This privacy notice (updated November 2022) is related specifically to the Kent School Games (KSG) and School Games (SG) programme delivered by Active Kent and Medway. For other projects delivered by Active Kent and Medway please see the relevant privacy policies available online at Active Kent and Medway Project Privacy Policies.
PLEASE NOTE: this notice is relevant to the element delivered by Active Kent and Medway. Localised opportunities of the School Games programme are the responsibility of School Games Organisers (SGOs) and their host schools who will have separate policies. If you would like to find out further information please contact your School Games Organiser.
At Active Kent and Medway, we’re committed to protecting and respecting your privacy.
We aim to provide you with the highest quality service whilst you are accessing our services. To do this, we must keep records about you and the services we provide for you. We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing.
We will:
- only collect personal data for specified purposes
- explain why we are collecting personal data
- where necessary, seek consent relating to the use of personal data
- retain personal data securely and
- only hold personal data for a specified amount of time after which it will be deleted.
If you have any questions regarding this policy or our privacy practices then please contact us:
by email: activekent@kent.gov.uk
in writing: Active Kent and Medway, Kent County Council, Worrall House, 30 Kings Hill Avenue, Kings Hill, Kent, ME19 4AE.
or by telephone: 03000 414001.
We may change our privacy notices from time to time, so please check the Active Kent and Medway website occasionally to ensure that you’re happy with any changes.
Who are we?
Active Kent and Medway is a service within and is part of Kent County Council. Kent County Council is the data controller and is responsible for the security of the data that you provide and for overall compliance with data protection legislation. We are an integrated team of Kent County Council and Sport England funded staff, working together as the Active Partnership for Kent. We work with partners and networks across the county to provide opportunities for everyone to get involved in sport and physical activity for enjoyment as well as wider health and social outcomes.
The Kent School Games/School Games is a government led programme, inspiring young people to be physically active for life through positive experiences of daily activity and competition. In Kent, the Active Partnership work alongside a network of 13 School Games Organisers (SGOs) covering Kent and Medway to engage those most affected by inequalities and to support the positioning of physical activity across our network of schools.
What information we collect and how we use it
This policy explains when and why we collect personal information about those involved in KSG, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
Information for KSG is normally collected using Microsoft Forms or Microsoft Lists, prior to or at events. This document outlines in more detail the software used to collect information and how that information is used.
Photograph and video footage registration forms (via Microsoft Forms)
How do we collect information from you?
These are completed by any adults wishing to take images at KSG events. We collect this information as part of our safeguarding policy to protect participants taking part in KSG events.
What information do we collect?
- Name
- Address
- Contact
- Telephone number
How is your information used?
We have a legal obligation (safeguarding duty) to collect your personal data in this way. We will only use your information if a safeguarding incident occurs at a KSG event.
How long will we hold your information?
Information is stored securely and retained for five years after which this is disposed of.
Who has access to your information?
Only Active Kent and Medway (KCC) will have access to your details and your personal information will only be shared with the relevant authorities (e.g. police) if a safeguarding incident occurs in relation to images or video footage taken at a KSG event.
Evaluation and Feedback Forms (via Microsoft Forms)
How do we collect information from you?
These can be completed anonymously by teachers, spectators, officials and anyone else wishing to feedback on their KSG experience.
What information do we collect?
Forms are anonymous but names and email addresses can be provided to sign up to our mailing list.
How is your information used?
Feedback provided is used to improve service delivery and is not associated with any personal data, even when a name and email address is included.
How long will we hold your information?
Responses are stored securely and retained until the relevant reporting has been submitted, up to a maximum of one year.
Who has access to your information?
We will not sell or rent your information to third parties or share your information with third parties for marketing purposes.
Team Sheets (via Microsoft Lists)
How do we collect information from you?
These are completed by team managers via a secure link.
What information do we collect?
Participant details:
- Forename
- Surname
- Date of birth
- Academic year
- Photo consent
- Gender
- Ethnicity
- Special educational needs and disability
- Unique pupil number
- In receipt of free school meals
How is your information used?
The legal basis we use for collecting this data is that it is necessary for the performance of a public task in the public interest. Data is used to provide partners with aggregated and anonymised statistics about who is taking part in our events, to secure future funding and improve our services.
We process equalities monitoring data for reasons of substantial public interest to ensure equality of opportunity or treatment. We want to make sure that everyone is treated fairly and equally, and that no one gets left out. We won’t share this information with anyone else. We’ll use it only to help us make decisions and improve our services.
No personal or identifiable information is shared with anyone outside of KCC.
How long will we hold your information?
The information is stored securely and retained until the relevant reporting has been submitted, up to a maximum of two years.
Who has access to your information?
Raw data including personal details are shared with KCC’s Strategic Commissioning – Analytics Team. The data is matched to a pupil dataset to compare the profile of participants in the Kent School Games against the countywide demographic dataset. For further information please refer to the Pupil Information Privacy Notice. This is for reasons of public interest to ensure equality of opportunity or treatment. When reported, the data is aggregated and anonymised, no individual is identified. We do not make any decisions about individual service users based on automated decision making or profiling.
Reports are produced for Sport England but these do not contain any personal or identifiable data.
Photographic images and video footage
How do we collect information from you?
We follow the photography guidelines published by the NSPCC Child Protection in Sport Unit, as well as our own safeguarding, welfare and photography policies.
What information do we collect?
Photographs and video footage are taken at events.
How is your information used?
Photography or filming may take place at any of our events to promote the values of the Kent School Games. Our use of images and video footage portrays diverse groups of people engaging in and enjoying physical activity, helping us to inspire other people to be more active.
We rely on consent to take photographs and video footage in which participants are identifiable.
Where consent is given images and video footage may be used by Active Kent and Medway for promotional purposes and published on the websites, social media accounts and printed publications owned and managed by Active Kent and Medway.
How long will we hold your information?
Original images and videos are retained for a two-year period after which they will be securely disposed of. After this time, copies of images or videos may still appear in previously published website articles, social media posts, printed publications or promotional materials.
Who has access to your information?
Images and videos may be used by Active Kent and Medway and published on the websites, social media accounts and printed publications owned and managed by Active Kent and Medway and are therefore accessible to the general public.
Images and videos may also be shared with sponsors and media partners but only for use in promotion of the Kent School Games, and/or the organisation’s partnership with KSG.
How you can access and update your information
The accuracy of your information is important to us. If you would like to update or amend the information that we hold about you, then please contact us:
by email: activekent@kent.gov.uk
in writing: Active Kent and Medway, Kent County Council, Worrall House, 30 Kings Hill Avenue, Kings Hill, Kent, ME19 4AE.
or by telephone: 03000 414001.
Your Rights
Under the GDPR you have a number of rights which you can access exercise free of charge which that allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioner’s Office.
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways.
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Who to Contact
Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk or by writing to the Data Protection Officer at Sessions House, Maidstone, Kent ME14 1XQ.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 03031 231113.
For further information please visit https://www.kent.gov.uk/about-the-council/about-the-website/privacy-statement
