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Strategy implementation plan 2025-28 project data privacy notice

22 August 2024

Introduction and purpose

The English Sports Council (Sport England) is a non-departmental public body responsible for growing and developing grassroots sport and getting more people active in England.

In January 2021 Sport England launched its 10-year strategy called Uniting the Movement (the Strategy) through which it intends to keep movement, sport and physical activity central to the lives of everyone, by tackling access inequalities and providing opportunities to people and communities that have traditionally been left behind, while helping to remove the barriers to sport and physical activity participation.

Four years after the launch of the Strategy Sport England is looking towards the second phase of delivery known as Strategy Implementation 2025-28 and wants to engage with and get the views and input of stakeholders both within and outside of the organisation on the effectiveness of the first implementation period (2022-25) and how to develop the next (2025-28).

To help it in finding out more about the different communities it serves Sport England commissions or creates research and uses those findings to make better funding decisions.

The Strategy Implementation Plan 2025-28 Project intends to conduct research and gather data on what is changing in our context that should influence our decisions, how we can be better at tackling the inequalities in sport and physical activity, and whether our assumptions about the next implementation period are correct.

During this project, we will be processing personal data relating to you. Under UK GDPR law, whenever your personal data is being processed you must be told what personal data will be processed, who will process it, how they will do so and the responsibilities they have to you and to the law.

This privacy notice sets out how this processing will be done compliantly.

Who are the data subjects?

Anyone who receives and completes any of our surveys, attends any of our events or participates in any of our interviews will be a data subject, whether they are Sport England staff or members of other organisations or the public.

Who will be processing your personal data (data controllers and data processors)

Sport England is the owner of the project and funder of the research and is an ICO registered data controller with registration number ZA208476.

It is the data controller in relation to all the personal data collected from you. Sport England will process the data you provide for this project in accordance with this privacy notice and its general privacy statement which can be found here.

Trajectory Limited (Trajectory) is a supplier Sport England has contracted to carry out some of our research services. This makes Trajectory Limited our authorised Data Processor. It is a registered data processor with ICO number Z3013102.

Tresorit AG is a storage and hosting service provider for Trajectory and therefore considered a sub processor for your personal data where it is held by Trajectory.

Your personal data and our lawful basis for processing

Sport England and Trajectory will be processing all or some of following personal data in relation to you; First and last name, email address, telephone number, workplace name and address, role, gender, views and opinions.

Our lawful basis for processing your personal data is public task.

Sport England (not Trajectory) will process the following special category data if you explicitly consent to be video recorded, race, ethnicity, health detail, possible religious orientation.

Sport England’s additional lawful basis for processing your special category data will be your explicit consent which you will be asked to provide in writing in a different document.

How your personal data is processed

Sport England will be conducting a number of different types of research and engagement and depending on the event you participate in this is how your data will be processed.

  1. Your personal data will be processed to send you survey links to complete our surveys, and to conduct other related research but your survey results will be anonymised and you will not be asked to provide any personal data in the surveys themselves.
  2. Your personal data will be processed to invite to attend internal audio-video recorded presentations. At the time when you are invited to any recorded event you will be provided with a notice about the recording session and how you may consent to participate.
  3. Your voice will be recorded if you consent to interviews. You can still participate in interviews if you do not give your consent to be voice recorded.
  4. Your special category data will be processed if you consent to be video recorded.

Purpose for processing

Your voice personal data will only be processed to allow Trajectory to obtain and provide accurate reports for interviews conducted. These audio files will be deleted as soon as they have been transcribed.

Sport England will only audio-video record designated Show and Tell sessions for internal business communications and staff engagement purposes.

Your special category data will be processed only where you consent or enable microphone or camera functions on the recording platform.

Your other personal data will only be used to contact you to provide you with the survey or to invite you to participate in the surveys or interviews.

Your personal data will also be processed by all the parties to provide contracted services or to respond to compliant, legislative rights requests or statutory and regulatory obligations.

Your personal data will be processed to contact you for future research or follow up relating to this project.

Storage, retention and deletion

Sport England will retain any personal data recorded in the Show and Tell sessions and any information relating to providing you with the surveys as part of its business records which are kept for three years according to our File Retention Schedule.

Trajectory will only store your data for the duration of the contract period after which it will be deleted no later than thirty days after the end of the contract.

Restricted transfers

Neither Sport England,Trajectory nor Tresorit AG will transfer your personal data outside of the UK.

Applications

Sport England will use Microsoft Forms (for surveys) and Microsoft Teams for Show and Tell Recordings. These are known as third-party applications, meaning they are owned and operated by Microsoft but licensed for use by Sport England. This means when we use them in this project, we will be subject to the terms of this privacy notice but if you wish to have more information on Microsoft you can find their privacy notice here.

Consent and other data rights

You can also modify your consent at any time, perhaps removing certain elements of your personal data, though you should be aware that in doing so, we may not then be able to consider you for continued participation in the project.

Other data rights

Under data protection law, you have other rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights.

If you make a request, based on the nature of your request, Sport England, Trajectory and Tresorit AG data controller and processors will have one calendar month to comply with your request.

Sport England can be contacted at DPO@sportengland.org

Trajectory can be contacted at carolyn@trajectorypartnership.com

Tresorit AG can be contacted at dpo@tresorit.com  

Complaints

To lodge a complaint about the handling of your personal data, contact the Information Commissioner’s Office:

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

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