Who is collecting and using your personal data?

Devon County Council (DCC) has partnered with Eequ as part of the government’s Holiday Activity and Food programme (HAF) to deliver activities and healthy meals during the school holidays for children of families aged 5 to 16 years old eligible for benefit related free school meals.

In order to provide the activities to you and your family, it is necessary to collect and hold personal information about you and your child/ren. This information will include:

full name of child
contact details
address
date of birth or age
medical Information
dietary needs
SEND needs
photographic and video permissions
school name
eligibility categories (for example, looked after, previously looked after, child with an EHCP and young carer)

DCC and Eequ will collect personal data from providers and families to ensure the smooth running of the programme. DCC and Eequ will handle personal data in accordance with the UK general Data Protection Regulation Act 2018 and other relevant legislation and will not disclose your data to any other third party unless allowed or required to do so by legislation.

For further details about the processing of your personal data please see the council’s Data Protection web pages and Eequ’s privacy policy.

Who is processing my data?

All personal data held, is processed in accordance with the data protection law. The Data Controller for the information outlined in this privacy notice is Devon County Council.

Eequ is working as a data processor and will process your information on behalf of the council.

How will we use the Information we hold about you?

We will collect information about you (where applicable) to:

determine the eligibility of children for the Holiday Activity and Food Programme
connect parents or carers and providers in high-risk groups to connect and support children so they have high quality activity and food over the school holidays
share any medical or personal data (for example, food allergies or additional neds) to help keep children and young people safe
coordinate an effective response to the HAF fund from the council and wider community
connect you with service updates relating to the HAF programme

What is the legal basis for us to process your data?

This information processing is considered to be part of Devon County Councils public task. The processing and sharing of personal data in this way is required for the purpose of coordinating the HAF programme effectively, as outlined in the Department of Education (DFE) guidance.

The legal basis for processing the data is in the public interest or in the exercise of official authority (Article 6.1e UK GDPR).

Who will we share your information with?

We may share your information with partner organisations, including:

activity providers where parents have signed their child or young person up to complete an activity
council voluntary community groups to provide support if required

Anonymised data will be share with the Department of Education for the purpose of submitting the Holiday Activity Return which is a requirement of the funding received by Devon County Council.

We will not normally share your information with organisations other than our partner organisations without your consent however, there may be certain circumstances where we would share without consent such as where we were required to by law, to safeguard public safety, and in risk of harm in emergency situations. Any information shared will only be on a need-to-know basis, with appropriate individuals. Only the minimum information for the purpose will be shared.

How long do we keep your records?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected, including the purposes of managing your HAF booking needs or DfE reporting requirements. We will retain your personal HAF data so you can book future activities without the need to re-enter information. Data collected for the HAF programme during checkout will be kept until the Termination of the Data Processing Agreement with Eequ. Eequ’s privacy policy details how Eequ may retain your personal data for the purpose of using the Booking platform for other non- HAF activities: Eequ Privacy Policy | Eequ Help Centre

All information will be held securely and destroyed under confidential conditions.

Your rights

You have a number of rights under data protection law3, including the right to request your information and to request that the information be amended or erased if incorrect.

To request your records, you will need to contact the Information Governance Team via email at foioffice@devon.gov.uk.

You also have a right to make a complaint about our handling of your personal data to the Information Commissioners Office.

Providing accurate information

It is important we hold accurate and up to date information about you in order to assess your needs and deliver the appropriate services. If any of your details have changed or change in the future, please ensure you inform us as soon as possible so we can update your records.

Further information

If you have any questions or concerns about how your information is used, please contact haf@devon.gov.uk.

You can also contact the Data Protection team at Devon County Council.

More information about data protection and how it applies can be found on the Information Commissioners Office website.

March 2025