DATA PROTECTION & SAFEGUARDING POLICY

Equalise Ltd
45 Fitzroy St, London, W1T 6EB
Email: lh@equalise.life
Last updated: 10/12/2025

1. Introduction

Equalise Ltd (“Equalise”, “we”, “us”, “our”) is committed to protecting the privacy, safety and rights of all individuals who engage with our programmes, including employees, school pupils, teachers, parents, and corporate participants.

We uphold the highest standards of data protection and safeguarding in accordance with:

• UK General Data Protection Regulation (UK GDPR)

• Data Protection Act 2018

• Keeping Children Safe in Education (KCSIE) guidance

• Relevant safeguarding frameworks for youth and educational settings

This Policy explains how we protect personal data, how we manage safeguarding responsibilities, and the measures we take to ensure safety and confidentiality.

⭐ 2. Data Controller Information

Equalise Ltd is the Data Controller for all personal data processed as part of our programmes.

Data Controller: Equalise Ltd
Address: 45 Fitzroy St, London, W1T 6EB
Email: lh@equalise.life

Any data protection or safeguarding queries can be directed to this address.

⭐ 3. Our Commitment to Data Protection

We ensure that all personal data is:

• Collected lawfully, fairly and transparently

• Used only for clear, specific purposes

• Limited to what is necessary

• Accurate and kept up to date

• Stored securely with strict access controls

• Deleted when no longer required

We never sell personal data.
We never use children’s data for marketing or commercial profiling.

⭐ 4. Types of Data We Process

Depending on the programme, Equalise may process:

4.1 Participant Data (Adults in workplaces)

• Name, email and team or department

• Self-reported wellbeing assessments

• Engagement data related to the programme

4.2 Pupil Data (Healthy Schools programmes)

• Name or anonymised ID

• Age or year group

• Self-reported wellbeing questionnaire data

• Non-medical observations from assessment sessions

• Pastoral notes shared by schools

4.3 School and Corporate Contact Data

• Staff names, roles and emails

• Communication logs

• Programme administration details

4.4 Technical Data

• Device and browser information

• IP address

• Cookie and analytics data

Equalise does not collect medical diagnoses or clinical health records.

⭐ 5. Legal Basis for Processing

We rely on the following lawful bases under UK GDPR:

• Consent: for pupil wellbeing assessments or where sensitive data is involved

• Legitimate Interests: for running workplace wellbeing programmes

• Contractual Necessity: when delivering services to clients

• Legal Obligation: safeguarding, regulatory requirements

• Public Interest: safeguarding duties in educational environments

Consent can be withdrawn at any time.

⭐ 6. Data Security Measures

We use a combination of technical and organisational measures to protect data, including:

• Encryption of data in transit and at rest

• Secure UK or UK-approved cloud storage

• Role-based access control (only authorised staff see data)

• Password and MFA protections

• Regular data security reviews

• Staff training on safeguarding and data protection

• Confidentiality agreements for all practitioners

We regularly review and update our security protocols.

⭐ 7. Safeguarding Commitments (Children & Young People)

Equalise works closely with schools to ensure safety at all times.

We commit to:

• Ensuring all practitioners are DBS-checked

• Sharing relevant wellbeing concerns only with authorised school safeguarding leads

• Following KCSIE guidance and school safeguarding policies

• Reporting safeguarding concerns immediately and appropriately

• Never collecting unnecessary information about a child

• Never contacting children directly outside of school-authorised sessions

• Ensuring children cannot be personally identified in externally shared outputs

Safeguarding always takes priority over confidentiality.

⭐ 8. Data Sharing

Equalise shares data only when necessary, and always securely.

We may share:

8.1 With Schools

• Pupil wellbeing insights

• Reports for pastoral or educational support

• Flags for safeguarding risk (where appropriate)

8.2 With Corporate Clients

• Aggregated workforce wellbeing insights

• No individual employee reports are shared unless explicitly agreed

8.3 With Service Providers

(e.g., analytics, hosting, security providers)
All providers operate under Data Processing Agreements.

8.4 With Authorities

Only when legally required or necessary for safeguarding.

We never share personal data with third parties for marketing.

⭐ 9. Data Retention

We retain data only for as long as necessary:

• Pupil wellbeing assessment data — up to 24 months

• Workforce wellbeing data — up to 24 months

• Corporate insight and reporting data — up to 36 months

• Safeguarding or legal records — retained according to statutory requirements

Data is securely deleted once retention periods expire.

⭐ 10. International Data Transfers

Where data is stored or processed outside the UK, Equalise ensures appropriate safeguards such as:

• Adequacy regulations

• Standard Contractual Clauses

• UK International Data Transfer Agreements (IDTAs)

⭐ 11. Your Rights Under UK GDPR

Individuals have the right to:

• Access personal data we hold

• Request corrections

• Request deletion (where appropriate)

• Restrict or object to processing

• Request data portability

• Withdraw consent

• Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise these rights, contact:
lh@equalise.life

⭐ 12. Cookies and Website Tracking

Our website uses cookies to improve user experience and analyse usage.
Users can control cookie settings through their browser.

A full Cookie Policy can be provided separately.

⭐ 13. Changes to This Policy

Equalise may update this Policy periodically.
The most recent version will always be available on our website.

⭐ 14. Contact Information

For any data protection or safeguarding queries, please contact:

Equalise Ltd
45 Fitzroy St
London
W1T 6EB

Email: lh@equalise.life