VAS Privacy Notice: Sheffield Healthy Holidays

Who we are
Sheffield Healthy Holidays (SHH) is part of the Holiday Activities and Food (HAF) programme funded by the Department for Education (DfE) and is co-ordinated in Sheffield by Voluntary Action Sheffield (VAS). For the purpose of data protection legislation, the DfE and VAS are both data controllers of personal data collected about you and your child. The DfE have a separate privacy notice which can be found at sheffieldhealthyholidays.org/privacydfe

VAS may securely share your data with a data processor in order to carry out some of the tasks outlined below. The data processor will have access to your data solely for the purposes outlined below, and once the work has been completed and securely returned to VAS, the data processor will remove all personal data relating to SHH from their systems.

How we will use your information
Your SHH local provider collects and uses personal information in order to run the holiday activities and food programme. Data is also collected to provide information about which groups of people are accessing the services in order to determine if we are reaching those most in need.

Personal information collected by your SHH local provider about you and your child is passed to your local Healthy Holiday Hub and VAS. Where activities and food are   provided directly by the local Healthy Holiday Hub, the information will be passed directly to VAS. The data will then be summarised.

The summarised information itself does not contain any personal data from which you or your child can be identified. The summarised information is then securely shared by VAS with the DfE in order for them to understand the uptake of holiday activities and food provision in your area and how public money has been spent to help improve provision.

This enables analysis of the longer-term benefits of participating in holiday activities and food projects.

The nature of your personal data being used
The personal data collected by your SHH provider will include

  • a minimum of personal data to identify attendance numbers (this might include for example name, address, date of birth and school attended to identify the number of unique attendees)
  • self-declaration of Special Education Needs
  • self-declaration of Free School Meals entitlement
  • ethnicity and gender (this will be anonymised and used to inform future projects in Sheffield)
  • an e-mail address if you are happy to be contacted for evaluation purposes and receive further information about the SHH programme.

When the data is summarised by VAS, names and other identifiers are removed to prevent identification of individuals from the summarised information.

Why our use of your personal data is lawful
In order for the use of the personal data to be lawful, it needs to meet one (or more) conditions in the data protection legislation.

The legal basis for VAS and DfE processing the personal data is Article 6(1)(e) of the General Data Protection Regulation (GDPR) where “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the [data] controller”.
The processing of special category data is necessary for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment between persons as permitted under Article 9(2)(j) of the GDPR. This is with a view to enabling such equality to be promoted or maintained and is carried out with appropriate safeguards for the rights and freedoms of data subjects.

How long your personal data will be kept
Your personal data will only be retained as long as necessary in order to run the Sheffield Healthy Holiday scheme and to supply DfE with the necessary summarised information. When your personal data has been securely destroyed by the local providers, Healthy Holiday Hubs and VAS, VAS and DfE will retain the remaining non personal data for research and analysis purposes.

Your data protection rights
Under certain circumstances, you have the right:

  • to ask us for access to information about you that we hold
  • to have your personal data rectified, if it is inaccurate or incomplete
  • to request the deletion or removal of personal data where there is no compelling reason for its continued processing
  • to restrict our processing of your personal data (i.e. permitting its storage but no further processing)
  • to object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics
  • not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you

If you need to contact DfE regarding any of the above, please do so at:
HAF.programme@education.gov.uk. If you need to contact VAS, please do so at: info@vas.org.uk.

Further information about your data protection rights appears on the Information Commissioner’s website at:
https://ico.org.uk/for-organisations/guide-to-data-protection/principle-6-rights/.

Last updated
We may need to update this privacy notice periodically so we recommend that you revisit this information from time to time. This version was last updated on 9 September 2020.

Contact Info:
If you have any questions about how your personal information will be used, please contact us at HAF.programme@education.gov.uk or info@vas.org.uk. To contact the DfE’s Data Protection Officer (DPO) please contact us via gov.uk (https://www.gov.uk/contact-dfe) and mark it for the attention of the ‘DPO’.