Privacy Policy
Privacy Policy Bright Spark Collective
Last updated: June 2026
Bright Spark Collective ("Bright Spark", "we", "us" or "our") is committed to protecting the privacy of everyone who uses our website and our services, including the children and young people who take part in our programmes and the parents or guardians who book on their behalf.
This policy explains what personal information we collect, why we collect it, how we use it, and the rights you have over your information. It applies to our website and to the information we collect when you book a place, get in touch with us, or take part in a Bright Spark programme.
This policy is written in line with UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
-
Who we are
Bright Spark Collective is the data controller responsible for the personal information described in this policy. If you have any questions about this policy or how we handle your information, you can contact us using the details in section 11.
-
Information we collect
We collect different types of information depending on how you interact with us.
2.1 Information you give us directly
Your name and your child's name
Your child's age
Your contact details, including phone number and email address
Preferred location and programme choice
Medical information or allergies relevant to your child's participation
Details of any additional needs or support required
Emergency contact details
Photo and video consent preferences
Any messages or information you send us through our contact or booking forms
2.2 Information collected automatically
When you visit our website, we use cookies and similar technologies to collect some information automatically, including:
Analytics information, such as which pages you visit, how long you spend on the site, and how you arrived at our website (for example, through Google Analytics)
Marketing information, used to understand the effectiveness of our social media and advertising (for example, through the Meta/Facebook Pixel)
You can manage your cookie preferences at any time through the cookie banner on our website.
-
How we use your information
We use the information we collect for the following purposes:
To process bookings and manage places on our programmes
To communicate with you about sessions, schedules, or any changes
To ensure your child's safety and wellbeing during sessions, including taking account of any medical information or additional needs you have shared with us
To contact emergency contacts if necessary during a session
To respond to enquiries made through our contact form
To send you updates about Bright Spark programmes, where you have agreed to receive these
To understand how our website is used and to improve it, using analytics
To meet our legal, insurance and safeguarding obligations
-
Our legal basis for using your information
Under UK GDPR, we rely on the following legal bases to process personal information:
Consent — for example, when you agree to photo or video consent, or opt in to marketing communications
Contract — to process a booking and deliver the programme you have signed up for
Legitimate interests — for example, to improve our website and services through analytics
Legal obligation — where we are required to keep certain records for insurance, safeguarding or regulatory purposes
Where we rely on consent, you can withdraw it at any time. Withdrawing consent will not affect the lawfulness of anything we did with your information before you withdrew it.
-
Children's information
Because Bright Spark works directly with children and young people, some of the personal information we collect relates to children. We take extra care with this information, and the following principles apply:
Information about a child is provided to us by a parent or guardian at the point of booking, not directly by the child
We only collect the information we need to run our sessions safely, including medical information, allergies and additional needs where relevant
Photo and video consent is always optional, and is collected separately and clearly during the booking process
We do not use children's information for marketing purposes without explicit parental consent
Access to children's information is limited to staff who need it to deliver sessions safely
-
Sharing your information
We do not sell personal information to third parties. We may share information in the following limited circumstances:
With staff and session leaders who need the information to deliver and supervise programmes safely
With our payment provider, to process any payments for bookings. We do not store your card or full payment details ourselves; this is handled directly and securely by our payment provider
With analytics and advertising providers, such as Google Analytics and Meta, to help us understand website usage and the effectiveness of our marketing. These providers process information in line with their own privacy policies
With relevant authorities, where we are required to do so by law, or where necessary to protect the safety of a child
We require any third party we work with to handle personal information securely and in line with data protection law.
-
Cookies
We use cookies for the following purposes:
Essential cookies, which are necessary for the website to function correctly
Analytics cookies, which help us understand how visitors use our website (for example, Google Analytics)
Marketing cookies, which are used to measure the effectiveness of our advertising and social media activity (for example, the Meta/Facebook Pixel)
You can manage or withdraw your cookie preferences at any time through the cookie settings banner on our website, or through your browser settings. Please note that disabling certain cookies may affect how parts of our website work.
-
How long we keep your information
We keep personal information for as long as necessary to fulfil the purposes set out in this policy, including any legal, accounting or reporting requirements. As a general guide:
Booking and programme records are kept for the duration of your child's participation and for a reasonable period afterwards, in line with insurance and safeguarding requirements
Medical and additional needs information is securely deleted once it is no longer needed for the purpose it was collected for
Marketing data is kept until you withdraw consent or unsubscribe
If you would like more detail on how long we retain a specific type of information, please contact us.
-
Keeping your information secure
We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse or disclosure. This includes restricting access to personal information to those who need it, and using secure, reputable platforms and providers to store and process data.
-
Your rights
Under UK GDPR, you have the following rights in relation to your personal information:
The right to be informed about how we use your information
The right to access the personal information we hold about you or your child
The right to have inaccurate information corrected
The right to ask us to delete your information, in certain circumstances
The right to restrict how we use your information, in certain circumstances
The right to object to certain types of processing, including direct marketing
The right to data portability, where applicable
The right to withdraw consent at any time, where we rely on consent to process your information
To exercise any of these rights, please contact us using the details below. We will respond within one month, as required by law.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator, if you believe we have not handled your information correctly. The ICO can be contacted at ico.org.uk.
-
Contact us
If you have any questions about this Privacy Policy, or would like to exercise any of your rights, please contact uS.
-
Changes to this policy
We may update this Privacy Policy from time to time, for example to reflect changes in the law or in how we use personal information. Any changes will be posted on this page, along with an updated revision date at the top of this policy. We encourage you to review this page periodically.
This document is a starting template and should be reviewed to ensure it accurately reflects your specific data practices before publishing it live. It does not constitute legal advice.
Safeguarding
Bright Spark Safeguarding and Child Protection Policy
Organisation: Bright Spark
Activity: Drama, performing arts, confidence-building, tutoring and creative programmes for children and young people
---
1. Policy Statement
Bright Spark is committed to safeguarding and promoting the welfare, safety and wellbeing of all children and young people who attend our activities.
We believe that every child has the right to feel safe, respected, listened to and valued. We are committed to creating a positive, inclusive and supportive environment where children can develop confidence, creativity, communication skills and self-expression.
Safeguarding is everyone’s responsibility. All adults working with or on behalf of Bright Spark, including staff, volunteers, assistants, freelancers and visiting facilitators, are expected to follow this policy and act in the best interests of children and young people at all times.
---
2. Purpose of This Policy
The purpose of this policy is to:
- Protect children and young people who attend Bright Spark activities.
- Provide staff, volunteers and assistants with clear guidance on safeguarding and child protection.
- Ensure concerns are recognised, recorded and reported appropriately.
- Support safe recruitment, supervision and professional conduct.
- Reassure parents and carers that Bright Spark takes safeguarding seriously.
- Ensure Bright Spark follows safeguarding expectations in Northern Ireland.
---
3. Scope of This Policy
This policy applies to:
- All Bright Spark staff.
- Volunteers and assistants.
- Freelance tutors, drama practitioners or visiting facilitators.
- Anyone working on behalf of Bright Spark.
- Children and young people attending Bright Spark sessions, summer schemes, workshops, tutoring, parties or events.
This policy applies during all Bright Spark activities, including sessions held in hired venues, schools, community spaces, private venues, online spaces, events and performances.
---
4. Legal and Guidance Framework
Bright Spark will work in line with relevant safeguarding legislation and guidance in Northern Ireland, including:
- The Children Order 1995.
- Safeguarding Board Act Northern Ireland 2011.
- Co-operating to Safeguard Children and Young People in Northern Ireland.
- Safeguarding Board for Northern Ireland regional policies and procedures.
- AccessNI guidance relating to regulated activity and enhanced checks.
- Relevant health and safety, equality and data protection requirements.
This policy will be reviewed regularly to ensure it remains current and appropriate.
---
5. Our Safeguarding Principles
Bright Spark will:
- Put the welfare of children and young people first.
- Treat all children with dignity, respect and kindness.
- Listen to children and take their concerns seriously.
- Promote a safe, inclusive and welcoming environment.
- Recognise that some children may be more vulnerable than others.
- Respond promptly and appropriately to concerns.
- Work in partnership with parents, carers and relevant agencies where appropriate.
- Maintain appropriate professional boundaries at all times.
---
6. Definitions of Abuse and Harm
Bright Spark recognises that children may be harmed in different ways. Abuse may be carried out by adults or by other children and young people. Abuse can happen in person or online.
Types of harm may include:
Physical abuse
This may involve hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating or otherwise causing physical harm to a child.
Emotional abuse
This may involve persistent emotional ill-treatment, such as making a child feel worthless, unloved, frightened, bullied, humiliated or constantly criticised.
Sexual abuse
This involves forcing or enticing a child or young person to take part in sexual activities. It may include physical contact, non-contact activities, exposure to sexual content or online exploitation.
Neglect
This is the persistent failure to meet a child’s basic physical or emotional needs, such as food, clothing, shelter, supervision, medical care, emotional warmth or protection from harm.
Exploitation
This may include sexual exploitation, criminal exploitation, trafficking, coercive control, grooming or using a child for another person’s gain.
Online harm
This may include grooming, cyberbullying, exposure to inappropriate content, pressure to share images, online harassment or unsafe contact through digital platforms.
Bullying
This may include physical, verbal, emotional, social or online bullying. Bright Spark will not tolerate bullying in any form.
---
7. Designated Safeguarding Lead
The Designated Safeguarding Lead for Bright Spark is:
Name: [Name]
Phone: [Phone number]
Email: [Email address]
The role of the Designated Safeguarding Lead is to:
- Act as the first point of contact for safeguarding concerns.
- Ensure concerns are recorded accurately and securely.
- Make decisions about referral to relevant agencies.
- Support staff, volunteers and assistants with safeguarding matters.
- Ensure safeguarding procedures are followed.
- Keep safeguarding records confidential and secure.
- Ensure staff and volunteers receive appropriate safeguarding information or training.
- Review and update this policy.
Where the Designated Safeguarding Lead is unavailable, concerns should be reported to:
Deputy / Alternative Contact: [Name and contact details]
If a child is in immediate danger, staff should contact emergency services by calling 999.
---
8. Recognising Safeguarding Concerns
Adults working with Bright Spark should be alert to signs that a child may be experiencing harm. These may include, but are not limited to:
- Unexplained injuries or frequent accidents.
- Sudden changes in behaviour, mood or confidence.
- Fearfulness, anxiety, withdrawal or distress.
- Inappropriate sexualised behaviour or language.
- Poor hygiene, hunger, tiredness or unsuitable clothing.
- A child appearing afraid of a particular person or situation.
- Disclosure of harm, abuse, bullying or neglect.
- Concerning behaviour from another adult or child.
- Online safety concerns.
Staff should not investigate concerns themselves. Their role is to notice, listen, record and report.
---
9. Responding to a Disclosure
If a child tells an adult that they are being harmed or are worried about something, the adult should:
- Listen carefully and calmly.
- Take the child seriously.
- Reassure the child that they have done the right thing by speaking up.
- Avoid showing shock, panic or disbelief.
- Do not promise confidentiality.
- Explain that the information may need to be shared with people who can help keep them safe.
- Do not ask leading questions.
- Do not investigate or confront anyone involved.
- Write down what was said as soon as possible, using the child’s own words where possible.
- Report the concern to the Designated Safeguarding Lead immediately.
Suggested wording:
“I’m really glad you told me. You have done the right thing. I can’t promise to keep this secret because I may need to tell someone who can help keep you safe.”
---
10. Recording Concerns
Any safeguarding concern must be recorded as soon as possible. Records should be factual, accurate and dated.
A safeguarding record should include:
- Child’s name.
- Date of birth, if known.
- Date, time and location of the concern or disclosure.
- Name of the person recording the concern.
- What was seen, heard or reported.
- The child’s own words, where possible.
- Any visible injuries or signs of distress.
- Action taken.
- Who the concern was reported to.
- Any follow-up action.
Records must be kept securely and confidentially. They should only be shared with people who need to know in order to protect the child.
---
11. Reporting Safeguarding Concerns
All concerns must be reported to the Designated Safeguarding Lead as soon as possible.
The Designated Safeguarding Lead will decide what action is needed. This may include:
- Monitoring and recording the concern.
- Speaking with parents or carers, if appropriate and safe to do so.
- Seeking advice from relevant safeguarding services.
- Making a referral to the local Health and Social Care Trust Gateway Team.
- Contacting the PSNI if a child is at immediate risk of harm or a crime may have been committed.
- Contacting emergency services if immediate protection or medical help is needed.
If there is immediate danger, staff should call 999.
If the concern involves the Designated Safeguarding Lead, the concern should be reported to the deputy safeguarding contact or directly to the relevant statutory service.
---
12. Allegations Against Staff, Volunteers or Adults
Any allegation or concern about the behaviour of an adult working with or on behalf of Bright Spark will be taken seriously.
This may include concerns that an adult has:
- Behaved in a way that has harmed or may have harmed a child.
- Possibly committed a criminal offence against or related to a child.
- Behaved towards a child in a way that indicates they may pose a risk.
- Breached professional boundaries.
- Used inappropriate language, physical contact or communication.
- Contacted a child inappropriately online or outside Bright Spark activities.
The Designated Safeguarding Lead will:
- Ensure the child is safe.
- Record the concern.
- Remove the adult from unsupervised contact with children while advice is sought, if appropriate.
- Seek advice from the relevant statutory agency.
- Contact PSNI or social services where required.
- Maintain confidentiality and fairness while prioritising child safety.
Bright Spark will not ignore or minimise concerns about adults.
---
13. Safer Recruitment
Bright Spark is committed to safer recruitment.
Before adults work with children through Bright Spark, we will consider the appropriate checks and safeguards for the role. This may include:
- Clear role description.
- Application or expression of interest.
- Identity check.
- References.
- Interview or suitability discussion.
- AccessNI check where the role is eligible or required.
- Confirmation of qualifications, where relevant.
- Safeguarding induction.
- Agreement to follow Bright Spark policies and code of conduct.
No adult should begin working unsupervised with children until appropriate checks and safeguards have been completed.
---
14. AccessNI Checks
Bright Spark will assess each role to decide whether an AccessNI check is appropriate or required.
Where a role involves regulated activity with children, an enhanced AccessNI check with barred list information may be required. Bright Spark will ensure that checks are processed appropriately through an AccessNI registered body where needed.
AccessNI checks are one part of safer recruitment and do not replace references, supervision, training or professional judgement.
---
15. Staff and Volunteer Code of Conduct
Adults working with Bright Spark must:
- Treat children with respect, kindness and fairness.
- Use positive and appropriate language.
- Maintain professional boundaries.
- Avoid favouritism.
- Avoid being alone with a child where this can reasonably be avoided.
- Use open and observable spaces for activities.
- Report concerns immediately.
- Follow Bright Spark policies and procedures.
- Challenge inappropriate behaviour safely.
- Respect confidentiality.
- Model appropriate behaviour.
Adults must not:
- Hit, threaten, humiliate or frighten a child.
- Use sexual, discriminatory or degrading language.
- Develop inappropriate personal relationships with children.
- Contact children privately through personal social media accounts.
- Share personal phone numbers with children unless part of an agreed, parent-approved arrangement.
- Take photographs or videos without permission.
- Give lifts to children alone unless there is an emergency or prior written parent/carer consent.
- Allow bullying, harassment or abusive behaviour to go unchallenged.
- Consume alcohol or be under the influence of drugs during activities.
- Smoke or vape in front of children during Bright Spark sessions.
- Share confidential information unnecessarily.
---
16. Physical Contact
Some Bright Spark activities, particularly drama and performance work, may involve movement, positioning, games or performance direction. Any physical contact must be:
- Necessary and appropriate to the activity.
- Explained clearly.
- Consented to by the child.
- Respectful of personal boundaries.
- In public view where possible.
- Never secretive, rough, punitive or sexualised.
Children have the right to say no to physical contact. Alternative instructions should be offered where possible.
Physical contact may be necessary in an emergency, for example to prevent injury or provide first aid.
---
17. Toileting, Changing and Personal Care
Bright Spark will consider toilet and changing arrangements as part of venue risk assessment.
Staff and volunteers should:
- Avoid being alone with a child in a toilet or changing area.
- Use agreed procedures for younger children who may need assistance.
- Respect privacy and dignity.
- Encourage children to manage personal care independently where appropriate.
- Report any concerns immediately.
Parents and carers should inform Bright Spark in advance if a child needs additional personal care support.
---
18. Supervision and Ratios
Bright Spark will ensure appropriate supervision for the age, needs and number of children attending.
When planning ratios, Bright Spark will consider:
- Age of children.
- Additional needs.
- Venue layout.
- Type of activity.
- Behavioural needs.
- Fire evacuation arrangements.
- Toileting arrangements.
- Whether the activity is indoors, outdoors or off-site.
Children will not be left unsupervised during Bright Spark activities.
---
19. Arrival and Collection
Parents and carers must provide accurate emergency contact details and collection information.
Bright Spark will:
- Keep a register of attendance.
- Record arrival and collection.
- Only release children to authorised adults.
- Ask parents/carers to inform Bright Spark if someone different will collect their child.
- Follow a late collection procedure if a child is not collected on time.
- Keep children supervised until collected.
If a child is not collected and Bright Spark cannot contact parents, carers or emergency contacts, the Designated Safeguarding Lead may seek advice from social services or PSNI.
---
20. Photography, Video and Social Media
Bright Spark may wish to use photographs or videos for celebration, promotion or parent communication. This will only happen where appropriate consent has been obtained.
Bright Spark will:
- Ask parents/carers for written photo and video consent.
- Respect any refusal of consent.
- Avoid using full names alongside images.
- Avoid sharing images that may embarrass, exploit or endanger a child.
- Store images securely.
- Ensure staff do not use personal devices for images unless agreed by the Designated Safeguarding Lead and images are transferred/deleted appropriately.
- Never allow children to be photographed or filmed in toilets or changing areas.
Parents and carers may be asked not to share images of other children publicly without permission.
---
21. Online Safety
If Bright Spark delivers any online sessions or uses digital communication, we will take steps to keep children safe.
This may include:
- Using appropriate platforms.
- Sending links to parents/carers rather than directly to children where possible.
- Ensuring online sessions are supervised.
- Avoiding private one-to-one messaging with children.
- Keeping communication professional.
- Recording online sessions only with consent.
- Encouraging children to report anything that makes them uncomfortable.
Staff must not contact children through personal social media accounts.
---
22. Behaviour, Bullying and Peer-on-Peer Harm
Bright Spark expects all children and young people to treat each other with kindness and respect.
We will not tolerate:
- Bullying.
- Harassment.
- Racist, sexist, homophobic, transphobic or discriminatory language.
- Physical aggression.
- Sexualised comments or behaviour.
- Online bullying.
- Exclusion or intimidation.
Concerns about bullying or peer-on-peer harm will be recorded, taken seriously and addressed promptly. Parents/carers may be contacted where appropriate.
---
23. Inclusion and Additional Needs
Bright Spark aims to be inclusive and supportive of children with different needs, backgrounds and abilities.
Parents/carers are asked to share relevant information about:
- Medical needs.
- Allergies.
- Additional educational needs.
- Communication needs.
- Anxiety or emotional needs.
- Sensory needs.
- Behaviour support strategies.
- Access requirements.
This helps Bright Spark plan safe and positive participation. Information will be treated sensitively and shared only with adults who need to know.
---
24. First Aid, Accidents and Medical Needs
Bright Spark will ensure appropriate first aid arrangements are in place for activities.
Parents/carers must provide:
- Emergency contact details.
- Medical information.
- Allergy information.
- Medication details.
- Permission for emergency medical treatment.
Accidents and injuries will be recorded. Parents/carers will be informed of accidents or incidents involving their child.
Medication will only be administered where this has been agreed with parents/carers and recorded appropriately.
---
25. Risk Assessment
Bright Spark will complete risk assessments for activities and venues.
Risk assessments may include:
- Venue safety.
- Fire procedures.
- First aid.
- Toilets and changing areas.
- Arrival and collection.
- Activity risks.
- Props, costumes and equipment.
- Movement or performance activities.
- Allergies and medical needs.
- Photography and filming.
- Online safety.
- Emergency evacuation.
- Staffing and supervision.
Risk assessments will be reviewed when venues, activities or circumstances change.
---
26. Confidentiality and Information Sharing
Bright Spark respects confidentiality but safeguarding concerns may need to be shared to protect a child.
Information will be shared:
- On a need-to-know basis.
- With the Designated Safeguarding Lead.
- With parents/carers where appropriate and safe.
- With statutory agencies where there is a safeguarding concern.
- In line with data protection requirements.
Bright Spark will not promise absolute confidentiality where a child may be at risk of harm.
---
27. Record Keeping and Data Protection
Bright Spark will keep safeguarding records securely and separately from general records where possible.
Records will be:
- Factual.
- Dated and signed.
- Stored securely.
- Shared only when necessary.
- Retained in line with appropriate safeguarding and data protection requirements.
Parents/carers should be aware that safeguarding records may be shared with relevant authorities if necessary to protect a child.
---
28. Training and Induction
All adults working with Bright Spark will receive safeguarding information appropriate to their role.
This may include:
- Reading this policy.
- Knowing who the Designated Safeguarding Lead is.
- Understanding how to report a concern.
- Understanding the code of conduct.
- Completing safeguarding training where appropriate.
- Understanding emergency procedures.
The Designated Safeguarding Lead should complete appropriate safeguarding training and keep knowledge up to date.
---
29. Whistleblowing
Staff, volunteers and assistants have a responsibility to raise concerns about unsafe practice.
Concerns may include:
- Poor safeguarding practice.
- Breaches of professional boundaries.
- Unsafe supervision.
- Inappropriate behaviour by adults.
- Failure to respond to concerns.