ELP2.0 Participant Privacy Notice
ELP2.0 is funded by Climate Action Fund of The National Lottery Fund and the partnership is governed by a formal partnership agreement. Throughout this document ‘we’ ‘us’ and ‘our/ours’ refers to the Partnership between UpRising and SWT.
About this notice
UpRising Leadership (hereafter UpRising) needs to collect personal data about participants in order to deliver its programmes to young people and fulfil its charitable aims. We process your personal data in line with the requirements set out in the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
UpRising is a charity registered in England & Wales (registered charity no. 1149905; registered office 2nd Floor Central, 2.C.05, 35-47, Bethnal Green Road, London, E1 6LA). UpRising leads a partnership with Shropshire Wildlife Trust (registered charity no. 212744; registered office 193 Abbey Foregate, Shrewsbury, SY2 6AH) to deliver its Environmental Leadership Programme 2.0 funded by Climate Action Fund of The National Lottery Fund.
This privacy policy explains how we process personal data of prospective, applicant, current, and former participants (you/your). If you have any questions about how we use your personal data please contact us at [email protected] or by post at Data Protection c/o UpRising Leadership, 2nd Floor Central, 2.C.05, 35-47, Bethnal Green Road, London, E1 6LA).
We respect your privacy. We will always be transparent with you about how we process your personal data and ensure it is stored safely and securely. We never share your personal data with any third parties unless we are required to by law or in ways that help us to provide this service.
How we collect your personal data
We may collect your personal data in a number of ways, including:
- personal data provided by you when you complete an Expression of Interest Form
- personal data provided by you when you complete an Application Form
- personal data collected indirectly when you use our website
- personal data provided by you when you are accepted onto our programmes and complete an Information Form
- personal data provided by you when you participate in our programmes and complete Evaluation Forms before, during, and after the programme
- personal data provided by you when you give your consent to be interviewed and/or participate in focus groups for research and/or promotional purposes
- personal data collected indirectly in the form of visual content when you participate in our programmes (e.g. photos, videos, session recordings)
- personal data provided by you when you participate in our programmes and provide personal documents such as your CV
- personal data provided by you when you engage in our online tools and learning platforms, such as Mural, Notion, Zoom and Slack
- personal data provided by you after you have completed the programme when we ask you about your employment, education, and training status
Types of personal data processed
We may process the following types of personal data:
- your unique system IDs generated in our systems used to identify you
- contact details (e.g. name, email, telephone number)
- information about why you want to take part
- information about your CV support or coaching preferences
- demographic information about you (e.g. data of birth, gender) - including more sensitive data classified as special category data (see below)
- educational and background information about you (e.g. the type of school you attended, the occupation of your parent/carer when you were 14)
- information about where you live
- medical information relevant to your participation
- emergency contact details of a person(s) you nominate
- your responses in evaluations completed before, during, and after our programmes
- feedback on and the impact/reach of your Social Action Campaign (SAC)
- further details about your experiences on our programmes (e.g. in a focus group or interview)
- personal documents (e.g. CV) and your contributions during the programme (e.g. comments on Mural)
- visual content of you (e.g. photos, videos, session recordings)
- your employment, education, and training status before and up to 12 months after you take part in our programmes
During the course of the programme, we may also collect the following special categories of more sensitive personal data:
- your racial or ethnic origin
- your religious beliefs
- your political opinions
- data concerning your health
- your sexual orientation
We take additional care when handling these types of data.
How we process your personal data
We may process your personal data for the following purposes:
If you express an interest in and/or apply to our programmes:
- to inform you when applications for our programmes open
- to contact you to discuss the programme and provide any support you may need in your application
- to monitor interest in our programmes
- to update you on the status of your application
- to assess applications, including scoring applications (this process will always involve human intervention – see the section below on ‘Automated decision making and profiling’)
If you participate in our programmes:
- to communicate programme information and updates with you before and during your participation (e.g. zoom links, reading materials, evaluation forms)
- to match you with a volunteer, e.g. coach or mentor
- to send you information we feel may be of interest to you and relevant to your employment search and/or career development
- to act in an emergency (e.g. call your emergency contact or access data about any medical conditions)
- to monitor and evaluate our impact (e.g. asking for programme feedback, your responses to evaluations, and your employment, education, and training status)
- to improve our programmes
- after aggregation and anonymization, to demonstrate the impact of our programmes to stakeholders
- only ever with your unambiguous and explicit consent, in marketing materials (e.g. an Instagram post)
- to understand how you use and engage with our website
- to stay in touch with you as a member of our alumni to continue to support you in your next steps
After you participate in our programme:
- to stay in touch with you as a member of our alumni to continue to support you in your next steps and to inform you about related programmes that may be taking place – either of relevance to you or those in your networks
- to analyse information about your time on the programme, including any campaigns you run and their impact
- only ever with your explicit written permission, to share information about your own experiences and campaign more widely e.g. for publicity purposes or with funders.
Lawful bases for processing your personal data
When we process your personal data we only do so when permitted by law. This includes:
- the processing is necessary for our legitimate interests, only when your interests and rights do not override our interests (our interests include: monitoring interest in our programmes, enabling you to participate in our programmes, ensuring we target young people most in need of our help, monitoring the impact of our programmes, generating interest in our programmes, and raising funds through fundraising activities)
- you have given explicit consent, such as checking a box on a form
- research purposes
- equality of opportunity or treatment.
Automated decision making and profiling
When you apply to our programmes we will ask you for your demographic and background information. This is so that we can ensure we are fulfilling our mission as a charity to support young people from disadvantaged and underrepresented backgrounds, monitor the effectiveness of our programmes for different groups, and fulfil our commitment to diversity and inclusion.
Therefore, we use this data for two purposes. We anonymise and aggregate this personal data for reporting, evaluation, and research purposes. We also ‘profile’ applications using a secure, semi-anonymised, carefully designed, and human-monitored scoring system. We will never make solely automated decisions and recruitment to our programmes always involves human intervention. As explained in the section below detailing ‘Your rights under GDPR’, you have a right to object to this processing or, where you have given us your consent including in relation to special category data, you have the right to withdraw your consent. If you would like to exercise your right to object or withdraw consent, we will stop processing your data whilst we investigate whether an exemption applies. We will also clearly communicate the implications of any ending to our processing with you.
Sharing your personal data
Within the partnership
UpRising and SWT share data between one another for the following purposes:
- To ensure that UpRising is delivering against its mission to support young people aged 18 – 25 from disadvantaged and underserved communities.
- To communicate with applicants throughout the application process, to assess their suitability, and to understand how they can best be supported on the programme.
- To gather information about participant pastoral, access, welfare and support needs in order to ensure each participant has a safe, supportive and engaging experience on the programme.
Data shared for these purposes may be collected from:
- Digital systems including (but not limited to) FormAssembly and Salesforce
- Hard copy printed forms
- Electronic and hard copy notes of communications via telephone, instant messenger services, email and in person
UpRising and SWT have agreed a Data Sharing Agreement (Processor to Processor) which reflects these purposes
Beyond the partnership with SWT
We never sell your personal data to anyone. We never share it, unless we are required to by law or in ways that enable us to deliver this service. In the event that we do share it, we will take additional steps to protect your identity and personal data, such as anonymising it where possible and establishing data processing contracts with the receiving organisation. These circumstances may include:
- Non-anonymised data to external evaluators employed to help us evaluate our programmes
- Consultants employed to work on our database
- Potential future employers requesting a reference for you
- Any other circumstance where we are required to do so by law
- In aggregate form with The National Lottery Fund for the purposes of evaluation and/or reporting on the programme.
International transfers
Most of your personal data will be stored on servers inside the European Economic Area (EEA). There may be some instances where the servers we use are located outside of the EEA. In these instances, we will ensure that your data is only processed in countries that have adequate levels of protection or appropriate safeguards.
How long we retain your personal data
We only keep your personal data for as long as is necessary. This depends on the purposes of our processing. We decide how long we need to keep your personal data by considering the following:
- your rights and interests
- the nature and sensitivity of your personal data
- the potential risks involved in the continued processing of your personal data
- our legitimate interests, including whether our processing remains necessary for our reporting requirements, fundraising activities, and promotional interests
- any regulatory requirements and any existing or possible legal requirements
- whether our processing remains necessary for research and statistical purposes
Where possible, we will anonymise your personal data so that it is no longer identifiable with you. In such cases, we may retain this data indefinitely.
Alumni
After you have completed a programme you will become a member of UpRising’s supportive alumni community. As part of this, you will receive our alumni newsletter, unless you have previously opted out of receiving email communications from us. In this case, we will ask you whether you would like to opt in to join our alumni mailing list. You can opt out of receiving these communications at any point by emailing us at [email protected] or by clicking the unsubscribe button on any of these emails.
Your rights under GDPR in respect of your personal data
You have the following rights under the UK GDPR in respect of the processing of your personal data:
- Right to request access to the personal data we hold about you
- Right to request correction of any inaccurate or incomplete personal data we hold about you
- Right to request the erasure of any personal data we hold about you
- Right to request restriction of our processing of your personal data
- Right to object to the processing of your personal data, unless you have given consent in which case you have the right to withdraw consent
- Right to request that UpRising transfers a copy of your personal data in an electronic format
- Right to complain to the Information Commissioner’s Office (ICO).
If you would like to exercise any of these rights, please contact us at [email protected] and we will respond to you as soon as possible. Depending on the circumstance we may be entitled to reject your request and if this is the case we will communicate this with you clearly.