Peeple is a charity, whose main purpose is to support parents/carers, babies and children to learn together, by valuing and building on what families already do. Peep practitioners and families share information and ideas from the Peep Learning Together Programme about how to make the most of the learning opportunities that surround us in everyday life and play. Research shows that this - known as the home learning environment - makes the biggest contribution to narrowing the gap in children's outcomes. So, as well as working directly with families in Oxfordshire, we train practitioners around the UK and beyond, to share the messages as widely as possible. All our work is underpinned by the Peeple principles and the ORIM framework.

“The objects of the Charity [i.e. Peeple's aims registered with the Charity Commission] are for the benefit of the public:

To advance education, in particular (but not limited to) the early learning and development of children; and

To promote, commission, carry out and disseminate research in the field of early years and other education.”

Peeple is a registered charity no. 1144975 in England / Wales and no. SCO44031 in Scotland, and a company limited by guarantee no. 7514469. Peeple has a trading subsidiary company called Peep Learning Ltd which exists to process sales of training and learning resources on behalf of Peeple.

Policy last updated: July 2021

By 'personal data' we mean any information which identifies you, or which can be identified as relating to you personally, for example name, address and email address.

There are a number of different grounds for keeping your personal data, known as the ‘lawful basis’ for data processing. These are:

• Your consent, freely given
• To enter into, or perform, a contract with you;
• To comply with a legal duty;
• To protect your vital interests;
• For our own (or a third party’s) lawful interests, provided your rights don’t override these (otherwise known as ‘legitimate interests’).

In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes) and we will not keep your data longer than is necessary for those purposes.

For more information on your rights to see your data and to correct, update or erase it see the section ‘Your Rights’ below.

At the Peeple Centre in Oxford we employ a few practitioners who work directly with local families. This section relates only to these families; we do not collect any data about families who attend Peep sessions delivered by Peep-trained practitioners in other parts of the country.

Contact details - what we collect and why: We collect information including your name, address, e-mail and contact phone number when you register to come to a Peep group.  The lawful basis for collecting this information is legitimate interests.  We use the information to contact you while we are providing services to you and your family. 

Sensitive data - what we collect and why: We also collect some sensitive data from you such as ethnicity and employment status which is only used for monitoring and evaluation purposes. The lawful basis for this is legitimate interests. We use the information to provide funders with statistics that help them evaluate the benefits of funding Peep groups and to improve our services. Funders require this information as part of their contract with us to provide funding for groups. This data is given to funders as anonymous statistics.  Your name is never given with it.

Occasionally we may collect sensitive data from you that helps our practitioners to support you better, or that is necessary for us to know medically, for example if your child has a nut allergy or is autistic.  This data is collected on the lawful basis of consent.  The practitioner will fill in a form, usually after a discussion with you, which you will get to see and sign. 

How we store your data, and your rights regarding it: All the information we collect from you is stored on our secure electronic database and in locked filing cabinets. 

We will keep this information until your child is five years old and then it will be deleted from our database and any paper records destroyed.

We will never pass your information on to a third party without your permission unless it is a matter of safety for you or your child.

Child protection: If we have any concerns about the safety of you or your child we have a legal duty to pass on our worries to someone who can help.  We will not ask your permission if we are worried but will always tell you what we have done, unless doing so would cause further risk.

Receiving information from another organisation: If you and your family are referred to us by another organisation, that organisation passes information about you, including sensitive data, to us in order that we can provide a service.  That organisation has your consent to give us this information and we hold it on the lawful basis of legal obligation.  This means that because there are safeguarding concerns we are legally required to keep your data in accordance with safeguarding laws.

Dolly Parton Imagination Library: We collect information including your name, address and e-mail address on behalf of the Dolly Parton Imagination Library.  This data is collected in order that the Imagination Library can send your child free books.  The data is stored on the Imagination Library database and Peeple is the data processor not the data keeper.  This data is therefore covered by the Imagination Library Privacy Notice.

Photos and video footage: Sometimes in our groups we take photographs or videos for the purposes of using in Peeple materials, leaflets, on the website or for professional evaluation of our work or staff.  We do this using the lawful basis of consent.  They are stored electronically on our server.  Your pictures or videos will never be used without your permission and you can ask to see them or remove them at any time.  We will keep them indefinitely unless you instruct us otherwise.

Please see our Peeple Early Education and childcare policies page.

When you book a place on Peep Training we collect information including your name, role and contact details (address, phone number, and your and your manager’s email). This is usually your work rather than home contact details. If you opt for us to post your training pack to your home address, this address is deleted from our system at the end of the course. We record the information you have provided on our internal contacts database for use in administration of training. We share your information (not home address) with the freelance trainers who deliver training under contract from us, but no-one else. We cross-shred printed personal data at the end of the course.

Post-course contact: Some of our courses include access to log-in areas on our website, to support your delivery of the programme(s). This is known as membership, for which there is currently no charge. We hold the information that you complete in the Practitioner Declaration during the training and on the online registration form (work contact and training details) for as long as you renew your membership. Each year we also ask you to complete an online membership renewal questionnaire. This enables us to:

• share good practice with practitioners and organisations;
• learn more about what post-course support you do/don't find helpful;
• update our awareness of what Peep is happening where - enabling us to let practitioners and families know if Peep is happening near them
• report to [potential] funders, who are interested in funding work that supports the home learning environment and early intervention.

Annual log-in renewal: If you decide not to renew your annual membership or there is no response within 18 months of the renewal date, then we will remove your personal details and therefore your access to the log-in area of the website. We will keep basic information about individuals who have attended Peeple training on our contacts database for five years from the date of the training to enable us to grant you membership or other services related to the training, such as refresher training, as practitioners' roles often change. You can ask us to remove your data from our system at any time.

We do not share information about our members or training delegates with any other third parties without your prior permission. We will never sell your information or give our mailing list to a commercial organisation.

Post-course newsletter: Practitioners/members and their managers will be sent Peeple newsletters by email, approximately monthly, as part of our post-training support. We include managers as it raises the quality of delivery when managers understand more about Peep programmes and how they can be used. The newsletters contain news, information and updates that support Peep delivery. There is always an Unsubscribe link in the e-newsletter, so you can opt out at any time.

We may analyse our membership data to determine common characteristics and preferences. We do this by assessing various types of information including behaviour (e.g. previous responses) or demographic information (e.g. location). We may compile statistical data from time to time; this will never include any references to any individual.

Under GDPR, the lawful basis for the above (regarding training and membership) is our legitimate interests.

As part of the registration, assessment and certification processes for the AIM Unit: Supporting Parents and Children to Learn Together, we collect information including your name, date of birth, gender, address, e-mail, contact telephone number(s), completed portfolio and records of internal quality assurance activities.  This data is collected on the lawful basis of the contract we have with you to accredit your learning.  We use the information to provide you with services to support the completion of your accreditation.  

As indicated on the Learner Registration Form, the course is accredited through Peeple (approved by AIM Qualifications and Assessment Group).  We use your name, gender, date of birth and qualification information to enrol you on the course with AIM.  AIM assign you a unique learner number (ULN) which is used in relation to your learning, assessment and certification. 

In exceptional circumstances we may also collect and transfer to AIM sensitive personal data, such as: 

• information about your physical or mental health condition – to comply with our duty under the Equality Act 2010 and enable us to administer requests for reasonable adjustments to support your learning and assessment.
• information relating to an investigation, complaint or appeal – to allow us and/or AIM to make an informed response.

This additional sensitive data is collected on the lawful basis of consent.  As such, you will need to complete a form following a discussion with a Peeple trainer/ staff member.  The form will require you to give your explicit consent for the sensitive personal data you have shared to be held by us and transferred to AIM for the purposes outlined above.

All the information we collect from you is stored on our secure electronic database and in locked filing cabinets to which only authorised staff have access.  Hardcopy portfolios are scanned and stored electronically for quality assurance activities. 

We pass your information to freelance assessors who assess portfolios under contract from us as necessary to enable us to provide accreditation services to you.  Completed learner portfolios are shared securely with an allocated assessor either electronically, or sent and returned by post using the Royal Mail Signed For® service.  Assessors are required to store all off-site learner and assessment data securely and within a locked location throughout the assessment process; password protected equipment must be used for electronic assessment.  Once assessment is complete, assessors are required to return, delete and/ or destroy all learner and assessment data.   

We acknowledge that the content of your portfolio, whether it be hardcopy, scanned or an e-portfolio, is your property and remains so after certification.  Hardcopy portfolios will be returned to you along with your certificate of achievement on successful completion of internal quality assurance activities.  At this point we may contact you to seek your permission to retain an anonymised copy of your portfolio for training and marketing purposes.  Scans of hardcopy portfolios, e-portfolios and additional evidence received as a result of remediation will be retained until the annual External Quality Assurance (EQA) visit from AIM has taken place following certification, after which it will be deleted.

All other information will be kept for 3 years following certification in case any issues arise and for regulatory compliance purposes.

All personal data and sensitive personal data transferred to AIM will be processed in accordance with their Record Keeping Policy (available at www.aim-group.org.uk/privacy/ )

We will never pass your information on to a third party without your permission.  

Reviewed/ updated: November 2022

Learners Your delivery centre collects information including your name, date of birth, home address, email/mobile/landline number, course title and course level, your child's name (if in keepsake book/portfolio) and photos and/or drawings provided.  This data is shared Peeple under the lawful basis of the contract you have with us.  Some of this data is also collected under the lawful basis of legitimate interests.  This allows us to register you as a learner for the Peep Progression Pathway and certificate your achievements.  We also keep a copy of your keepsake book/portfolio on our database for quality assurance purposes.

We record the information you have provided on Peeple’s database for:

• use in administration of Peep Progression Pathway units
• anonymously reporting to our funders 
• adhering to quality assurance procedures required by the Scottish Qualifications Authority (SQA)

The data is stored on Peeple's database, which is owned by Peeple and hosted by Lamplight Database Systems.  Lamplight is an online database system that helps charities across the UK to manage their services.  The database is password protected - only accessible to authorised staff Lamplight provides occasional technical support to assure the efficiency of the database.)

You will receive no communication directly from Peeple, unless you have submitted an appeals complaint to us, or if you have contacted us directly.

Your keepsake book will be kept for  15 months to allow time for the annual external quality assurance visit.  

All data except your email/mobile/landline number will be kept for 20 years to allow us to re-issue your certificate in the future should you need it, and in case you decide to return to a Peep course in the future with children or grandchildren.  Your email/mobile/landline number will be kept for 15 months.

We will not share information about our learners with any other third parties without their prior permission.

We may analyse our learners to determine common characteristics and preferences. We do this by assessing various types of information including learning level or demographic information (e.g. location). We may compile statistical data from time to time; this will never include any references to any individual.

We will never sell your information or give our mailing list to a commercial organisation.

If you have given permission, we may share your keepsake book with other organisations who might offer the Peep Progression Pathway in their area.  Your keepsake book may be used to help us to train more staff in how to deliver the Peep Progression Pathway.  Your keepsake book may be taken to conferences and events and be displayed to promote Peep programmes.  Your portfolio would be used under the lawful basis of legitimate interests.  You can withdraw permission at any time by emailing pathway@peeple.org.uk.

Assessors, Peep Practitioners and Internal Quality Assurance Officers Your name, work address, email, mobile/landline number, qualifications and experience and training event details will be held on the Peeple server and Peeple database (password protected - only accessible to authorised staff).  Training event details will be kept for three years.  All other data will be deleted when you are no longer involved in the delivery of the Peep Progression Pathway.  Your data is held under the lawful basis of legitimate interests.

Peeple will never collect or use data for research purposes without the specific written opt-in consent from participants in advance of research commencing. Data collected as part of research will be kept on file at Peeple until the scheduled end date of the piece of research as agreed with the funder. Additional privacy information will be provided as necessary based on the nature of the specific piece of research.

If the research involves attending Peep training and participants register for a website login and sign up as members, the advice (above) regarding ‘Practitioner training and membership' also applies.

Introduction

The Peep Exploring Together Programme - supporting the foundations of Science, Technology, Engineering & Maths (STEM) provides a package of training and resources to early years practitioners and families. The programme encourages parents to identify and make the most of STEM opportunities that are part of their everyday life – and then to explore these with their children in fun and engaging ways.

Peeple have received funding to develop and evaluate the Exploring Together Programme from a grant issued by the Mercers’ Company, as part of their philanthropic special initiative in Early Years, Literacy and Transitions. In this Privacy Notice, Peeple are referred to as the ‘Delivery Team’.  The independent evaluation is a collaboration between the University of Oxford and the Institute for Employment Studies (IES). Together, these parties are referred to as the ‘Research Team’ in this Privacy Notice.

The roles of each party named above are as follows:

• Mercers’ are the funders of the evaluation project.
• Peeple are responsible for designing the programme and providing training to the practitioners and parents/carers so that they each can implement it within their practice (in settings and homes).
• IES and the University of Oxford will evaluate the programme; focusing on practitioners and their views of the training/resources and of children’s engagement with the intervention and parents/carers and the home learning environment, particularly in maths and science.
  The evaluation will enable an assessment of whether the programme could be implemented at a larger scale.

In line with the EU General Data Protection Regulation (GDPR), this privacy notice sets out how the Delivery Team and Research Team will collect and use your personal data, and who you can contact with a query or a complaint.

We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it and let you know of any material changes to this notice.

What is the legal basis for processing my data?

Peeple and the University of Oxford are data controllers. IES are data processors.
Peeple’s legal basis for processing personal data is legitimate interests’ under Article 6 (1) (f) of the General Data Protection Regulation (GDPR). The evaluation of the Exploring Together Programme fulfils one of Peeple’s core business purposes (undertaking training, research, evaluation and information activities) and is therefore in our legitimate interest, that processing personal information is necessary for the conduct of the evaluation. The legal basis for the University of Oxford collecting personal data is ‘public interest task’ under GDPR Article 6(1)(e). This research will build on existing work by the Department of Experimental Psychology at the University of Oxford finding out about what might support learning and development in the Early years.

What kind of information do we collect?

The research will involve:

• Online questionnaires being sent to all parents to complete and return electronically (paper copies will be made available to parents but all data transferred will be electronic)
• Interviews with key staff (e.g., settings managers and practitioners) in case study settings
• Interviews with parents/carers in case study settings, who have consented to take part
• Review of training programme and materials provided online by Peeple
• Analysis of data from the Delivery Team.

What data are being collected, by who and why?

The Delivery Team will collect the following personal data from settings for the three groups below.

1. Parents/carers - name, email address, telephone number(s)

These data, given by consent, will be passed securely to the Research Team via a secure data transfer system. The reason why these data are being collected is:

1. to confirm parents/guardians’ agreement to take part in the independent evaluation and facilitate their participation in the Exploring Together Programme.
2. to send parents/guardians a questionnaire at the beginning of the study which will include questions on the home learning environment, particularly relating to maths and science, and optional questions about family background.
3. to send parents/guardians a questionnaire at the end of the study, again including questions on the home learning environment, particularly relating to maths and science and
4. to contact the parents/guardians to arrange a telephone interview to gather their views and opinions of the training.

2. Key staff and practitioners - name, email address, telephone number(s), consent.

These data, with explicit consent, will be passed securely to the Research Team via a secure data transfer system. Personal data of key staff and practitioners will only be collected where it is necessary: either to send invitations to participate in the research or where it is relevant to the interview to contextualise their responses.

The reason why these data are being collected is to gather staff views and opinions of the training.

3. Children – name, age in months, gender.

The child’s name will be collected, stored securely and held solely by the Delivery Team for the purpose of analysing data and creating named certificates.  This data will NOT be passed to the Research Team.

The child’s age in months and gender will be passed securely to the Research Team via a secure data transfer system. Personal data of children will only be collected where it is necessary: to analyse their data.
Data shared with the Research Team will be stored in de-identified form (i.e., using a numerical unique identifier). A key file with the participants’ names, setting name and parents details will be kept securely and separate from the data file.

How will my data be treated?

We take all reasonable steps to protect your personal information and follow procedures designed to prevent unauthorised access, alteration, loss or disclosure of your information. Where personal information is collected, these details will be stored on an encrypted server with access restricted solely to Peeple staff who are part of the project team.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If you are invited by IES, and choose to take part in an interview, survey, assessment or case study for this project, the data you give will be used for research purposes only. In reporting, no individuals or settings will be named, nor will any information be included that could reveal your identity, except with your explicit permission.

IES will produce a report that summarises the main findings from all these research activities.
The University of Oxford will prepare data for submission to a peer reviewed academic journal.
The Research Team may decide to disseminate more widely.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. Personal information, interview and survey responses will be securely deleted:

• Peeple and the University of Oxford retain data for 3 years after primary and secondary data analyses (impacts of the intervention on the Home Learning Environment with regard to maths and science) have been published (deletion currently estimated to take place in March 2027)
• IES retain data for six months after the research project is complete (deletion currently estimated to take place in September 2024)

Who else has access to your information?

The Research Team may disclose your information to third parties in connection with the purposes of processing your personal data set out in this notice. These third parties may include suppliers, research assistants, trusted academic partners and subcontractors who may process information on behalf of the Research Team to carry out such work as undertaking interviews, analysing data, or transcribing interviews. In all cases, the Research Team will ensure that these third parties enter into appropriate data processing agreements with us and that they keep your personal data secure and confidential.

We may disclose your personal information if required by law, or to protect or defend ourselves or others against illegal or harmful activities, or as part of a reorganisation or restructuring of our organisations.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the rights to:

• Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it.
• Withdraw the information you have provided as part of the interviews or survey up to two weeks after you have submitted your response.

Please see the Information Commissioner’s Office website for a full description of your legal rights.

If you wish to exercise any of the rights set out above in connection with this research project, please contact Janet Sly, Finance and HR Manager at Peeple at

Janet.sly@peeple.org.uk

Alternatively, further information about your rights with respect to your personal data is available from the University of Oxford:

https://compliance.web.ox.ac.uk/individual-rights

Who can I contact with a query about how my data will be used?

If you have any questions about how your data will be used, please contact the Research or delivery team:

• Katy Baker, Project Manager, Peeple (katy.baker@peeple.org.uk  /  07825 775459)
• Ceri Williams, Research Manager, IES (ETPSTEM@employment-studies.co.uk  / 01273 763407)
• Alexandra Hendry, University of Oxford (alexandra.hendry@psy.ox.ac.uk)

Who can I contact with a complaint?

Under GDPR, you have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact Peeple in the first instance.

Company details for the Delivery and Research Teams

Peeple is a charity registered and a company limited by guarantee in England & Wales.

• Charity registration number: 1144975
• Company number: 07514469.
• Registered office: The Peeple Centre, Littlemore, Oxford OX4 6JZ
• Email: info@peeple.org.uk

The Institute for Employment Studies is a charitable company limited by guarantee registered in England.

• Registration number: 931547
• Charity registration number: 258930
• Registered office: Institute for Employment Studies, City Gate, 185 Dyke Road, Brighton, BN3 1 TL6
• Email: askIES@employment-studies.co.uk

The University of Oxford is a University in England.

• Medical Sciences Interdivisional Research Ethics Committee; Address: Research Services, University of Oxford, Boundary Brook House, Churchill Drive, Headington, Oxford OX3 7GB
• Email: ethics@medsci.ox.ac.uk

Newsletters: Peep-trained practitioners and their managers will be sent Peep Postings newsletters and our general newsletter as part of their membership (see above). Other people may subscribe to our Peeple newsletter by opting in to join our mailing list (lawful basis: consent). Anyone can unsubscribe from Peeple newsletters at any time by clicking the Unsubscribe button.

Enquiries: If you enquire about Peep Training or resources, we keep your details on our internal system for up to two years, so that we can respond to follow-up enquiries.

When you place an order with us via our on line shop or by any other means such as an emailed order form, we ask for your name, address, email and phone number to enable us to process your order. We may also use this information to contact you with information about new products or training unless you advise us otherwise. Information relating to your purchase will also be kept on our finance system, Quickbooks, for up to 6 years for tax and audit purposes.

Employee records: we keep both electronic and paper details of employees to fulfil our legal obligations in relation to contracts of employment, payroll and pensions.

We share employee information Tax Assist Payroll services who have an agreement with us to process payroll and pensions data.

Employee data will not be kept longer than necessary to comply with legal and statutory obligations which in the case of payroll is 6 years from the end of the relevant tax year. A separate records retention schedule details other retention periods.

Any additional information which is not required for the above purposes, e.g. use of photographs, will require employee consent.

Volunteer and trustee records: we keep both electronic and paper details of volunteers and trustees under the lawful basis of our legitimate interests.

Freelance consultants including Peep trainers and assessors: we keep electronic details of trainers and assessors (name, address, email, phone, CV) and each consultant signs a letter of agreement covering the nature of their work for Peeple, its duration etc. The lawful basis for this is contractual.  Consultant data will be kept for the duration of their work for Peeple and for a further 6 years from the end of the last relevant tax year in case it is needed for tax or related reasons.

Job applicants: enquiries and application forms from unsuccessful candidates will be kept for a period of 6 months from the end of the selection process.

Register of interest: anyone interested in hearing about future vacancies or volunteering opportunities (including unsuccessful job applicants) may register their interest on our Register of interest form. Details will be kept both electronically and on paper for a period of 18 months.

Historical records: we keep information on senior personnel such as trustees and directors indefinitely for the purpose of historical records.

Under the GDPR, you have various rights with respect to our use of your personal data:

Right to Access

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if there is no basis for your request, or if it is excessive.

Right to rectification

We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Contact details:

If you wish to find out more about the information we hold about you, contact us in connection with your rights or you have any questions about this Privacy Policy and Cookie Statement, please email:

dataprotectionlead@peeple.org.uk

or phone 01865 395145