Privacy Policy
Data Processing Notice
01
What personal data is collected
02
Why personal data is collected
03
Where personal data is stored
04
Who Apollo may share your personal data with and why
05
The purpose and lawful basis of personal data processing
06
Your rights with respect to your personal data
Introduction
Apollo Developments Limited (“Apollo”) is committed to providing an optimally safe and informed service, which requires the collection of personal information and processing of personal data. This Data Processing Notice has been made freely accessible to notify clients, referrals, referees and other related parties of the following:
02- How Personal Data is Collected Collected
Apollo collects personal information by the completion of a Referral & Consent Form. Personal information will also be collected in the written session recordings taken after each session.
01- What Personal Data is Collected
Apollo currently collects and processes the following
personal data:
- Full name
- Residential address
- Contact and/or emergency contact details
- Medical information pertinent to physical activity (may include Special Category data)
- If referred, the reason for the referral, what support is provided already and the relevant history of the person (this will often include sensitive, special category and third-party data).
02- How Personal Data is Collected Collected
Apollo collects personal information by the completion of a Referral & Consent Form. Personal information will also be collected in the written session recordings taken after each session.
04- Who Apollo May Share Personal Data With and Why Collected
With the signed consent of the parent or guardian of a young person, Apollo may share personal data with relevant authorities in the best interest of that young person (e.g. their social worker and/or school and/or other support service, etcetera) to ensure their safety and informed, coordinated support is provided.
In accordance with its safeguarding obligations, Apollo may share personal data if information is disclosed by the young person or a family member or other interested party if it is deemed to present a safeguarding concern (see Apollo’s Safeguarding Policy for more information).
03- Why Personal Data is Collected Collected
Most of the personal information Apollo collects or processes is required for at least one of the following reasons:
Service Provision
To provide activities and services, such as registration for programs and activities, communications, and to ensure safe and optimal service provision;
Safeguarding
To comply with legal obligations to protect the safety and wellbeing of young people, such as emergency contact information, relevant history and medical details;
Monitoring, Evaluation, Impact
To monitor the physical and mental health and wellbeing of participants, where appropriate, and evaluate the effectiveness of programs and activities, e.g. gathering feedback, tracking attendance, recording session evaluations, etcetera. This includes recording statistical information to measure and demonstrate the impact of service provision.
04- Who Apollo May Share Personal Data With and Why Collected
With the signed consent of the parent or guardian of a young person, Apollo may share personal data with relevant authorities in the best interest of that young person (e.g. their social worker and/or school and/or other support service, etcetera) to ensure their safety and informed, coordinated support is provided.
In accordance with its safeguarding obligations, Apollo may share personal data if information is disclosed by the young person or a family member or other interested party if it is deemed to present a safeguarding concern (see Apollo’s Safeguarding Policy for more information).
05- The Purpose and Lawful Basis of Data Processing
In compliance with the Data Protection (Bailiwick of Guernsey) Law, 2017, the lawful bases Apollo rely on for processing personal data are detailed in the table below:
Data Processing Activity
Completion of Referral & Consent Forms
Recording of Special Category Data
Disclosure of information for safeguarding and child protection
Sharing of information and ‘signposting’ to other services
Type of Personal Data Processed
General personal data, e.g. name, address, contact details, etcetera
Health data (physical), e.g. medical history, physical capability, etcetera
Health data (mental), e.g. relevant history of referrals, familial situations, socioeconomic status, etcetera
Sensitive ‘special category’ data, e.g., whether the young person self-harms, has SEND, is a young carer, under child protection, etcetera, which is kept confidential and may be presented in anonymity with the informed consent of the young person and parent/guardian
Any information pertinent to the safeguarding of the young person
General personal data, e.g. name, address, contact details, etcetera
Health data (mental), e.g. relevant history of referrals, familial situations, socioeconomic status, etcetera
Lawful Basis of Data Processing
Explicit Consent
Note: Optimal service provision and communication
Explicit Consent
Note: Child’s safety and wellbeing, ensured by disclosure of relevant medical details
Explicit Consent
Note: Child’s safety and wellbeing, ensuring best practice and service provision, ensured by disclosure of relevant history
Authorised Processing of Special Category Data under The Data Protection (General Provisions) (Bailiwick of Guernsey) Regulations, 2018, Regulation 11(1), Schedule 2, Paragraph 4 (a) (iii) Note: Child’s safety and wellbeing, ensuring best practice and service provision
Law
Note: The Children Law (Guernsey and Alderney) 2008, obligation to disclose information to ensure the welfare and safety of children
Explicit Consent
Note: Coordinated service provision and communication
Explicit Consent Note: Child’s safety and wellbeing, ensuring relevant information is shared amongst interested parties as appropriate, e.g. referring organisation, MASH, etcetera
If you are concerned about Apollo’s use of your personal information, you can make a complaint to us directly.
You can also complain to The Office of the Data Protection Authority (ODPA) if you are unhappy with how we have used your data.
The ODPA’s address is:
The Office of the Data Protection Authority
St Martin's House
Le Bordage
St. Peter Port Guernsey
GY1 1BR
Telephone number: 01481 742074
How to Complain
06- Your Data Protection Rights:
Under the Data Protection (Bailiwick of Guernsey) Law, 2017, you have certain rights, listed below:
- Right to information for personal data collected from you
- Right of access
- Right to object to processing for direct marketing purposes
- Right to object to processing on grounds of public interest
- Right to object to processing for historical or scientific purposes
- Right to rectification
- Right to erasure - Right to restriction of processing
- Right not to be subject to decisions based on automated processing
- Right to data portability
For further information on exercising your rights, you can visit the following link: Individuals Rights · ODPA.
If you make a request, Apollo undertakes to respond to you within one month of your request.
Apollo does not charge for the exercising of any right as listed above.
Please contact Apollo directly if you wish to make a request.
How to Complain
If you are concerned about Apollo’s use of your personal information, you can make a complaint to us directly.
You can also complain to The Office of the Data Protection Authority (ODPA) if you are unhappy with how we have used your data.
The ODPA’s address is:
The Office of the Data Protection Authority
St Martin's House
Le Bordage
St. Peter Port Guernsey
GY1 1BR
Telephone number: 01481 742074