Digital Privacy Notice
At The King’s Trust International our mission is to empower young people like you to learn, earn and thrive. We want to be transparent about what personal details we collect from you when you use our digital programme(s), including Vibe Check, Get Ready and any other WhatsApp based programmes (together and individually referenced as the “Digital Programme”), and why we need them.
If you decide you no longer want to use our Digital Programme, please type OPTOUT in the chat function with the Digital Programme you are using. If you want any information we have collected on you deleted from our systems, please email us using the contact details in section 10 below.
By messaging us on a Digital Programme, you consent to the collection and use of any personal information submitted by you in accordance with the General Data Protection Regulation 2016/679 (“GDPR”) as transposed into UK national law by operation of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019. GDPR along with the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 gives privacy rights to individuals. Together, this legislation forms UK data protection law.
This Digital Privacy Notice covers the following:
- Who we are
- Information you share with us on our Digital Programme
- Our legal basis for processing your personal data
- What we do with your information
- Who we might share your information with
- Your rights and how to access, correct or delete your information
- How we keep your data safe
- How long we store your data for
- Changes to this Digital Privacy Notice
- Contact us
- Further information
You can find our full privacy notice here. This full privacy notice covers our processing of the personal data of our supporters, young people on our programmes and others to manage our relationships with them and to measure the impact of our work. This Digital Privacy Notice just deals with what we do with the personal information you provide when using the Digital Programme.
If you have any questions about this Digital Privacy Notice, please contact our Data Protection Officer according to the contact details provided in section 10 below.
- Who we are
The King’s Trust International is a charity founded by His Majesty King Charles III to tackle the global crisis of youth unemployment and has been supporting young people worldwide since 2015. We work with local partners to develop programmes and interventions to help young people to build their own futures.
We are a company (number 09090276) and charity (number 1159815) registered in England and Wales with our registered office situated at 8 Glade Path, London, SE1 8EG, United Kingdom. We are registered as Data Controllers with the UK’s Information Commissioner’s Office (number ZA071184).
- Information you share with us on our Digital Programme
a) WhatsApp name & Phone number
By using our Digital Programme on WhatsApp, you agree to share any information about you listed on your WhatsApp profile, including the name you have used, and your phone number.
By adding our Digital Programme as a contact, you cannot prevent us from seeing your phone number (just like with a friend). As this Digital Programme uses WhatsApp and needs access to your phone number, it is not possible to participate on this programme without us processing your phone number. Our partner organisation delivering the programme will also need some information about you including your name and date of birth and they will advise you separately on this. You will see below what we may do with your personal information provided using WhatsApp on this Digital Programme.
b) Usage information
When you interact with our Digital Programme by sending us messages, those messages get stored on a secure platform. This is stored by –
Turn.io is the platform which allows us to send the messages to WhatsApp which is hosted in Belgium.
RapidPro is the application which holds all our programme content and interactive messaging. RapidPro is hosted in London.
We keep a record of the messages sent to help us understand how people are interacting with our Digital Programme. We also share this information with trusted contractors as detailed in section 5 below. This helps us to make improvements and effectively manage and support the programme.
Rest assured that the combination of your usage information, your name and your telephone number will never be shared outside of the platform and those involved in the Digital Programme (i.e. our partner delivering the programme, ourselves and our trusted contractors).
c) Other information you give us
During the Digital Programme we may ask some additional questions such as your age, gender, about your personal experiences or your feedback on the programme, which we use to help understand our audience better and ensure programme suitability. You are under no obligation to provide us with this information, but if you choose to, be aware that this will be part of the information we store about you.
We may use information such as age, gender, or your responses to quizzes, in an aggregated way, for example, in order to determine what percentage of our users are female or male.
We will never ask you for any sensitive data or special category data via the Digital Programme. This is information regarding racial or ethnic origins, political opinions, religious beliefs, health, and information concerning criminal offences. We would also encourage you not to share any information via the Digital Programme that is sensitive or confidential. This includes personal information such as your home address.
The Digital Programme is only available to those who are 13 years or over. Please also note that if parental / guardian consent is needed in your country, you will need it before joining the Digital Programme. Our partner organisation providing details of the Digital Programme will advise you further on this.
- Our legal basis for processing your personal data
We rely on the following legal basis for processing your data on the Digital Programme:
- Consent – We ask you to confirm that you are happy for us to process your data for the purposes explained in this Digital Privacy Notice when you apply for your account and opt in to use the Digital Programme. As advised above, where parental / guardian consent is needed, we will require this from a parent/guardian on your behalf. Please note that you have the right to withdraw your consent at any time.
- Performance of a contract – without your WhatsApp name and telephone number we are unable to provide the WhatsApp based content with you to enable you to participate in our Digital Programme
It is possible that in relation to your wider involvement in one or more of our programmes that we may rely on another legal basis such as:
- Legitimate Interests – In carrying out our wider activities, we may collect and process personal data for our legitimate interests (i.e. we use the information to evaluate the services we provide, to develop or tailor new programmes or tailor existing ones). If we process any of your personal information for our legitimate interests, we will make sure to consider and balance any potential impact on you and your rights under data protection laws. We will always ensure that your personal data will not be used where our interests are overridden by the impact on you.
Such other interactions and our processing of your personal information in relation to these is discussed in our full privacy notice here.
- What we do with your information
As advised above, your mobile number is needed for you to use WhatsApp for the Digital Programme. Our partner organisation delivering the programme will also need to monitor your use to ensure that you and others participating in the Digital Programme do not violate the terms of use, e.g. by sending abusive or otherwise inappropriate messages. We and our partners therefore need to reserve the right to contact anyone breaching the terms of use to warn them of inappropriate behaviour and/or to remove them from the Digital Programme where considered appropriate.
We will also use some personal information provided to monitor and evaluate the Digital Programme and its impact on you and other young people on this programme. For this, we will monitor overall engagement and progress of participants with the Digital Programme.
We may ask you to provide some information such as your gender, personal experiences or feedback on the service to help us understand:
- the gender of our users so we can ensure we are reaching as many females as males.
- feedback including how we can improve the Digital Programme.
This information may be included in internal or external reports or presentations but will never be associated with your personally identifiable information (name and phone number).
We will also use your name and date of birth to enable you to participate in the Get Hired face to face job fair
- Who might we share your information with?
We are committed to protecting your data and therefore it will only ever be disclosed to external trusted organisations such as partner organisations delivering the Digital Programme and data processors who are carrying out work on our behalf. Where we enter into a relationship with an external party, this will be following due diligence; and any such arrangements will be subject to a formal agreement between The King’s Trust International and that organisation to protect the security of your data. See under section 7 below for more details. We do not sell data.
External parties may include:
1) ColoredCow Consulting Pvt. Ltd., a technology developer who support the development of the Digital Programme. They are based in India (from where they can access the platform). There is not an adequacy decision made by the EU (or UK) which recognises that India provides an equivalent level of protection for personal data as the EU (or UK). We have therefore carried out a transfer risk assessment and ensured appropriate safeguards are in place including an international data transfer agreement with ColoredCow.
2) Delivery Partners, based in your own country, who may access your personal data to conduct monitoring and evaluation of the programme and/or to invite you to subsequent events – for example a Jobs Fair.
For more information on how we comply with UK data protection law, and the appropriate safeguards we put in place to keep your personal data safe (including when this is sent to other countries), please see section 7 below.
- Your rights and how to access, correct or delete your information
Under UK data protection law, you have the following rights in relation to your personal data:
- right to be informed (about what data we process, how we process it, why we process it and other key information);
- right to access your personal information (request a copy of your information);
- right to ask us to rectify personal information you think is inaccurate, including where this needs to be updated;
- right to request to have your personal information deleted;
- right to ask us to restrict the processing of your personal information;
- right to object to the processing of your personal information;
- right to ask us to transfer the personal information you have given us to another organisation, or to you; and
- right to withdraw your consent.
You can read more about your rights at: For the public | ICO. If you make a request, we must respond to you without undue delay and in any event within one month.
If you wish to exercise your rights, please address your request, by email or mail, to King’s Trust International. Please see under section 10 below for the appropriate address details. To help us locate information about you (or in case we need to get in touch with you to verify your identity or obtain further information to help us locate your records) please include your full name, address and telephone number with your request.
If you decide you no longer want to use our Digital Programme, please type OPTOUT in the chat function with the Digital Programme you are using.
- How we keep your data safe
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 platform is protected and monitored. Within our offices all of our staff receive training on handling data securely. We also ensure the same is the case with our contractors and our delivery partners who are delivering the Digital Programme.
We ensure that our contractors and delivery partners are clear on how they are to handle all personal data with specific instructions in place to protect personal data at all times, ensuring no local copies are created beyond the need to complete immediate tasks, and are never shared beyond those working on the project and are deleted on completion. We periodically check to ensure that they adhere to the outlined processes. Access to our systems is to named individuals only, and access is removed on completion.
Any data reports containing personal data have restricted access, ensuring that only authorised personnel can view them. Personal data will not be accessible for general download, and appropriate technical and organisational measures are in place to safeguard its confidentiality, integrity, and availability.
As stated above, we carry out comprehensive checks on such other parties before we work with them and ensure that contracts are in place that set out our expectations and requirements.
As advised under section 5 above, we may need to share your personal data outside of your country, the UK and the European Economic Area (EEA) to allow such parties to perform services on our behalf. In doing so, your data will be transferred, stored or processed outside of these countries / areas. Where this happens, we endeavour to ensure that your data is processed in accordance with the appropriate security requirements in line with our legal responsibilities, and by submitting your details in such circumstances you agree to this sharing of your data. For further information or to obtain a copy of the appropriate safeguards put in place for any such transfers please contact us using the contact information provided at section 10 below.
Despite all our precautions no data transmission over WhatsApp or the internet can be guaranteed to be 100% secure. So, whilst we will always strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us and so wish to draw to your attention that you do so at your own risk.
- How long we store your data for
We will hold on to your personal information on our systems for 2 years after the end of the Digital Programme you are participating in.
- Changes to this Digital Privacy Notice
This Digital Privacy Notice has most recently been updated in February 2025 ahead of the start of the next Digital Programme in Nigeria.
- Contact us
If you have any queries about this Digital Privacy Notice, any complaints with regard to the administration of this or to exercise any of your rights in respect of your personal data please contact us as follows:
By email at: ktidataprotection@kingstrustinternational.org; or
By sending a letter to the Data Protection Officer, The King’s Trust International, 8 Glade Path, London, SE1 8EG, United Kingdom.
- Further information
The UK data protection law governing how your personal data can be used is set out in:
- EU/UK General Data Protection Regulation 2016/679
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations 2003
If you believe that The King’s Trust International has not complied with your data protection rights, or remain unhappy with our response on how we have used your data after raising a complaint with us, you can complain to the Information Commissioner’s Office (ICO) or your supervisory authority.
The ICO is the UK’s supervisory authority and is responsible for monitoring the application of the UK data protection laws in order to protect the fundamental rights and freedoms of natural persons whose data is subject to processing.
The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
United Kingdom
Helpline number: +44 (0)303 123 1113