Data controller: Greater Manchester Combined Authority, Churchgate House, 56 Oxford Street, Manchester M1 6EU
ICO registration reference: Z5119967
Customer enquiries contact details: firstname.lastname@example.org
Data Protection Officer: Phillipa Nazari, Greater Manchester Combined Authority
The Greater Manchester Combined Authority (GMCA) is made up of the ten Greater Manchester councils and the Mayor of Greater Manchester.
We work with local councils in Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside and Trafford, to inspire and encourage the residents of Greater Manchester to manage their waste responsibly, helping residents to see the value of waste and the real benefits that can be achieved by wasting less and recycling right. (Though part of Greater Manchester, the Metropolitan Borough of Wigan administers its own waste disposal operations).
The GMCA Recycle for Greater Manchester gallery competition allows primary school children aged 4 to 11 years old to upload an image of some sort of recycling activity. For example, it could be an image of picture they have drawn, poem they have written, or a photograph of their recycling collections at home. The child will be assisted by a responsible adult at home to upload their image. Every a month a winner will be selected and a prize awarded.
The GMCA is running this competition and this means that for data protection purposes they are the data controllers, for the information they will use to manage the competition. However Facebook, Instagram, Twitter and their relevant subsidiaries will be considered the data controllers for the information you provide to have the relevant social media account.
The GMCA will use the information listed below to manage the Recycle for Greater Manchester Gallery competition. This will include entry into the competition and later notification to winners. Winners will be asked to provide contact details to enable the prize to be issued to them.
If you are the winner of a prize, the GMCA would also want to publish your child’s winning image on social media, along with their first name and age. However you will be consulted about this at the time you are notified of your prize. You will have the ability to refuse the upload of the image to social media.
Facebook, Instagram, Twitter and their relevant subsidiaries as data controllers for their respective social media platforms, will use your information for other purposes. If you want further details of how they will use your information you will need to check their Data Policies. Links to these can be found below.
Instagram – Data Policy
Facebook – Data Policy
Twitter – Data Policy
The GMCA will collect the following details in order to process and upload the gallery image and display it on the Recycle for GM website. The details will also be used to establish that those entering the competition are within the GM remit and to contact the responsible adult of the child whose image has won the competition that month:
• First name of the child
• Email address of Responsible Adult
• District in which the child resides
The GMCA may also collect (if the child is the monthly winner):
• Address of Responsible Adult
• Name of Responsible Adult
The request for the District in which the child lives, is to make sure that any prize winners live within the Greater Manchester area and are eligible for the competition.
The remaining information will be used to make sure the GMCA is able to provide the winners with their prize.
As a separate activity ,R4GM operate a quiz activity that has two functions:
• Members of the public including children, can complete the quiz without submitting any personal data
• Certain members of the public will have been given a code that submits their quiz results into a competition. The code will not identify any individual but will identify the group with whom they participated in an R4GM education activity. The original booking details (contact of group leader) will be used to contact this group if they were to win the monthly quiz competition. This privacy notice also covers the use of that contacts information
4. Why we will use your information and our legal basis for using it
As the GMCA have responsibilities for waste disposal, improving recycling and for the wellbeing of Greater Manchester residents, the legal basis for undertaking using your information for this competition will be:
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 vested in the controller
Facebook, Instagram, Twitter and their relevant subsidiaries as data controllers for their respective social media platforms, will use your information for other purposes. They will also be using a different legal basis for managing your information. For more information on these, please go to their Data Policies.
The GMCA are committed to the security of the information we collect. We aim to ensure that there are appropriate, physical, technical and managerial controls in place to protect any personal information you may provide to us, for example our network is protected and monitored. Within our offices all of our staff receive training on handling data securely.
Where we use external companies to collect or process data on our behalf we carry out comprehensive checks on them before we work with them and ensure that contracts are in place that set out our expectations and requirements.
The GMCA will keep information of those who have not won the months competition for two weeks after the winner has announced and will then securely delete the information. Responsible adults whose child has won the competition that month, their data will be kept until the end of the calendar year .This is to monitor the number of wins of any one particular child as a child can only win the competition three times in a year. Therefore the data needs to be kept to check that the child has not exceeded the competition wins. At the end of that calendar year, the data will be securely deleted.
Facebook, Instagram, Twitter and their relevant subsidiaries as data controllers for their respective social media platforms, will keep your information for a longer period. For more details on how long they keep your information, please go to their Data Policies.
We may publish limited personal information about the winners of our competitions and prize draws on our social media sites which are hosted in the United States. Facebook (including Instagram and Facebook), Twitter and Google (including YouTube) are all certified under the EU-US Privacy Shield Framework and this is the safeguard we rely on when transferring your personal data for this purpose.
The information collected as part of this competition will only be used by the GMCA for the purposes explained.
Facebook, Instagram, Twitter and their relevant subsidiaries as data controllers for their respective social media platforms, may share the information they collect. For more information on how they will share your data, please go to their Data Policies.
The GMCA must comply with the General Data Protection Regulations (GDPR) and the Data Protection Act 2018.
Under data protection law, your rights include:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
If you wish to make a request, please contact us at:
Email – email@example.com
Postal – Office of the DPO GMCA, Broadchurch House, 56 Oxford Street, Manchester, M1 6EU
The GMCA will only be able to comply with your rights in relation to the information they have collected.
Facebook, Instagram, Twitter and their relevant subsidiaries as data controllers for their respective social media platforms, will have to be contacted separately to exercise your rights. For more information on how to do this, please go to their Data Policies.
If you are not satisfied with how the GMCA is using the information we hold about you please contact our Data Protection Officer by emailing firstname.lastname@example.org.
If you are still not satisfied with the GMCA’s response to any request to exercise your individual rights or if you believe that the GMCA is not processing your personal data in accordance with the law, you can contact the Information Commissioners’ Office:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
For more details on how the GMCA will use data please visit the GMCA Website
If you want to make a complaint to Facebook, Instagram, Twitter and their relevant subsidiaries as data controllers for their respective social media platforms, please go to their Data Policies. If you are not satisfied with their response you may also contact the Information Commissioner’s Office as stated above.