including full name, date of birth/age, address, gender, ethnicity, medical history, allergies, Special Educational Needs (SEND), behavioural information and school they attend.
- Eligibility for benefits related free school meals (SEND or another Vulnerable Group)
- Emergency Contact Information
- Your personal details, including full name, address, telephone number, national insurance number and email address.
- If you provide consent, the holiday camps you attend may use your child’s photo in publicity such as on social media, websites and newsletters. If you do not provide consent, your child’s photo will not be taken.
Why we process your data
We will use the data collected about you/your child to:
· Book your child onto the selected session or programmes.
· Ensure that your child’s needs are met during the session.
· Ensure that your child is appropriately safeguarded during the session.
· Ensure eligibility for the programme.
Certain information such as name and contact details are mandatory. Should you decide not to provide any of the information we request, you will be unable to book onto any of the sessions.
All the data collected during the project will be treated in strict confidence and in accordance with the requirements of the Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR). The data provided by you will not be used for any purpose, other than this project.
Lawful basis for processing
We will process your data based on your consent in accordance with UK GDPR Article 6(1)(a) and 9(2)(a). The processing shall be lawful only if and to the extent that the following applies:
- Article 6(1)(a) - the data subject has given consent to the processing of their personal data for one or more specific purposes;
- Article 9(2)(a) – Processing of special categories of personal data. The data subject has given explicit consent to the processing of personal data for one or more specified purposes - data, such as allergy or dietary information, to ensure that your child will be appropriately safeguarded at the session.
Withdrawing your consent
You have the right to withdraw your consent from participating in the project at any time. Withdrawing your consent will not affect any services or benefits you receive otherwise. If you decide that you no longer wish to participate in the project, please contact us on the contact details provided in this notice.
Data retention, storage, and destruction
Our data retention policies and procedures are designed to help ensure that we comply with our legal obligations in relation to the retention, storage, and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary.
The council will retain your personal data as follows:
We will keep your personal information for three years after your child turns 16 (and is therefore ineligible to access the programme). We will remove your child’s details from the system if they have not been active on the system for 3 years.
The reason for keeping information for this period is to be in line with Limitation Act 1980 in case of any potential claim against the Council.
If you get in touch to opt-out of the project, we will treat this as withdrawal of your consent and will plan to delete your personal data.
Who we can share your data with
To enable us to provide our service to you we will, where appropriate, share your information with:
- Third party providers of the sessions you have booked on.
- Other Healthy Holiday providers who may be able to provide a service to you or your children, where we are not able to.
In addition, we will share your personal data:
- where such disclosure is necessary for compliance with a legal obligation to which we are subject
- to protect your vital interests or the vital interests of another natural person
- for the purposes of security and prevention of fraud and other criminal activity
- where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
Automated decision making
Your child’s data will be automatically checked against the Leeds Free School Meal database. If it doesn’t match, it will be manually checked against the database. If there is no match then, you will be emailed to confirm eligibility.
Your rights
Your principal rights under data protection law are:
- the right to access - you can ask for copies of your personal data.
- the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data.
- the right to erasure - you can ask us to erase your personal data.
- the right to restrict processing - you can ask us to restrict the processing of your personal data.
- the right to object to processing - you can object to the processing of your personal data.
- the right to data portability - you can ask that we transfer your personal data to another organisation or to you.
- the right to complain to a supervisory authority - you can complain about our processing of your personal data.
- the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects through the Information Commissioner's Office external link.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
When your data gets sent to other countries:
Your data will not be sent to other countries.
Contact us
Any enquiries in relation to this project should be forwarded to:
Leeds City Council
Amelia Gunn – Senior Policy Development Officer
Phone: 0113 3783597,
Email: amelia.gunn@leeds.gov.uk
Data Protection Officer
Aaron Linden
Head of Information Management and Governance - Data Protection Officer
Leeds City Council
Merrion House
110 Merrion Way
Leeds
LS2 8BB
DPO@leeds.gov.uk
The Council privacy notice is available to view Privacy notice (leeds.gov.uk)
Changes to this notice
We keep our privacy notice under regular review. We will notify you of significant changes to this notice by email or other means as appropriate. This privacy notice was last updated June 2024.