Privacy notice - Dolly Parton Imagination Library

Dolly Parton Imagination Library – Privacy Notice

The Wheatley Foundation is the charitable trust set up by the Wheatley Group. It is funded by the Group and its subsidiaries to benefit our customers.

Maximising social inclusion, jobs, and training and education outcomes for our customers is a key Wheatley Group priority.

To support this, The Wheatley Foundation is in partnership with the Dolly Parton Imagination Library (DPIL) to provide children who live in our homes and are aged 0-5, a free book every month. Each month a new, carefully selected book will arrive by mail in your child’s name and be delivered directly to your home. There is no cost or obligation to your family.

When you apply for your children to receive books through the Imagination Library, staff at the Wheatley Group will input the information you have provided into the DPIL book ordering system. After 6 weeks, your child will start to receive free monthly books.

Wheatley Foundation and Dolly Parton Imagination Library will be the "data controllers" of the personal information that you provide to us. This information is required to process and manage your child’s registration with the Imagination Library.

Our Data Protection Officer is Ranald Brown who can be contacted on

What we need

When you register to receive books from the Imagination Library, we will ask you for the following personal information:

  • Parent or Guardians name
  • Parent or Guardians email address
  • Name of child
  • Date of birth of child
  • Sex of child
  • Childs home mailing address and postcode
  • Confirmation that parent or guardian is customer of the Wheatley Group

We will ask you for this information in order to process and fulfil free book deliveries to your child. We will also use this information to monitor the project and evaluate the impact it has.

Why we need your personal information

We will process your personal information with your consent so that we can register you with the Imagination Library and begin to receive free monthly books for your child/children.  We will use your personal information to:

  • Ensure your child/children receive free books to the correct address

We will collect your personal information via the application form. This will be passed to a member of Wheatley Group staff within your local housing office who will input this information into the DPIL Book Ordering System to being the delivery process. We will collect no other information.

Our landline phone calls to our Customer First Centre are recorded for training and monitoring purposes and our recordings are usually held for a period of six months.

Other uses of your personal information

We may ask you if we can process your personal information for additional purposes.  For example, to promote the Imagination Library or to report on the successes of the programme.  Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

Furthermore, in order to carry out research and evaluation around the performance of the programme we may ask you to complete questionnaires issued by or on behalf of Wheatley Group, and to participate in evaluations that Wheatley Group or it’s representatives may conduct.

We may take photographs and video footage at events we organise or take part in, at our offices and in our communities to use for general marketing and publicity. We may also ask you to take part in case studies to demonstrate the impact of the project.

Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

Who we share your personal information with

We will share your information with the Dolly Parton Imagination Library. This will be for the purposes of delivering monthly books to your child only. This information will be held on Dolly Parton Imagination Library servers which are based in the United States. This means personal information will be transferred outside the European Union.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

We may need to share personal information with local authorities, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.

We may be required to share personal information with Statutory or Regulatory authorities and organisations to comply with statutory obligations.   We will only share information on the basis of your consent or in accordance with UK data protection legislation.

How we protect your personal information

Your personal information is stored on our IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you.

How long we keep your personal information

We will only keep your personal information for until your child stops receiving books from the Imagination Library (child reaches 5, your address changes or you no longer want to take part).  We will keep evidence of your application to the Imagination Library for 5 years after which it will be deleted.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold.  This sets out different retention periods and you can request a copy by writing to us at Wheatley Foundation, 25 Cochrane Street, Glasgow, G1 1HL or by e-mailing

The Imagination Library will hold the children’s personal information on their systems for 1 year after they have graduated (their 5th birthday). After this the children’s information is removed leaving only the information of their parent/guardian who signed them up. This information is kept on the book ordering system until the child’s 11th birthday after which all details are removed leaving only statistical information.

Your rights

You can exercise any of the following rights by writing to us at Wheatley Foundation, 25 Cochrane Street, Glasgow, G1 1HL or by e-mailing

Your rights in relation to your personal information are:

  • you have a right to request access to the personal information that we hold about you by making a "subject access request";
  • if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;
  • you have a right to request that we restrict the processing of your personal information for specific purposes; and
  • if you wish us to delete your personal information, you may request that we do so.

Any requests received by the Foundation will be considered under applicable data protection legislation.  If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information.

Changes to our Privacy Notice

Our Privacy Notice is regularly kept up to date and this version was reviewed on 1st August 2021. The latest full version will be available from our website at