Date of last review: September 2024
Summary
At Community Senior Letters (“CSL”), we are committed to respecting and protecting the privacy of all individuals and institutions that engage with our services. This Privacy Policy outlines the types of personal data we collect, how we use and store this data, and your rights concerning it. Special provisions are made regarding images of pupils, ensuring that parental consent is obtained where necessary.
1. Data We Collect
CSL collects and processes the following categories of personal data:
- School Information: Including, but not limited to, the name of the school or educational institution, Unique Reference Number (URN), school address (including postcode), contact emails and phone numbers, and names of primary and secondary contact points within the school.
- Primary Contact Information: Names, email addresses, and any relevant communication history between Primary Contacts and CSL team members.
- Participation Information: Information related to the number of pupils participating in the program, any previous involvement with CSL, the name and address of the care home a school wishes to be paired with (where applicable), and any materials requested by the school to assist with pupil participation.
- Images: Photographs or other visual media provided by schools featuring pupils, staff, or activities related to the CSL program, used with consent for promotional purposes.
- Parental Consent: Where images or identifiable information about pupils are provided by schools, confirmation of parental or guardian consent must be obtained by the school before submission to CSL. CSL assumes that all such submissions are made in compliance with applicable consent requirements.
2. Legal Basis for Data Processing
CSL processes personal data based on the following legal grounds:
- Consent: For processing images or personal data provided for promotional purposes, explicit consent is required. Schools are responsible for obtaining and confirming parental or guardian consent before providing such data to CSL.
- Contractual Necessity: Certain personal data is required for CSL to fulfil its obligations in running the letter exchange program, including facilitating communication between schools, care homes, and volunteers.
- Legitimate Interest: We may process school and volunteer contact details and participation information based on our legitimate interest in managing and improving the CSL program.
3. How We Use Your Data
CSL processes personal data for the following purposes:
- To coordinate the exchange of letters between schools, care homes, and volunteers.
- To manage correspondence with schools and care homes, ensuring the smooth operation of the program.
- To track participation and maintain records of program involvement, including commitments made by schools to send letters.
- To use images and other promotional content, with appropriate consent, in CSL newsletters, on social media, or on the CSL website to raise awareness and promote the program.
- To provide educational materials, presentations, and resources to schools to assist them in explaining the CSL process to pupils.
4. Handling of Images and Parental Consent
- Use of Images: CSL may use images provided by schools, including photos of pupils, staff, and program-related activities, for marketing and promotional purposes. These may be published in CSL newsletters, social media posts, or other digital and print media.
- Parental Consent: Schools must obtain parental or guardian consent for any images of pupils submitted to CSL for promotional purposes. CSL relies on the representation by schools that they have obtained the necessary consent and will not be held liable for any failure to secure such permissions.
- Withdrawal of Consent: If consent for the use of an image is withdrawn by a school or parent/guardian, CSL will cease further use of the image and remove it from future publications. To withdraw consent, please contact CSL at the contact information provided below.
5. Data Sharing and Disclosure
We do not sell, trade, or otherwise transfer personal data to third parties, except where required for the operation of the CSL program. Personal data may be shared with:
- Authorised CSL team members: Team members who need access to specific data to perform their duties, including communicating with schools, care homes, and volunteers.
- Primary Contacts: Limited data (e.g., the name of the school and care home) may be shared with volunteers as necessary to facilitate letter exchanges. Personal contact details of schools or care homes will not be disclosed to volunteers without consent.
- Legal Requirements: CSL may disclose personal data where required by law or in response to a valid request by public authorities (e.g., a court or government agency).
6. Data Security
CSL takes data security seriously and implements appropriate technical and organisational measures to protect personal data against unauthorised or unlawful access, alteration, disclosure, or destruction. These measures include secure data storage, restricted access to personal data, and regular reviews of our security protocols.
7. Data Retention
We retain personal data only for as long as is necessary to fulfil the purposes outlined in this Privacy Policy or as required by law. Personal data related to program participation may be retained for historical or record-keeping purposes, while data such as images may be retained for promotional use until consent is withdrawn or the data is no longer required.
8. Your Rights
Under applicable data protection laws, you have the following rights:
- Right of Access: You have the right to request a copy of the personal data we hold about you or your institution.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
- Right to Erasure: You may request that we delete your personal data when it is no longer necessary for the purposes for which it was collected.
- Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests or consent.
- Right to Withdraw Consent: Where we process personal data based on your consent, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us at legal@communityseniorletters.com and cc’ ryan@communityseniorletters.com
9. Changes to This Policy
CSL reserves the right to modify or update this Privacy Policy at any time. Any significant changes will be communicated to schools and care homes, and the updated policy will be made available on our website. Your continued participation in the CSL program after such changes constitutes your acknowledgement of the updated policy.
10. Contact Us
If you have any questions or concerns regarding this Privacy Policy, or if you wish to exercise any of your rights, please contact us at:
Community Senior Letters
FOI of Hetty Ekbery/Andrew Copeman, Ryan Khodja
Latymer Upper School
King’s Street
W69LR
Email: legal@communityseniorletters.com
Mobile: 07448200161