1. Introduction
Rainbow Flag Award is a project centrally held by The Proud Trust (a company limited by guarantee, registered in England under company number 05585290, charity number 1161102), in partnership with a selection of other organisations. Current information on partner organisations can be found on the following web page: https://www.rainbowflagaward.co.uk/delivery-partners/.
This document details how your information is used, in line with The Proud Trust’s commitment to protecting personal information provided , and ensuring transparency as to its usage. This Privacy Notice in particular explains:
- What personal information The Proud Trust may collect;
- How that information may be used, both by The Proud Trust and applicable partners;
- Our legal basis for using personal information;
- How we protect the privacy of children and vulnerable people;
- How and when details may be shared with partner organisations;
- Your rights and choices regarding personal information you provide to us.
2. When do we collect personal information?
Personal information may be collected when you:
- Ask about Rainbow Flag Award activities, resources or training;
- Create and account for the Rainbow Flag Award website (for example when registering for access to The Classroom resources);
- Use Rainbow Flag Award services, or sign up to attend Rainbow Flag Award events;
- An account is registered in your name by your school or organisation;
- Telephone, write, contact the Rainbow Flag Award email or delivery partners online, text, or otherwise provide your personal information;
- Submit evidence towards a Rainbow Flag Award, including your contact details.
These above collection scenarios are permitted under current data privacy laws due to the legitimate need to carry out data processing for these purposes, as well as the requirement to perform any contract with your or your organisation.
Personal information may also be inadvertently collected when an evidence submission contains personal information, or personal information that is not sufficiently redacted. Although The Proud Trust and delivery partners request that data be anonymised, organisations are unable to take responsibility for personal information submitted by you.
3. What information do we collect?
Information collected about you by The Proud Trust in relation to Rainbow Flag Award includes your full name, the email address that you provide, and the school or organisation for which you work (or whichever you declare if working across multiple organisations) or are acting on behalf of.
Any other information collected about you will be collected and held by your delivery partner (if applicable), you should check the policies and contact the delivery partner for further details.
Although we ask that any personally identifiable information, particularly that of young people, be redacted from any evidence submitted towards the Rainbow Flag Award, and/or treated in line with your organisation’s data protection agreements, Rainbow Flag Award delivery organisations may inadvertently come to hold information through this means.
The Rainbow Flag Award does not collect or record special category data except in the case of inadvertent data collection via evidence submissions as described above.
4. Why do we collect this information?
The main purposes for which your personal information is held are:
- To enable delivery partners to contact you as an identified contact for an organisation during the course of a Rainbow Flag Award;
- To perform central functions of Rainbow Flag Award, such as returning completed evidence reviews to you as an identified contact for a school or organisation;
- To inform you as a Rainbow Flag Award contact as to the status of your held Rainbow Flag Award following completion;
- To share Rainbow Flag Award marketing materials, as appropriate to your interest;
- To maintain central records and determine interest in resources and products used;
- For legal and regulatory compliance purposes; including in relation to litigation, internal investigations or audits, and to ensure compliance with laws;
- To carry out contractual obligations with you, in relation to Rainbow Flag Award;
- For ‘legitimate business interest’; a reasonable use in line with the aims and activities of The Proud Trust and delivery partners in direct relation to Rainbow Flag Award.
5. Your rights and choices
This section details the following rights related to your personal information:
- The right to request that inaccuracies be corrected;
- The right to request a copy of personal information held about you;
- The right to request us to stop processing your personal data;
- The right to withdraw consent;
- The right to lodge a complaint with the Information Commissioner’s Office or Fundraising Regulator.
You can help ensure records are kept up to date by informing The Proud Trust when your contact details or other personal information changes. Where you have provided consent for the use of your personal information, you also have a right to withdraw your consent. Please contact The Proud Trust via rainbowflagaward@theproudtrust.org to request this, or at the postal address below.
You have a right to request a copy of the personal information held about you by The Proud Trust, or delivery partners (if applicable).
You also have the right to request the removal of your personal information, request that processing of your personal information be restricted, or object to the processing of your personal information.
Whilst The Proud Trust will comply with legal obligations in relation to such requests please be aware that some information may need to be retained for legal reasons, for example if there is ongoing litigation or a reasonable prospect of law enforcement action.
Should you wish to exercise the above right, please provide as much information as possible about the nature of your contact with The Proud Trust, to help locate your records. Useful information may include previous names or aliases you may have been known by, and what ways you have previously had contact with a Rainbow Flag Award delivery organisation in relation to Rainbow Flag Award.
Confirmation of your identity may be requested before releasing any information if we reasonably believe this is necessary to safeguard the personal information.
Please address requests to:
The Proud Trust
The LGBT+ Centre
49-51 Sidney Street
Manchester
M1 7HB
Or to: rainbowflagaward@theproudtrust.org
If your request pertains to personal data held by a delivery partner, please address requests directly to the partner this concerns, referencing their relevant privacy policies for further instruction.
6. How do we protect your personal information?
For information on how your data is protected by The Proud Trust, please see the GDPR Privacy Notice of The Proud Trust at the following address:
https://www.theproudtrust.org/gdpr-privacy-policy/
For information on how your data is protected by other delivery organisations, please see the relevant privacy policies of the organisation(s) of concern.
In instances of inadvertent personal data collection (as described in Section 3) The Proud Trust will inform the submitting organisation of the data shared, and the individual(s) to whom this concerns. It is expected that the organisation will respond to this in line with their own data protection policies and legal responsibilities.
7. Sharing your personal information
Your information may be shared with delivery partners if you are identified as a point of contact for your school or organisation which has signed up to the Rainbow Flag Award or you have been responsible for submitting evidence towards the Rainbow Flag Award for your school or organisation.
When submitting evidence, any information contained therein is sent to the Rainbow Flag Award central email address (held by The Proud Trust) and forwarded – without human review – to the delivery organisation with which your agreement exists.
As such, except in cases where your Rainbow Flag Award agreement is directly with The Proud Trust, information will be shared between the two organisations.
Personal information held within the function of Rainbow Flag Award will only be shared with other organisations outside of the above purposes if:
- There is a requirement to do so under the law, or by a regulator;
- It is deemed necessary and appropriate to respond to a legitimate request of assistance from law enforcement agencies;
- Where appropriate to enforce the rights of a delivery organisation and its volunteers and employees.
Further information on the sharing of personal information, with regards to The Proud Trust, can be found in the GDPR Privacy Notice at the following address:
https://www.theproudtrust.org/gdpr-privacy-policy/
For information on how other delivery organisations share information, please refer to the relevant privacy and data protection policies of the organisation of concern.
8. Where personal information is stored
For information on where personal information is stored, in relation to central functions of Rainbow Flag Award, please review the GDPR Privacy Notice of The Proud Trust at the following address:
https://www.theproudtrust.org/gdpr-privacy-policy/
For information on where other delivery organisations store personal information, please review the relevant privacy and data protection policies of the organisation of concern.
9. Changes to this Privacy Notice
The terms of this policy may be updated at any time, so please review it as appropriate for your purposes. You will be notified of significant changes in the way we treat personal information by sending a notice to the email address you have provided to us, and by placing a prominent notice on the Rainbow Flag Award website. By continuing to use the Rainbow Flag Award website and services, you will be deemed to have accepted such changes.