Privacy Notice for #AnimalEDGEucation

1st June 2020

Your privacy is important to On the EDGE (On the EDGE).

On the EDGE is running #AnimalEDGEucation which is a series of online educational activities for children hosted on the On the EDGE website (Website). #AnimalEDGEucation encourages you to share children’s work on Facebook, Instagram and/or Twitter (the Social Media Platforms). Some of the work which is shared in this way will be included in an #AnimalEDGEucation book which may be published in print and/or online via the Website and/or the Social Media Platforms (the Book).

This privacy notice provides information about the different types of personal information that are collected by On the EDGE in connection with your engagement with #AnimalEDGEucation and the ways in which we use it.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

If you have any questions please feel free to contact us using the contact details included at section 13.

1. Purpose of this Privacy Notice

This privacy notice describes how On the EDGE will collect and use the personal information that you provide to us or that we obtain about you when you participate in the #AnimalEDGEucation activities.

It is important that you read this privacy notice together with our wider privacy policy that we have provided or may provide to you when we are collecting or processing personal information about you in other contexts. This privacy notice supplements our Website privacy policy and any other privacy statement that we have given to you and is not intended to replace them.

This privacy notice should be read in conjunction with the On the EDGE Website Terms and Conditions.

If you are sharing any personal information about a child when you post their work via the Social Media Platforms (for instance their name) please explain to them how their personal information is likely to be used in connection with #AnimalEDGEucation as explained in this privacy notice.

In this notice, references to “we” or “us” are to On the EDGE and references to the GDPR are to the General Data Protection Regulation (EU 2016/679) including to the implementation of the GDPR into UK law.

2. Who we are

On The EDGE Conservation Ltd. is a registered charity (No. 1163124) and company limited by guarantee in England & Wales (No. 09646831). Our registered office is at 152a Walton St, Chelsea, London, United Kingdom, SW3 2JJ. We are the controller of any personal information which is outlined in section 4 of this notice.

3. When do we collect personal information about you in connection with #AnimalEDGEucation?

We will collect personal information about you and, where you disclose it, your child’s(1) personal information:

1.1              when you share your child's work using #AnimalEDGEucation on the Social Media Platforms;

1.2              when you contact us directly, for instance to raise a question or make a comment about #AnimalEDGEucation or respond to communications from us, including communications about inclusion of your child’s work in the Book.

4. What personal information do we use?

We may collect, store and otherwise process the following kinds of personal information:

4.1              your full name and contact details, including email address, telephone number, but only where you have provided this information to us;

4.2              your social media handle where you have uploaded a child’s work to any of the Social Media Platforms using #AnimalEDGEucation;

4.3              any personal information about you and/or your child which you include either in the work that you upload to the Social Media platforms or in any accompanying comments that you include in your posts to the Social Media Platforms;

4.4              an assessment of your child’s engagement and learning progress following completion of the #AnimalEDGEucation learning activities. [This will be used to analyse the effectiveness of our learning materials in improving learning and awareness.]

5. What about personal information that is considered more sensitive?

We will only collect and use sensitive information (also known as ‘special category data’ under the GDPR) if there is a valid reason for doing so and where the law allows us to. Sensitive information includes personal information about health, ethnicity, religion, political opinions or sexuality.

We collect these types of personal information in limited circumstances, for instance if you volunteer it within the work that you post or in any accompanying comments that you upload to the Social Media Platforms, although we recommend that you avoid disclosing  any sensitive information relating to you or your child when posting to Social Media Platforms.

When we collect sensitive information about you and we are required to tell you what our lawful basis is for doing so, we will set this out.

6. How we use your personal information

We will use your personal information for a variety of purposes:

We will use your contact details including your social media handles:

(a)           to contact you in connection with your and/or your child’s participation in #AnimalEDGEucation;

(b)           to contact you about the inclusion of your child’s work in the Book;

(c)           to identify work produced by your child and monitor the progress of that child as he/she engages in other #AnimalEDGEucation learning activities; and

(d)           to satisfy legal obligations which are binding on us.

We will use the contents of the work that you upload via the Social Media Platforms:

(e)           for research purposes so that we can identify learning outcomes for children who participate in the #AnimalEDGEucation activities as well as improving our understanding of different levels of perception and understanding in relation to different EDGE species ; and

(f)            to include in the Book and any publications which promote the Book, [including names of children where this personal information has been provided.

For more information on how we will use the contents of the work that you upload, please see our Terms and Conditions. 

7. Lawful grounds

Under the GDPR, we are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

7.1              Legitimate interests

We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information about you to assess the effectiveness of our awareness raising activities and how these activities help us to work towards our organisation’s charitable goals. Additionally, where you post personal information online to a Social Media Platform in publicly available format and use the #AnimalEDGEucation hashtag, we have a legitimate interest to use such personal information for the purposes in section 6 and we consider such uses to be within your expectations. 

7.2              Consent

We may obtain your consent to use your personal information in certain circumstances e.g. where you have voluntarily provided us with sensitive information about you. We will ensure that when we obtain your consent you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you.

8. Do we share your personal information?

We will not sell, rent or lease the personal information that we obtain about you (as outlined in section 4). However, we may ask third party processors to assist us or we may disclose your personal information to selected third party processors (such as agents or sub-contractors) for the purposes outlined at section 6. The third party in question will be obligated to use any personal information they receive in accordance with our instructions.

We may also engage third parties to assist us with website hosting, data analysis, aggregation of social media postings and other administrative services.

We reserve the right to disclose your personal information to third parties:

(a)           in the event that we acquire or dispose of any business or assets, in which case we will disclose your personal information to the prospective transferor or transferee or such business or assets;

(b)           if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;

(c)           for auditing purposes or for professional advice purposes e.g. with our lawyers;

(d)           if we are under any legal or regulatory obligation to do so e.g. to comply with legal process or requests from government authorities;

(e)           to permit us to pursue available remedies or limit the damages that we may sustain; and

(f)            in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our or a third party’s legal rights.

9. International data transfers

Where your personal information is transferred, stored, and/or otherwise processed outside the UK or EU in a country which does not offer an equivalent standard of protection to the UK or EU, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. For instance, we will enter into standard contractual clauses (with the recipient) where such clauses are approved by the Information Commissioner’s Office or the European Commission where relevant.

If you have any questions about the transfer of your personal information, please contact us using the details at section 13.

10. How long do we keep your personal information?

We will keep your personal information for as long as necessary:

(a)           to comply with any statutory or regulatory requirements we are subject to under applicable law;

(b)           to fulfil the purposes for which the personal information was collected, i.e. to carry out analysis into the learning outcomes [and publish the Book];

(c)           to defend our or a third party’s legal rights.

If you have any questions about the retention periods for holding your personal information, please contact us using the details at section 13 below.

11. Your rights and preferences

Please note that we will honour your requests to exercise your rights to the extent possible and required under applicable law. Certain of these rights may only be available to you if you are located in the UK or the EU when you access our Website or otherwise engage with us.

You have the right to:

(a)           Ask us for confirmation of what personal information we hold about you, and to request a copy of that information. If we are satisfied that you have a legal entitlement to see this personal information, and we are able to confirm your identity, we will provide you with this personal information.

(b)           Withdraw your consent at any time if we have relied on consent as the lawful ground to use your personal information.

(c)           Request that we delete the personal information we hold about you, as far as we are legally required to do so.

(d)           Ask that we correct any personal information that we hold about you which you believe to be inaccurate.

(e)           Object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for statistical purposes.

(f)            Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means.

(g)           Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.

Please note that you also have the right to lodge a complaint with your local data protection authority about how we use your personal information if you are located in the UK or the EU. In the UK, this is the Information Commissioner’s Office. Please always consider raising your concern with us first by contacting us using the contact details in section 13 below.

12. Updating this privacy notice

We may update this privacy notice by posting a new version on our Website. If we update this privacy notice in a way that significantly changes how we use your personal information, we will bring these changes to your attention where reasonably possible. Otherwise, we recommend that you periodically review this privacy notice to be aware of any other revisions.

13. How to contact us

Our Privacy Officer is responsible for monitoring compliance with relevant legislation in relation to personal information.  You can also contact the Privacy Officer if you have any questions about this privacy notice or our treatment of your personal information:

Email:  info@ontheedge.org  

Telephone: 020 7043 1673

Post: 152a Walton St, Chelsea, London, United Kingdom, SW3 2JJ