Holiday activities and food programme

Holiday activities and food (HAF) programme privacy notice

Information held about you

The London Borough of Bromley works with delivery partners, including Eequ, as part of the Government’s Holiday Activities and Food (HAF) programme. The programme provides holiday activities and healthy meals for children and young people aged 5 to 16 who are eligible for benefits‑related Free School Meals (FSM).

To deliver the HAF programme safely and effectively, we need to collect and process personal information about children and their parents or carers. The information we may collect includes:

  • Child’s full name
  • Date of birth / age
  • Eligibility for benefits (e.g. Free School Meals)
  • Home address
  • School attended
  • Gender
  • Ethnicity
  • Any health, dietary or additional needs required to keep children safe and supported

This information is collected from parents/carers and HAF providers to enable participation in the programme.

Who is processing my data?

All personal data is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  • Data Controller: London Borough of Bromley
  • Data Processor: Eequ (acting on behalf of Bromley Council to administer bookings and programme delivery)

Eequ processes personal data only in line with Bromley Council’s instructions and applicable data protection law including its privacy policy.

How will we use this information about you?

We use personal information to:

  • Assess eligibility for the Holiday Activities and Food programme
  • Match children and families with appropriate HAF provision
  • Share relevant medical, dietary or additional needs information with providers to keep children safe
  • Coordinate programme delivery across council, voluntary and community partners
  • Contact parents/carers with important updates related to the HAF programme

What is the legal basis for processing your data?

The processing of personal data for the HAF programme is necessary for the council to carry out its public task. The lawful basis for processing under UK GDPR is:

  • Article 6(1)(e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

This processing supports the delivery of the HAF programme in line with Department of Education (DfE) guidance.

Who may we share information with?

We may share your information with:

  • HAF activity providers that you have chosen for your child
  • Council services and voluntary/community organisations involved in delivering support
  • The Department of Education, in anonymised form, for mandatory HAF monitoring and reporting

We will only share information where necessary and on a need to know basis. Information will not be shared with third parties unless permitted or required by law, or where necessary to safeguard children or individuals at risk.

How long do we keep your information for?

We will retain personal data only for as long as necessary to:

  • Manage HAF bookings and delivery
  • Meet reporting and audit requirements
  • Allow families to re-book future HAF provision without re-entering information

Data stored within the Eequ booking platform is retained in line with the Data Processing Agreement between Bromley Council and Eequ. All information is stored securely and disposed of confidentially when no longer required.

What are your data protection rights?

You have rights under data protection law, including the right to:

  • Access your personal data
  • Request correction of inaccurate information
  • Request deletion or restriction of processing, where applicable

Requests relating to your personal information should be made to Bromley Council’s Information Governance Team at Data.Protection@bromley.gov.uk or write to: Data Protection Officer, Chief Executive’s Department, Civic Centre, Churchill Court, 2 Westmoreland Road, Bromley, BR1 1AS to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

You also have the right to raise concerns with the Information Commissioner’s Office (ICO)

Providing accurate information

It is important that the information we hold is accurate and up to date to ensure safe delivery of services. If your details change, please inform us as soon as possible so records can be updated.

Further information and contact details

If you have questions or concerns about how your information is used in relation to the HAF programme, please contact the HAF team at HolidayActivitiesandFood@bromley.gov.uk in the first instance.

You can also find general information about how Bromley Council handles personal data in the Education Privacy Notice and GDPR Statement.