Education Partnerships Africa Project Worker Privacy Notice
Last modified November 2018
About this Privacy Notice
In this Privacy Notice, references to “we”, “us” and “our” are to Education Partnerships Africa.
We are committed to protecting your personal data. Personal data is any information relating to an identifiable living person who can be directly or indirectly identified by reference to this data.
This privacy notice relates to our use of any personal data that you directly provide us.
We will comply with data protection law which requires that personal data we hold about you is:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about;
- kept securely.
This privacy notice will therefore inform you as to who we are, what personal data we collect, the purposes for which we use it, for how long we retain it and how we keep it secure, your rights in relation to you personal data, and how you can contact us to discuss, query or obtain details of the personal data we hold about you.
- Who we are
- Whose personal data we process
- Why we process your personal data
- Personal data sources
- How we will inform you about our privacy notice
- The purposes for which your personal data is collected and processed
- Who we will share your personal data with
- Transferring your data outside of the European Economic Area
- Safeguarding your personal data
- How long we retain your personal data
- Your rights as a data subject
- REporting a concern to us or to the Information Commissioner’s Office
- Your right to lodge a complaint with a supervisory authority
- Getting in touch with us
1. Who We Are
Education Partnerships Africa is a registered charity in England and Wales, with charity number 1104888 and company number 4970135. The registered address is 86 Gibson Gardens, London, N16 7HD.
Education Partnerships Africa is a charity which aims to improve the quality of education in East Africa through working with rural communities there. We also enable talented students in the UK to experience grassroots international development and provide them with the awareness, knowledge and skills to become leaders of the future.
Education Partnerships Africa is the controller of the data it stores.
As a charity which only stores the minimum information required about its members or individuals with which it has regular contact, Education Partnerships Africa is not registered with the Information Commissioner’s Office and does not have a Data Protection Officer.
Education Partnerships Africa has volunteers operating from many locations primarily in the UK, but also Europe, and uses cloud-based systems to store and process its data.
If you would like to contact Education Partnerships Africa, you can do so with the following contact details:
Education Partnerships Africa
86-90 Paul St
2. Whose Personal Data We Process
We collect and process personal data about our:
- Current Volunteers
- Previous Volunteers
- Summer Team
- Partner Schools
- Contacts in East Africa
3. Why We Process Your Data
We collect and process your personal data:
- with your consent;
- and/or to perform the agreement we have entered with you (or discharge other contractual obligations);
- and/or to comply with our legal obligations;
- and/or to protect the vital interests of yourself, a member of Education Partnerships Africa, or a third party;
- and/or to perform a task in the public interest;
- and/or to pursue the legitimate interests of yourself, Education Partnerships Africa, or a third party, so long as your rights do not override those legitimate interests.
4. Personal Data Sources
We can collect personal data from any number of sources, including but not limited to:
- Information you provide us directly, for example in forms you fill in online, or in emails you send us;
- Publicly available information online, for example from LinkedIn or Google;
- Third party providers such as contractors.
5. How We Will Inform You About Our Privacy Notice
We will provide a link to this privacy notice whenever we collect your personal data online.
We will not use your personal data for any purposes other than those set out below without first informing you. Changes made to this privacy notice will be updated on our website and clearly signposted on our key documents.
You can request a hard copy of this privacy notice for a reasonable administration fee, by contacting us using the details set out above.
6. The Purposes For Which Your Personal Data is Collected and Processed
We collect your personal data with the overall aim of enabling successful charitable work in our partner schools in East Africa.
6.1 – Name and Contact Details (including address, telephone numbers and email addresses)
This data allows us to coordinate our activities and communicate with you in order to carry out the agreement we have made with you.
Your name and occasionally your contact details will be disclosed when necessary to third parties when carrying out agreements we have made, for example the school you will be volunteering in, and any companies we use when arranging transport and accommodation. The data will be stored from the time you provide it, until we receive an erasure request from you. As we rely on our network as a source of personnel and donations, you may receive communication from us after you have been a project worker. You have the absolute right to object to this communication, in which case we will cease further communication.
6.2 – University and Course
This data allows us to coordinate our activities via the University Committees in our project worker hubs in order to carry out the agreement we have made with you.
It will be not be shared with third parties, and will be stored from the time you provide it, until we receive an erasure request from you, so that we can notify you of events happening at your project worker hub or ask for your assistance when coordinating our activities there.
6.3 Sensitive Personal Data – Health and Criminal Offences
If you are travelling to East Africa, we will collect your health data to safeguard your health in a medical emergency. This will not be disclosed to third parties, such as medical staff, without your explicit consent, unless your are physically incapable of doing so.
As part of your health declaration, we will request a copy of your yellowfever vaccination certificate, as this is a legal requirement for entering Kenya and Uganda.
We may also process your personal information relating to criminal offences. This will be done in accordance with the legal obligations set by the Child Protection Act 2004. If an incident occurs, it may be necessary to disclose the certificate number, name and expiry date on your Disclosure and Barring Service (DBS) certificate to an insurance company.
We will not collect any other sensitive personal data (special category data) from you, such as information relating to race or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, trade union membership, physical or mental health, sexual life, genetics or biometrics.
6.4 – Passport, Flight Confirmation, Visa Details and Insurance Policy
If you are travelling to East Africa, this data is required to carry out the agreement we have made with you when we:
- arrange transport and accommodation on your behalf
- coordinate logistics in East Africa
- reimburse you for valid expenses
It will be shared with relevant third parties where necessary to carry ot the agreement, for example airlines and accommodation. The data will be deleted within 6 weeks of returning from East Africa.
6.5 – Bank Details
This data is required to carry out the agreement we have made with you to reimburse valid expense claims and to transfer to you your upfront living allowance.
7. Who We Will Share Your Personal Data With
We may also share any of your personal data with:
- Regulatory authorities, government departments or the police in order to comply with any legal obligations or to assist in crime prevention and detection
- Other third parties where we reasonably believe that such action is necessary to comply with legal obligation, or to protect our rights and property, or act in urgent circumstances to protect the personal safety of our volunteers, the individuals and organisations we work with, or members of the public.
8. Transferring Your Data Outside of the European Economic Area
Your personal data will be securely transferred to East Africa by our Summer Team once per year for use by the Summer Team based there, all of whom are members of Education Partnerships Africa. When necessary to carry out the agreement we have made with you or a third party, limited personal data may occasionally be disclosed to third parties in East Africa without your explicit consent, for example to book accommodation upon arrival.
9. Safeguarding Your Personal Data
We take all reasonable steps to ensure that appropriate safeguards are in place to protect your personal data. We ensure our volunteers understand our Data Protection Policy, which can also be found on our website.
10. How Long We Retain Your Personal Data
Your personal data will be retained by us for as long as there remains a valid legal basis for retaining it. We will keep data retention under regular review.
For more information about retention periods for specific types of information, see our Data Protection Policy on our website.
11. Your Rights as a Data Subject
To ensure fair and transparent processing, it is important that we inform you of your rights with regards to how your personal data is processed. Were you wish to exercise a right, we have indicated the best contact details for you to get in touch with us.
We may ask for further information to locate the information and to verify your identity. If we believe that the right you have requested does not apply in the given situation, or your request is excessive or repetitive, we may refuse to comply with your request. You will be informed of this decision and the reasons why no action was taken.
11.1 Your Right to Be Informed
This is our privacy notice which informs you of who we are, why we are processing your personal data, with whom we share your personal data and how we have collected it. These details are out above.
Our privacy notice can be found on our website and a link to it will be provided whenever we collect your personal data digitally.
If you would like to discuss this privacy notice to find out more information, or suggest ways in which we could improve the content or its communication, then please email us at email@example.com or write to us at at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.
1.2 Your Right of Access
As a data subject, you have the right to access the personal data we hold about you, confirmation that your personal data is being lawfully processed and information about the source of the data.
Making a data subject access request (DSAR) is free and can be done in writing by emailing us at firstname.lastname@example.org or alternatively writing to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE. You can also speak to if you have any questions or queries relating to a DSAR.
Once we receive your request, we will ask you to verify your identity and ask you to specify the data or processing activity that you require so that we can confirm your expectations and respond within 28 days.
We do have the right to refuse a DSAW should it be manifestly unfounded or excessive, and we can apply a reasonable fee and/or extend the time to respond should the request be complex (in which case you would be informed within 28 days). We do have the right to apply a reasonable fee if you make numerous requests for the same information.
11.3 Your Right to Rectification
Where personal data is inaccurate or incomplete, you have the right for it to be rectified on our systems. In such cases, we will act promptly to apply the rectifications.
So that we can quickly resolve your query, we may ask you to provide some supporting evidence to show that the data needs to be altered.
If you require your personal data to be rectified, this can be done in writing by emailing us at email@example.com or alternatively writing to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.
11.4 Your Right to Erasure
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to withdraw consent (see below).
Sometimes however, we may refuse a request to erase such data in order, for example, to comply with a legal obligation.
If you require your personal data to be erased, this can be done in writing by emailing us at firstname.lastname@example.org or alternatively writing to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.
11.5 Your Right to Restrict Processing
This enables you to ask us to restrict the processing of your personal data For example, if you do not want us to erase your data, you may ask us to restrict our processing activities instead. A good example would be to retain data beyond the retention period to defend a legal claim.
11.6 Your Right to Data Portability
To help strengthen your control over your data, you have the right, in certain circumstances, to receive personal data from us in a format which allows you to easily access it. For example, you may want your donation data in CSV format.
We may ask you to specify what data you wish us to provide you. Where we can, we will try and provide you the data in a common format which transferable with other data controllers.
Should you wish to exercise your right to data portability, this can be done in writing by emailing us at email@example.com or alternatively writing to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.
11.7 Your Right to Withdraw Consent
In circumstances where you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing activity at any time.
To withdraw your consent, you can email firstname.lastname@example.org or alternatively write to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.
Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legal basis for doing so such a contractual or legal reason.
12. Reporting a Concern to Us or to the Information Commissioner’s Office
If you have a concern regarding how we handle your personal data then we kindly request that you inform us about it first so that we can work with you in an effort to resolve it.
You can report a concern or raise a complaint with us initially by contacting emailing us at email@example.com or alternatively writing to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.
We aim to acknowledge your complaint within one week and provide a resolution within 28 days. If we are unable to meet this timescale, we will write to notify you in advance.
If you are not satisfied with our proposed resolution to your complaint, you can raise the matter directly with the Information Commissioner’s Office (ICO). The ICO will take steps to address your concern and provide guidance and support to us so that we can put things right.
Details as to how to get in touch with the ICO or report a concern can be found on their website www.ico.org.uk/concerns
13. Your Right to Lodge a Complaint with a Supervisory Authority
If you consider that the processing of personal data infringes any of your rights set out in Section 11, you have the right to lodge a complaint with the relevant supervisory authority in the European State that you reside or work in, or the place of the alleged infringement. The relevant supervisory authority for the UK is the Information Commissioner’s Office.
The supervisory authority which which the complaint has been lodged shall inform you of its progress and the outcome of the complaint including the possibility of a judicial remedy.
14. Getting In Touch With Us
If you would like to discuss this privacy notice or suggest way in which we could improve the content or its communication, then please email us at firstname.lastname@example.org or write to us at Education Partnerships Africa, 86-90 Paul St, London, EC2A 4NE.