Privacy Notice for Members and Parents/Guardians

Draft v2 — published temporarily while this policy is pending Board adoption.

Explains how UYN uses the personal data of its members (aged 16–35) and, for members aged 16 or 17, their parents or guardians. Written to be readable by a young person.

Document Control

Status	Draft — pending Board adoption (target: 30 November 2026)
Adopted / Adapted / UYN’s own	UYN’s own. Layout and headings adapted from a school-sector model privacy notice for pupils’ data; all content written for UYN.
Review period	Annually, or when the registration forms change
Responsible lead	Data Protection Lead
Statutory	Statutory and legal (UK GDPR Articles 13 and 14)
Required on website	Yes
Ratified by Board on	[date — to be completed on adoption]
Review due	[date — to be completed on adoption]
Chair of Trustees’ signature	[signature — to be added on adoption]

Change History

Version	Date	Amendment or no change
1	September 2026	Created (UYN Governance & Compliance Policies Pack, first draft)
2	October 2026	Updated and expanded for UYN: document control, numbered sections, appendices and detail added; stale references removed. Registered office address and contact email addresses confirmed (12 October 2026).

Website History

Version	Date on website	Notes
—	[not yet published]	[to be completed when the policy is published on upsurgeyouth.org]

Contents

1. In short 2. Who we are 3. The personal data we collect and use 4. Why we collect and use this information 5. The lawful basis on which we use this information 6. Collecting this information 7. Parents and guardians of members aged 16–17

8. Outcome data and why we track it 9. Mentor matching and opportunity pairing 10. Storing and keeping your data 11. Who we share your information with 12. Your rights 13. Concerns and complaints 14. Changes to this notice

1. In short

The short version • We collect the information you give us when you join UYN so we can support you through the 13-week journey, match you with a mentor and track whether the programme is working. • We ask for some personal information (like your housing situation or health) only if you choose to share it. You can say no and still take part. • We never sell your data. We only share it with employers or training providers if you say yes, each time. • You can ask to see, correct or delete your information, or change your mind, at any time. If you are 16 or 17 you can do this yourself.

2. Who we are

Upsurge Youth Network (“UYN”) is a not-for-profit company limited by guarantee. Our registered office is at 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom, and our programmes are based in Reading, Berkshire. UYN is the data controller for the personal data in this notice. Our Data Protection Lead can be contacted at privacy@upsurgeyouth.org or by post at our registered office.

3. The personal data we collect and use

The personal data we collect from members, and from parents or guardians of members aged 16–17, includes:

Category	Examples	Required or optional?
Identity and contact	Name, date of birth, email, phone, address or area, preferred name and pronouns (if you choose to share)	Required
Programme details	Cohort, registration date, “trigger point” (the reason you joined), goals, availability, membership tier	Required
Education and employment	Education or training status, employment status, skills, CV, interests	Required (some fields optional)
Housing situation	Whether you are currently housed securely, at risk or without stable housing	Optional — shared in confidence
Wellbeing information	Anything you tell us about your health or mental wellbeing	Optional
Equality monitoring	Ethnicity, disability, gender identity, religion, sexual orientation	Optional (you can choose “prefer not to say”)
Mentor matching and sessions	Matching preferences, mentor name, session dates, notes of progress	Required
Outcome data	Progress at registration, week 13 and day 90: for example work, training or housing outcomes	Core progress data required; sensitive parts optional
Emergency contact	Name and phone of someone we can contact	Required
Parent/guardian details (16–17s)	Parent or guardian name, relationship, contact details, consent	Required for 16–17s
Safeguarding information	Concerns raised, referrals made, notes of any safeguarding action	Where applicable
Payments	Name, email and payment confirmation (card details are held by our payment provider, not UYN)	Paid tiers only
Photos and videos	Images from events or sessions	Only with your consent
Website and communications	Cookie choices, device information, emails and messages with us	Automatic / as you send

4. Why we collect and use this information

We use your information to:

• register you and run your place on the 13-week member journey;
• match you with a mentor and support you at your five trigger points;
• help you find opportunities — jobs, training, volunteering — and introduce you to employers or providers (with your consent);
• keep you safe and meet our safeguarding duties;
• check how the programme is working (progress and outcomes) and report anonymised results to funders and our Board;
• take payments and manage your membership;
• contact you about the programme, events and — only if you opt in — updates;
• meet legal and financial duties and handle complaints.

5. The lawful basis on which we use this information

What we do	Lawful basis	Extra condition for sensitive data
Run the programme, match mentors, track progress	Legitimate interests (and contract for paid tiers)	n/a unless sensitive data — then explicit consent
Keep you safe	Legal obligation; vital interests; legitimate interests	Safeguarding of children and individuals at risk
Share your profile with an employer or provider	Consent (each time)	Explicit consent where sensitive
Equality monitoring	Consent	Explicit consent; equality of opportunity
Photos, case studies	Consent (and parent/guardian consent for 16–17s)	n/a
Marketing and updates	Consent	n/a
Payments, accounts	Contract; legal obligation	n/a

Where we rely on consent you can withdraw it at any time — just tell us. Withdrawing consent for something optional will never affect your place in the programme.

6. Collecting this information

Most of the information comes from you (and, if you are 16–17, your parent or guardian) on our registration form. Some comes from your mentor as they support you, and, if you were referred by another organisation and you agreed, from them. Whether you have to give us a particular piece of information is shown on the form; if it is optional we will say so.

7. Parents and guardians of members aged 16–17

If you are 16 or 17 we ask a parent or guardian to complete a consent block at registration. We use their details to confirm consent and to contact them where necessary (for example if we are worried about your safety). You still have your own rights over your data (section 12), and your own choices on optional matters such as photos are recorded separately. See also our Children’s Data Provisions.

8. Outcome data and why we track it

To find out whether the programme is working, we record your progress at registration, at week 13 and at day 90 after the journey. This tells us, for example, whether members have moved into work, training or more stable housing. We use this data in two ways: to support you personally, and — in anonymised, combined form — to report to funders and our Board. We do not publish results about identifiable individuals. Any optional sensitive outcome questions are asked only with your explicit consent.

9. Mentor matching and opportunity pairing

Your mentor will see the information needed to support you. If you would like us to introduce you to an employer or training provider, we will agree with you exactly what profile information is shared and with whom, and ask for your consent each time. We will never share your housing, health or equality information with an employer unless you have said we can.

10. Storing and keeping your data

Your data is stored securely on UYN’s approved systems, with access limited to those who need it. Safeguarding information has tighter access still. We keep personal data only as long as necessary; the proposed periods are in the Data Protection Policy (Appendix 2) and we can tell you what applies to you. In general, member records are kept while you are engaged with UYN and for a short period afterwards, and outcome data is anonymised as early as possible.

11. Who we share your information with

We do not sell your information. We share it with:

• your mentor and the UYN team supporting you;
• our IT, database, email and payment providers, who act only on our instructions;
• employers, training providers and partners — only if you agree;
• local authority children’s or adults’ services, the police or other agencies — without your consent only where we have to, to keep you or someone else safe, or where the law requires;
• funders and the Board — in anonymised form;
• our accountants, insurers and professional advisers, and regulators, where necessary.

If we have to share information for safeguarding reasons without your consent, we will tell you what we are doing and why wherever it is safe to do so.

12. Your rights

You can ask us to:

• show you the information we hold about you (a “subject access request”);
• correct information that is wrong;
• delete your information, or limit how we use it, in some circumstances;
• stop using your information for marketing;
• object to us using your information in a particular way;
• give you your data in a portable format, in some cases;
• withdraw any consent you have given.

If you are 16 or 17 you can make these requests yourself; you do not need a parent’s permission. A parent or guardian can make a request for you only with your agreement, or if we think you could not do so yourself. We will answer within one month. To make a request, contact privacy@upsurgeyouth.org — or ask your mentor to pass it on.

13. Concerns and complaints

If you are worried about how we use your information, please talk to us first — you can contact the Data Protection Lead, or use our Complaints Policy. You can also contact the ICO:

• Information Commissioner’s Office (ICO) — https://ico.org.uk/make-a-complaint/ · Telephone 0303 123 1113 · Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

14. Changes to this notice

We review this notice annually and when our registration forms or practices change. The current version is always on our website, and we will tell you if a change matters to you.

Upsurge Youth Network · Privacy Notice for Members and Parents/Guardians · Draft pending Board adoption  ·  Page