Media Privacy Policy

About us

We’re Khulisa (which means ‘to nurture’ in Zulu), a national youth and rehabilitation charity dedicated to helping young people and adults with complex needs to live healthier, crime-free lives. Khulisa is a registered charity (no. 1120562) and company limited by guarantee (no. 6210432). We deliver emotional and social wellbeing programmes, therapeutic support and mentoring to young people and adults with complex needs in schools, prisons and the community. We also deliver  training on the effects of trauma to professionals working with these young people and adults, such as teachers, prison officers and social workers.

At Khulisa, we are committed to protecting and respecting the privacy of the people we work with. 

This media privacy policy sets out:

  • when and why we take photographic images or video footage in the course of our work;
  • where these images or video footage will be used, published or broadcast; 
  • how long we keep photographic images or video footage; 
  • the personal data we collect about you and/or the young person in your care when completing a media consent form;
  • your rights over the photographic images or video footage featuring you or the young person in your care; 
  • your rights over the personal data we collect in the media consent form; and
  • copyright information. 

This media privacy notice is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).

Contacting us

If you have any questions regarding this media privacy policy, these can be sent to our Data Protection Officer via our contact form on our website, by email with ‘media privacy policy’ in the subject to info@khulisa.co.uk or by post.

Your letter should be addressed to our registered office address:
The Data Protection Officer
Khulisa
32 Cubitt Street
London
WC1X 0LR

Why and when we take photographic images or video footage in the course of our work

Khulisa predominantly relies on donations from individuals or funding from trusts, foundations and other organisations to fund our services. In order to promote our work to these groups, we need to take photographic images and video footage of our services in action, such as during our emotional and social wellbeing programmes or training on the effects of trauma to professionals.

However, we will never feature anyone in our photographic images and video footage unless we have either obtained their consent, or where the subject is under 16 years old and has agreed to us doing so, the consent of the individual with parental responsibility. This applies even when the face of the person featured in the photographic images or video footage is out of view or obscured, as it is likely that the subject would still be recognisable by their family and friends. 

This is why we are asking for your consent to appear, or for the young person in your care to appear, in publicity materials which we will use to raise awareness of our services, fundraising events and campaigns. The photographic images or video footage of you and/or the young person in your care will help us continue providing support to young people and adults with complex needs across the UK, in addition to the professionals working with them. 

Where photographic images and video footage will be published, used or broadcast

We use, publish and broadcast photographic images and video footage in a range of marketing materials, communications and media applications in the public domain, throughout the world and with no time limit, to promote Khulisa as a whole and/or to illustrate particular areas of our work, such as our emotional and social wellbeing programmes or training. We may also use reproductions or adaptations of the photographic images and video footage for any purposes in relation to the work of Khulisa. 

This includes: 

  • printed and Internet publications;
  • advertisements;
  • audiovisual and electronic materials;
  • display materials;
  • media work on broadcast, print and social media; and
  • any other means and media (whether now known or developed in the future) which Khulisa deems appropriate throughout the world.

Photographic images or video footage may be used, published or broadcast alongside your first name or the first name of the young person in your care, unless you specifically disagree for names to be used. Text used alongside the photographic images or video footage may also suggest that you or the young person in your care are subject to a particular issue or live in particular circumstances (if relevant) in order to promote the work of Khulisa.

For example, we may feature photographic images or video footage on leaflets about our services, which we circulate to potential new funders or partners, or in reports about the work we have done to the trusts, foundations and other organisations or individuals funding our services. We may also use photographic images or video footage of you, or the young person in your care to form a post to share on social media

The personal data we collect about you and/or the young person in your care when completing a media consent form

We collect the following personal data about you when you complete a media consent form for yourself, or the young person in your care.

  • your full name;
  • your contact details; and
  • if the media consent form is for the young person in your care, the relationship to the young person in your care.

If the media consent form is for the young person in your care, we will also collect the full name of the young person in your care.

The data is collected by us and stored in our secure and password protected data processing system solely for the purposes of fulfilling and overseeing media consent to feature you or the young person in your care in photographic images and/or video footage. If you opt to keep up to date with Khulisa news, your contact details will also be included in relevant circulation lists for Khulisa’s newsletter, events and volunteering opportunities as you select in the consent form.

Copyright information

Khulisa owns the copyright in any photographic images and video footage or has all rights of ownership or other claims over the photographic images and video footage.

Where and for how long we store photographic images, video footage and personal data needed to fulfil and oversee this media consent?

All electronic copies of photographic images and video footage are stored securely by our Development and Communications Team in our password protected media library. We hold the personal data we collect from you in order to fulfil and oversee this media consent in our secure and password protected data processing system.

Where photographic images and video footage have been made public in an online environment, such as our website, YouTube, social media platforms or other website, or used in printed materials, the images and videos are also stored by the supplier of our website hosting services, social media operators and recipients of any printed materials

We keep all electronic photographic images and video footage for as long as they are deemed appropriate for use, with no time limit, at which point they are moved into our archives. We will hold the personal data we collect from you in order to fulfil and oversee this media consent for as long as the photographic images and video footage are still in use.

Who has access to the photographic images, video footage and personal data needed to fulfil and oversee media consent?

We may share the photographic images, video footage and/or personal data we hold for you and/or the young person in your care to oversee the collection of media consent with third parties providing a service to Khulisa e.g. graphic designers creating marketing material. This includes our suppliers, subcontractors, agents and other associated organisations we use to complete tasks and provide services to you on our behalf.

However, no photographic images, video footage or personal data will be shared with third parties providing a service  to Khulisa unless there is a contract in place that requires the third party to keep the information secure and prevents use for any other purpose than delivering the service. We only disclose the photographic images, video footage and personal data that are necessary to deliver the service.

We will not sell or rent the photographic images, video footage or personal data to third parties, nor will we share this information with third parties for marketing purposes.

Where photographic images and video footage have been made public in an online environment, such as our website, YouTube, social media platforms or other website, these photographic images or video footage have entered the public domain.

When used in printed materials, the photographic images or video footage can be accessed by any recipient of these printed materials.

International transfers

fSome of the photographic images, video footage and/or personal data we hold for you and/or the young person in your care to oversee the collection of media consent may be transferred and stored securely outside of the UK and European Union by the suppliers of our email, document management and storage services. Where that is the case, safeguards are in place to ensure legal protection under the GDPR. This includes supplier certification under the Privacy Shield Scheme if based in the United States of America, or reliance on Model Contract Clauses.

Legal basis of processing

We obtain your explicit consent to feature you or the young person in your care in photographic images or video footage, and only collect the personal data we need in order to fulfil and oversee this media consent.

Your rights

Your consent is for an indefinite period i.e. with no time limit. However, you have the right to withdraw your consent at any time.

You have the right to ask for a copy of the photographic images or video footage featuring you or the young person in your care, and a copy of the personal data we collected in order to fulfill and oversee the collection of media consent regarding these photographic images or video footage. If you wish to view this information, please make a request in writing (via our contact form on our website, by email or by post) to the Data Protection Officer and we will provide a response within 30 days. 

Your rights under the GDPR also include the following:

  1. Right to rectification: This means you may ask us to rectify any of the text alongside photographic images or video footage featuring you or the young person in your care, and any of the personal data we hold about you or the young person in your care to oversee the collection of media consent.
  2. Right to erasure (sometimes known as the right to be forgotten): If you withdraw consent, you have the right to request us to delete photographic images or video footage featuring you or the young person in your care, and the personal data we hold for you and/or the young person in your care to oversee the collection of media consent. However, we are unable to withdraw photographic images or video footage already in circulation, or published in an online environment or printed materials.
  3. Right to restrict processing: You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of the photographic images or video footage featuring you or the young person in your care, and the personal data we hold about you and/or the young person in your care to fulfill and oversee the collection of media consent is restricted.
  4. Right to data portability: You have the right to request a copy of the photographic images and video footage we hold for you or the young person in your care in an accessible electronic format, in addition to the personal data we hold about you and/or the young person in your care to fulfill and oversee the collection of media consent. You may also have the right for us to transmit this to another organisation of your choice in certain circumstances.

Complaints

If you consider that the photographic images, video footage or personal data we hold for you or the young person in your care have been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. 

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts. 

The Information Commissioner can be contacted at:

By email: casework@ico.org.uk

By phone: 0303 123 1113

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow. Cheshire. SK9 5AF