Privacy Policy
for Adults
In short:
We collect only the information needed to receive a child's letter, write and deliver a response, manage the Campaign safely and deal with questions. We do not use Campaign information for marketing without separate permission.
1. Who is responsible for the information
Epicurean Dairy (UK) Limited (company number 07614134), trading as The Collective, is the controller of personal information used for the School Letter Swap Campaign. Its registered office is YVHQ, Rhodyate, Blagdon, Somerset, England BS40 7YE.
For Campaign privacy questions or to exercise a data protection right, email letterswap@thecollective.co.uk.
You may also use The Collective's general contact email address at hello@thecollectivedairy.com.
2. Whose information this notice covers
This notice covers information about children aged 4 to 8 who take part and their parents or legal guardians. A separate short notice explains the same points in child-friendly language, please find this [here].
3. Information we collect
We do not ask for the child's surname, exact date of birth, school name or address, health information, ethnicity, religion, passwords or other unnecessary sensitive information. We also do not invite children to share worries, concerns or requests for advice within their letters.
Parents should check the letter before submission and remove these details. Because the letter is free text, we understand a child may nevertheless include unexpected personal or sensitive information, however we urge supervisory parents to check responses to ensure information of this nature is not disclosed.
If insufficient information is provided (for example, no return address or no child’s first name), The Collective will be unable to prepare or send a response.
4. How we receive the information
For postal entries, the parent or guardian sends the child's letter and return address through Royal Mail. For online entries, the parent or guardian completes the parent gateway and the Campaign form embedded on The Collective's Wix website.
5. What we use the information for and our legal bases
A parent may withdraw consent by emailing us. If the response has not yet been prepared or sent, we will stop consent-based processing and delete the routine Campaign information where possible. Withdrawal does not affect processing that was lawful before withdrawal or information we must retain for a safeguarding concern, complaint or legal obligation.
6. Who may see or receive the information
Access is limited to people who need it for the purposes above, including:
• Trained members of The Collective Campaign team and approved temporary staff;
• Wix, where it hosts the page or stores/handles form data, and Microsoft 365/Exchange Online, which hosts the restricted Campaign mailbox;
• Royal Mail and other delivery providers, to transport letters and replies;
• The Campaign's designated child psychologist, safeguarding advisers or legal advisers where their input is needed, using the minimum identifying information possible; and
• Emergency services, local authorities, regulators, courts or other appropriate bodies where sharing is necessary and lawful to protect someone, comply with the law or deal with a claim.
We do not sell Campaign information.
We do not publish a child's letter or identifying information, and we do not use Campaign information for direct marketing.
Wix and Microsoft may process personal data on servers outside the UK. Where this occurs, the transfer is protected by appropriate safeguards under UK data protection law, including UK adequacy regulations or, where required, the European Commission’s Standard Contractual Clauses together with the UK International Data Transfer Addendum.
7. How long we keep information
The operational aim is to keep routine Campaign information for the shortest practical period:
• Routine fulfilled entries: reviewed weekly and securely deleted from active Campaign systems, and paper letters confidentially shredded, once the response has been dispatched and any short operational check is complete. The target is within seven days after fulfilment.
• Unfulfilled entries: kept only until the reply is prepared and dispatched, or until it is established that no response is available, then included in the next weekly deletion cycle.
• Safeguarding concerns, complaints and legal matters: separated from routine entries, access-restricted and retained only for a longer period that is documented and justified for that specific purpose.
• Minimal non-content fulfilment record: if needed to demonstrate the 1,500 postal-response cap, dispatch or complaint handling, kept to only the minimum fields and to a defined a short deletion date in our DPIA.
Provider recovery windows
8. Security
The Collective will use role-based access limited to named staff; multi-factor authentication where available; a dedicated restricted mailbox; locked storage for paper letters; confidential shredding; staff and temporary-worker training; a safeguarding escalation route; and a decision log for concerning submissions. Campaign information will not be downloaded to personal devices, forwarded to personal accounts or used in public galleries, voting, comments, chat or social sharing.
We do not use automated decision-making or profiling in connection with the processing described in this notice. All decisions about responses, safeguarding and Campaign administration are made by trained members of The Collective’s Campaign team.
9. Children's and parents' rights
Depending on the circumstances, the child and parent may have rights to ask for access to personal information, correction, deletion, restriction, portability, or objection to certain uses, and to withdraw consent. A parent or guardian may contact The Collective on the child's behalf. We may ask for proportionate information to confirm identity and authority before acting.
10. Complaints
You have the right to make a complaint directly to The Collective about how we handle personal information. To make a complaint, please email hello@thecollectivedairy.com setting out your concern. We will acknowledge your complaint and provide a substantive response within one month of receipt, or inform you if we need more time.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s independent supervisory authority for data protection. You can contact the ICO at ico.org.uk, by telephone on 0303 123 1113, or by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. This right is in addition to any other legal remedies available to you.
For general Campaign questions that are not data protection complaints, please also use letterswap@thecollective.co.uk
11. Changes to this notice
We may update this notice if the Campaign systems or processes change. Any material change will be assessed before implementation and the current notice will be published on the Campaign page. We will not use Campaign information for a new incompatible purpose without providing the required information and obtaining any permission required by law.
Information | What it is needed for |
|---|---|
Child's first name | To address and personalise the postal or digital response. |
Child's letter or drawing | To understand what the child has written and prepare an appropriate response. It may contain personal information the child chooses to include. |
Return postal address | To post the response package. |
Parent or guardian email address | For online parent verification, Campaign administration, sending a digital response where applicable, safeguarding contact where appropriate, and responding to queries. It is not added to marketing newsletter lists through this campaign. |
Parent or guardian confirmation/consent record | To demonstrate adult oversight, consent to data processing and parental authorisation for a child under 13. |
Submission and fulfilment records | To manage the 1,500 postal-response limit, prevent duplicates, record whether a response was postal or digital, and handle questions or complaint |
Limited technical and security data | Wix, Microsoft or their infrastructure may process IP address, device or log data to deliver and secure the service. Campaign geolocation analytics will be disabled where technically available. |
System | Description |
|---|---|
Paper letters | Routine fulfilled letters will be shredded through the weekly disposal process. A safeguarding or legal record must be separated and retained under its own justified schedule. |
Microsoft 365 / Exchange Online | After an item is permanently deleted from the mailbox interface, Exchange Online keeps it in Recoverable Items for 30 days by default. |
Wix | Wix form submissions will be deleted from The Collective’s interface, although items moved to its Trash tab may remain recoverable there for 180 days. |
Purpose | Proposed lawful basis |
|---|---|
Provide and secure the website and mailbox | Our legitimate interests in providing a safe, reliable service. Non-essential analytics and geolocation tracking should be disabled for the Campaign. |
Handle complaints, legal claims and regulatory duties | Legal obligation and/or our legitimate interests in establishing, exercising or defending legal rights. |
Identify and respond to a safeguarding concern | Our legitimate interests and, for genuinely urgent life-or-death situations, vital interests. If special category information must be used for safeguarding, the proposed condition is UK GDPR Article 9(2)(g) with Data Protection Act 2018 Schedule 1 paragraph 18, where its tests are met. |
Run the Campaign fairly, manage the 1,500 postal-response cap and any additional digital replies, prevent misuse and keep basic fulfilment records | Our legitimate interests in administering a fair, secure and accountable Campaign, balanced against the child's rights and best interests. |
Receive and administer the submission; personalise and send one response | Consent, provided by the parent or legal guardian for a child under 13. The parent verification step must record an active, verifiable confirmation before online data collection. |
