Privacy Notices - Plas Pencelli Outdoor Education Centre visitors Privacy Notice

You need to be aware of this Privacy Notice if you are providing personal information to Swindon Borough Council operated Plas Pencelli Outdoor Education Centre. This privacy notice explains how personal and confidential data about you or your dependants is collected, used and shared. Plas Pencelli will process your personal data in accordance with the Data Protection Act 2018.

A Privacy Notice is a statement issued by an organisation which explains how personal and confidential data about individuals is collected, used and shared.

Swindon Borough Council will act as a “Data Controller” for any personal data that you provide to Plas Pencelli OEC.  We will ensure that the data given to us is processed in line with our Data Protection Act 2018 (DPA 18) and the EU General Data Protection Regulations. (GDPR)

To find out more about Plas Pencelli’s data protection policies please contact:

Plas Pencelli OEC
Pencelli
Brecon
Powys  LD3 7LX 

Email: office@plaspencelli.co.uk 
Tel: 01874 665241

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.

We collect the following:

• Name
• Contact details (address, email address, telephone number/s)
• Date of birth
• Medical information
• Emergency contact
• Whether you have a disability for which we can make reasonable adjustments
• Dietary information
• Water confidence
• Special educational needs
• Behavioural information
• Other personal needs (such as emotional or physical)
• Attendance information (such as days attended and reason for early departure)
• Opinions on your visit (from personal comments, staff feedback and review forms)
• Guarantor (if you are acting for another person, such as a child under the age of 16)

Plas Pencelli and Swindon Borough Council complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

There is a contractual obligation to provide personal data to Plas Pencelli as it is necessary for the safeguarding of all course participants and accompanying staff.

Your personal data is used to allow a good and safe level of service to be delivered at Plas Pencelli within the standards set by the Adventure Activities Licensing Regulations 1996 to:

• allow you access to the buildings and site
• provide and administer outdoor education services for you and to any person, such as children under 16, for whom you are a guarantor. This includes providing outdoor activities, providing transport to and from activity sites, supervising on-site evening activities, overseeing eating and sleeping arrangements, facilitating staff meetings, supporting young people, in particular, in day to day living and providing on-site and off-site training events.
• respond to your enquiries
• ensure that we are providing services that are needed and relevant to you
• ensure there is continuous improvement to the service at Plas Pencelli
• detect and help prevent crime and to protect centre staff and users

We receive information about you:

• when you contact us via our individual information forms or Individual course application forms
• provided to us by schools, other organisations or personally before a visit
• from you in person during your stay at Plas Pencelli
• from you via feedback responses

We use personal information provided to:

• effectively risk assess activities during the planning stage
• help ensure safety during activities (selecting appropriate venues for example)
• take appropriate precautions (such as bringing along an inhaler for asthmatics)
• make suitable adjustments to best accommodate individuals
• react appropriately in emergency situations
• support learning
• monitor and report on progress
• provide appropriate pastoral care
• assess the quality of our services
• comply with the law regarding data
• provide business to business marketing where there is a relevant and appropriate relationship with a customer

We collect and use personal information under the following lawful bases that:

• it is necessary to provide the contracted level of services
• there is a legal obligation to be able to effectively discharge a duty of care particularly for young people
• there is a vital interest as personal data is required to help protect life
• there is a legitimate interest in processing your data
• there is a legitimate interest for marketing our service to relevant education professionals
• processing of special category data is necessary for reasons of substantial public interest as it is necessary to protect the physical, mental and emotional wellbeing of individuals including those under the age of 18.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we might need to use it for another reason that is compatible with the original purpose. If we need to use your personal information for any other unrelated purpose, we will always notify you and we will explain the legitimate basis which allows us to do so or ask for your consent.

We may share your information with the following:

• Centre staff who lead activities or prepare meals
• The schools of pupils attending after departure
• Swindon Borough Council
• The Plas Pencelli Management Committee
• Anonymised data with the Association of Heads of Outdoor Centres to conduct research or analysis producing statistics, information, advice or guidance
• The NHS where a visit to a hospital has to be made

We do not share information about you with anyone without consent unless the law and our policies allow us to do so. We share information about you with our local authority (LA) Swindon Borough Council. Any user who does not comply with the centre rules and regulations or the law should be aware that we may share your personal data, including images, with your visiting school or organisation, other Swindon Council departments or the Police.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees and third parties (named above) who have a business need to know when providing services to Plas Pencelli. All parties will only process your personal information on our instructions and in accordance with obligations under the Data Protection Act 2018 and GDPR.

In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this Privacy Notice. This means that the retention periods will vary according to the type of the data and the reason that we have collected your data in the first place. We have procedures in place regarding our retention periods which we keep under review taking into account our reasons for processing your personal data and the legal bases for doing so.

The data you provide prior to and during a visit to Plas Pencelli

This data may be anonymised in the system and your information and feedback forms are destroyed within a month of your visit with the following exceptions:

• Where an accident or incident has happened all relevant personal data is retained to allow further investigation. This will normally be retained for 6 years or up until the individual reaches 25 years of age.
• The data we collect in the course of providing a service:
  • Any personal information you supply to us in any correspondence initiated by you (email, letter, telephone) will be retained for the duration of the enquiry and will be securely destroyed and in line with our information security procedures
  • Our systems will store your personal data for up to two years following your last contact with Plas Pencelli after which time it is deleted.

Under data protection legislation, parents and pupils and other visitors have the right to request access to information about them that we hold. To make a request for your personal information contact the data protection officer (see below).

You also have the right to:

• obtain a copy of your data we process and store within our policy
• object to certain processing of your personal data such as that, that is likely to cause, or is causing, damage or distress
• request us to restrict the processing of your data in certain ways such as for the purpose of direct marketing
• object to decisions being taken by automated means
• in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed
• withdraw consent for processing where that is the legal basis we use and be forgotten, for example, for your personal data to be removed from our systems and records under certain circumstances
• claim compensation for damages caused by a breach of the General Data Protection Regulations

You have the right to ask for a copy of all the information we have about you and the services you receive from us. When we receive a request from you in writing, we will give you access to everything we have recorded about you, however, we cannot let you see any parts of your records that contain:

• personal information about other people
•  information a professional thinks will cause serious harm to you or someone else’s physical or mental well-being
• information we think that the provision of which may stop us from preventing or detecting a crime

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Swindon Borough Council Data Protection Officer direct. (see below).

Plas Pencelli Information Asset Owner at Plas Pencelli OEC
Pencelli
Brecon
Powys  LD3 7LX 

Email: office@plaspencelli.co.uk 
Tel: 01874 665241

SBC Data Protection Officer at Swindon Borough Council, Civic Offices, Euclid Street, Swindon  SN1 2JH  email: dataprotection@swindon.gov.uk 

If you remain dissatisfied with the way your personal data has been handled, you have the right to complain to the Information Commissioner’s Office at www.ICO.org.uk You may refer the matter to the Information Commissioner’s Office whose contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF 

Email: casework@ico.org.uk

You are under no statutory obligation to provide personal data to us, however, if you do not provide the data, we may not be able to process your application or provide the services properly or at all.

A yearly audit will take place on personal data to ensure that we remain legally compliant in accordance with current data protection legislation.

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