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Privacy notices - People and Communities

Privacy notice – Holidays, Activities and Food (HAF) Programme

North Somerset Council is registered with the Information Commissioner’s Office for the purposes of processing personal data. The administration of the Holidays, Activities, and Food (HAF) programme is supported by our partner Eequ who process the data of those accessing HAF and our activity providers on our behalf. 

The HAF programme and Eequ 

The HAF programme is a Department for Education (DfE) funded scheme in North Somerset to provide free, enriching activities for children who are receiving benefits-related Free School Meals (FSM). Currently, in North Somerset, parents/carers can apply for benefits-related FSM through an online portal where their application is reviewed and the data of successful applications is stored. The HAF programme contracts a number of local activity providers for children to access free activities during key school holidays.

Eequ is a partner of North Somerset Council and provides an online booking system which collates all of the activity providers and allows parents/carers to book activities for their child/children using the same information they submitted when applying for FSM to ensure eligibility. 

The information held about you 

To access Eequ and the HAF programme we obtain the minimum required basic information to check eligibility. Additional information can be optionally submitted if the parent/carer feels it benefits their child/children. The following data is collected when using Eequ to book activities and check eligibility: 

  • Full name of child: forename(s)/surname
  • Date of birth/age 
  • School
  • Gender 
  • Eligible for benefits-related FSM
  • Health, dietary, or other additional needs (optional)

Why we collect data: the legal context 

North Somerset Council HAF programme collects data to fulfil its statutory duties and constitutional functions. The lawful basis for the collection of personal data can be found in Article 6(1)(e) of the General Data Protection Regulation (GDPR) and states: 

‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’. 

Furthermore, in Section 8 of the Data Protection Act (DPA) 2018 the public tasks cover processing necessary for ‘statutory functions’ and ‘Governmental functions.’

Eequ collects personal data from providers and families to ensure the best possible service is given to those accessing the HAF programme.

Further information on the public task to fulfil the HAF programme and the legal basis for the collection of data can be accessed in the DfE HAF Programme Guide. 

How long your data is held for 

North Somerset Council keep data for the minimum necessary amount of time for the purposes of managing the HAF programme or for DfE reporting after which data is destroyed in line with GDPR. We retain your data so parents/carers can book future activities without re-submitting their information. Data collected for the HAF programme using Eequ is kept until the termination of the Data Processing Agreement in place with Eequ - Eequ’s Privacy Policy can be accessed here. 

Your rights and access to information 

You have the right to access the information collected about you under data protection law. The Freedom of Information (FOL) Act 2000 gives you the right to access this information.

make a freedom of information request

For questions or concerns about the way we process your personal data you can contact North Somerset Council's Data Protection Officer: DPO@n-somerset.gov.uk

You have the right to make a complaint about how we handle your data to the Information Commissioner's Office.

Who we share information with

We may need to share information with partner organisations:

  • Contracted activity providers for attendance reporting and eligibility checking 
  • Council, voluntary and community groups connected with the HAF programme 
  • Anonymised data will be shared with the DfE for reporting purposes as required by the Section 31 Grant Determination Letter to receive funding for the programme

We will not share information with non-partner organisations unless we are required to do so by law to safeguard public safety. For example, in circumstances as outlined by the Telecoms Regulations 2000 (Lawful Business Practice) (Interception of Communications) such as to prevent or detect a crime, or to investigate the unauthorised use of the service. 

Data protection statement 

The data collected by Eequ in partnership with North Somerset Council HAF programme is never shared or sold to third parties. The data processing agreement in relation to the data collected for the HAF programme is solely between North Somerset Council and Eequ. A Data Protection Impact Assessment has been completed to outline the security provided by Eequ's services and by North Somerset Council in the protection of personal data. 

Data held by both Eequ and North Somerset Council is held securely in the UK and we have the capacity to recall individual’s data and permanently erase it. Staff with access to the data have the appropriate training and enhanced DBS checks where necessary. 

Further information