Active Schools – Privacy Policy

Policy Owner: Wendy Newton / Sarah Williams

Frequency of review: Annually unless management or legislation require it sooner.

About Us

The Active Schools team is a sub team within Active Surrey, who are the Active Partnership for Surrey. We are hosted by Surrey County Council (SCC). This privacy policy explains how we use any personal information we collect about you as a school user (typically via our website), as required under the General Data Protection Regulations (GDPR).

The Active Schools team organise, deliver, and manage programmes and events including but not limited to the Surrey School Games, Surrey Youth Games and Wellbeing Warriors, as part of our remit to promote physical activity across the county.

The Active Schools team’s work is mainly funded by Sport England (SE) and Department for Education (DfE) and overseen nationally by the Youth Sports Trust (YST). (Reference is also made below to AfPE (Association for Physical Education).)

What the Policy covers

This privacy policy covers the use of pupils’ names and other personal data (including their images) in the Surrey School Games (local and county sports events); other Active Surrey programmes (such as Active Schools Movement); and Leadership opportunities for pupils.

Leadership opportunities can include First Steps to Leadership; Sports Crew; Gifted and Talented (G&T) Academy     [List correct as at Nov 2022]

It also covers the use of adults’ data for programmes, and events such as networking conferences, Active Schools Membership and KS1 Star Mark applications. It does not currently cover teacher training provided as part of our CPD offer which is addressed by a separate privacy notice available upon request or when booking training.

Our legal basis for processing data

Legally, organisations can process personal data on six bases, any one of which may apply depending on the service you access. We may process your or your pupils’ personal data where:

• Consent has been given to the processing of personal data for one or more specific purposes – for example acknowledgement of parental permission for photography purposes at an event
• It is necessary for the performance of a sale or contract - such as an event booking, Active Schools membership or Star Mark application.
• It is necessary for compliance with a legal obligation to which we are subject
• It is necessary in order to protect your vital interests - such as providing emergency first aid at our events which take into account individuals’ needs; or conferring membership for the school of the YST or AfPE if you become an Active School member.
• It is necessary for the performance of a task carried out in the public interest
• It is necessary for the purposes of our legitimate interests, including reporting of anonymised statistics to our partners (such as YST, SE and AfPE) except where your data rights or those of a child over-ride this.

Information we collect

Pupils / Young People

We may collect school name, year group, gender, ethnicity and special educational needs & disability details depending on the requirements of the programme / event.

We will collect pupils’ initials and full surname, which will be linked to consent for photography and consent for first aid to be administered or passed to ambulance / other medical staff, alongside details of pupils’ medical conditions (based on existing records held by the school). Information should be provided prior to any event.

Active Surrey’s Photography Policy, designed to safeguard participants, can be viewed upon request. The Policy is also referenced at the point when such consent is sought. Photographs or video may be used by Active Surrey in promotional materials,

the press or on our website or social media. Images may also be shared with partners named in ‘How we use the information we hold and who we share it with’ below.

Some Inclusive events may ask for further details regarding their specific education need and disability grouping of pupils, to ensure their needs can be met.

Details of young people taking part in Leadership events (including name) will be used for tracking individuals’ progress through the programme.

Further anonymous feedback may be collected from pupils via surveys - either face to face or in group sessions - to help evaluate and improve the experience and event.

By definition none of this information will be able to be traced back to a specific pupil.

Teachers / other adults:

We will collect teachers’ / school staffs’ name and work contact details. This is for:

1. Communication with designated lead teachers over participation in events / programmes; to manage attendance at events; or handle lost property.
2. Attendance and communication relating to teacher-centred events such as networking sessions and conferences. Further details on dietary requirements or access needs may be requested at time of booking for these events.
3. Communications relating to your school’s Active Schools membership or KS1 Star Mark if applicable.

Anonymous feedback may be collected via email or survey, either face to face, online or in group sessions to help evaluate and improve the experience / event.

We may collect information when you voluntarily complete other customer surveys or when schools agree to take part in case studies / publicity.

As is the case with other websites or social media owners, we collect usage information via cookies when you engage with us online. For more information, please see our cookie policy - https://www.activesurrey.com/Policies/Cookies

Third party (external) systems we use

In addition to the secure IT system provided for us by our host organisation (Surrey County Council) on which your / pupils’ data may be held, we use a number of third party systems to help us collate, store and manage data. These include:

• • Capsule (a CRM system for recording ‘business to business’ contact information and correspondence)

• • Mailchimp (a mailing app, typically used to send e-newsletters)
  • Bookwhen (a platform for schools to book onto events and courses)
  • Microsoft Forms (for data capture relating to programmes including Sports Crew and G&T Academy and occasional, one-off or short-term surveys
  • Survey Mechanics (a platform for more complex surveys such as KS1 Star Mark applications)
  • Rider HQ (typically used outside of a school setting to record anyone associated with the Surrey Youth Games)
  • Your School Games, a website containing a password-protected dashboard (into which data may be added by us, Youth Sport Trust or Sport England)

No third party provider has permission to use or share your information for their own purposes. For further details and to access the individual privacy policies please click on the links above.

How we use the information we hold and who we share it with

We may use the information provided on pupils / young people to:

• • • Allow individuals to participate in a Surrey School Games, Leadership or other event / programme. Non name-specific details of pupils with special needs or access requirements may also be shared with the relevant event deliverer or venue pre-event to ensure the right equipment is provided and individuals can participate safely.
    • Obtain further information on some young people if the events they are entering have additional entry criteria to ensure eligibility.
    • Track the progress of named young people involved in our Leadership programme. This will be shared with the individual’s school if requested.
    • Record permission for photos and videos to be taken at Surrey School Game events or training etc organised by Active Surrey. Name, school and record of consent / non-consent may be shared with official photographers and event deliverers to help ensure those without permission are not photographed.
    • Confer permission for basic first aid to be administered at an event. If further treatment is required additional pupil information (name, school, medical history and SEND details) may be shared with medical, venue or emergency staff.
    • Share information with a third party deliverer for events that Active Surrey staff help organise but are not attending.
    • Ensure any event does not breach the maximum number of participants.
    • Help with the safeguarding of pupils in ways not already covered above.
    • Complete anonymised, summary reports for Sport England, Department for Education, Youth Sports Trust, and the Department for Digital, Culture, Media & Sport on those taking part in the School Games programme.

• • • Publish anonymised information (survey results, summary reports, case study details or images from events) online and in print. Such non-sensitive information may also be shared with those listed in the bullet above plus partners including but not limited to Surrey County Council, Borough and District councils, Public Health, National Governing Bodies of sport, other Active Partnerships and event deliverers who run events on our behalf.

We may use the information provided on teachers or other school staff to

• • • Communicate with you about Surrey School Games, Leadership events and other programmes which your pupils are involved in.
    • Send you information on upcoming events such as pupil Leadership opportunities, or other updates relating to PE, school sport and physical activity / programmes from us or our partners.
    • Manage your attendance at events such as networking sessions and conferences. This could include details of dietary or access requirements which will be shared with the venue.
    • Provide you with / request further information relating to your school’s Active Schools membership if your school decides to join. This will include sharing designated contact details with the Youth Sport Trust and the Association for Physical Education to give your school membership of those organisations. YST and AfPE use this information to add members to e-news communications, training and resource opportunities. When you register to be an Active Schools member, please indicate if you do not wish to join these professional organisations.
    • We will also share the information with Surrey Outdoor Learning and Development (SOLD). They will use your data to offer training and resources to AS member schools directly as part of their packages, provided you agree by ticking the relevant box on your application.
    • Process or request further information for any Star Mark application your school makes (KS1 only).
    • Include your school – with your consent – in online or printed pieces such as case studies, news pieces or reports. These may be shared publicly or with partners including but not limited to Surrey County Council, Borough and District councils, Public Health, National Governing Bodies, other Active Partnerships and event deliverers who run events on our behalf.
    • Administer training or events that Active Surrey staff are not delivering directly: teachers’ contact details and other relevant information may be shared with the deliverer which could include YST, Sport England, SOLD, Create Development, sport National Governing Body or other provider.

Active Surrey will not share or sell your contact information for marketing purposes with any third party organisation unless expressly stated.

How long we hold the information you provide

Newsletters and other email updates will continue until you unsubscribe. Identifiable (name, full address, email and phone number) data for Business-to-

Business correspondence is kept within the Capsule CRM System. This is held for no more than 3.5 years, after which point it is deleted on a 6-monthly cycle.

Details of teachers attending conferences, network events, forums etc will be kept for 3 years.

Photographs / videos along with photography permission will be kept for up to 4 (calendar) years.

Anonymised participant data from School Games (with all names, school names and medical details removed) will be kept for 3 years for evaluation and analysis purposes.

Details of pupils who take part in any of our Young Leaders training will be kept for 4 years to enable us to track progress and feedback to pupils’ schools if requested.

Active Surrey is required to retain details relating to any medical or safeguarding incidents or accidents that occur as part of any Active Schools events for 3 years following the event date. Third party event deliverers and venues may have similar policies – please check with them in the case of any such incident.

Paper records of participants’ medical, disability and safeguarding data, shared with third party event deliverers and venues during the event will be securely destroyed within 5 working days of the event.

Active School Members will have their details kept for as long as they are a member school and for up to one whole school year following any revocation of their membership.

Submissions for KS1 Star Mark applications will be kept for 15 months.

Should you provide personal information to us on paper, we will store it securely in lockable storage until such time as we may upload it onto relevant system(s), at which point the paperwork will be securely destroyed. This may typically happen in the case of late registration data for School Games events, in which case paper forms will be securely destroyed within 7 days.