Privacy Notice
Skills Connect and Future Bright - Privacy Notice
Participant Privacy Notice – Skills Connect and Future Bright
Skills Connect and Future Bright are funded and run by the West of England Combined Authority (‘the Combined Authority’). Participation in these programmes is voluntary, and your choice should be informed. As such, the purpose of this notice is to explain our use of your “personal data”, such as how we will use information you give to us and what we will use it for, and your rights as a “data subject” regarding information we hold on you and how we will protect your privacy rights. After you have read and understood this privacy notice, you will be asked if you want to participate.
Who are “we”?
Skills Connect and Future Bright are led by the Combined Authority, and we are working closely with Bath and North East Somerset, Bristol City and South Gloucestershire Councils to deliver these programmes on our behalf. As such, the Combined Authority and the Unitary Authorities are Joint Data Controllers for Skills Connect and Future Bright. Data protection law sets down the rules for data controllers, which means we are responsible for keeping your personal data safe, for using it lawfully, and for ensuring your rights to privacy are respected.
What is your “Personal Data”?
Personal data is information which is about you, and which identifies, or could identify, you as an individual. This means it could be used to make decisions which have a direct impact on you.
Transparency: what we need to tell you
As a data subject, you have rights under the law of data protection. You have the right to be informed by us about:
- what personal data we would collect from you as a participant
- how we would use it, and for what purpose
- who we would share your information with, and why
- your other data subject rights and how to exercise them
- retention periods for your data
Full details can be found at https://ico.org.uk/for-the-public/.
Our legal basis for using your personal data
Under data protection rules, there are certain conditions which must be met for the lawful use of other people’s information, and we are obliged to tell you which condition applies to Skills Connect and Future Bright and their participants:
- Participation in the programme is voluntary, and you are required to read this privacy notice to ensure you understand how we process your data.
- Our lawful basis for processing participant information in accordance with Article 6(1) is (e) Public Task. As a public authority with official functions defined by legislation the Combined Authority has “official authority” to be involved with Skills Connect and Future Bright, including its use of participant information, because it is in line with this official role and our related responsibilities.
- Personal information collected from participants which is “special category data”, such as information about your ethnic origin or health, is granted extra protection under UK GDPR. We rely on (g) reasons of substantial public interest as the Article 9 basis for processing special category data, and the condition of this we meet for processing special category data is (8) equality of opportunity or treatment.
- Information relating to criminal convictions or offences is also granted extra protection under UK GDPR. We rely on substantial public interest condition (6) statutory and government purposes as the Article 10 basis for sharing of information relating to criminal convictions or offences.
Purposes: Why do we want to use your information?
We collect your data to deliver Skills Connect and Future Bright to you, and to ensure we meet your personal needs. This includes, where appropriate, issuing you with a digital badge, further details on which are included in the ‘Digital badging’ section later in this notice.
Our primary aim is to help you to reach your work, skills and training or volunteer goals, and find a path towards a career that is right for you. This will be through career coaching and mentoring, information advice and guidance and helping you to access training and other support, enabling you to increase your confidence, skills and income.
We also collect your data to ensure targeted groups of individuals are enrolling on to the programme. Our aims include improving understanding about any challenges or discriminatory treatment our participants may face, for example due to their physical or mental health conditions, disabilities, criminal record history, sexual orientation or ethnicity.
Furthermore, successful training and career outcomes for our participants are intended to contribute to our broader aim of furthering the growth of the local economy and the skillset of the workforce in the West of England region.
What kind of personal data will we collect and record?
We may ask you to provide information including, but not limited to, the following:
- Personal details, e.g. name, sex, date of birth and main language
- Contact details, e.g. email address, home address and phone number
- Personal circumstances, e.g. caring responsibilities and housing situation
- Employment details, e.g. employment status and income
- Academic details, e.g. previous qualifications
- Demographic details, e.g. your ethnicity and whether you consider yourself to have any disabilities / learning difficulties / health conditions
The information we collect will be determined by whether we have decided it is necessary. Additionally, if you exit the programme before completion, we will ask for your reasons for exiting the programme.
Digital badging
A key part of your involvement in these programmes is the recognition that you have participated and of what you have achieved, including skills you have developed. Your organisation or the Combined Authority may issue you with an electronic badge detailing what you have achieved which, if you accept, you can carry with you on social media platforms and on your CV. To facilitate issuing you with a badge, a claim code will be sent to you. If you accept, your name and email address will be shared with Open Badge Factory. Skills Connect and Future Bright will provide more information on the digital badging at the appropriate time.
How will we use your information?
We will use information you provide to develop a personalised action plan with you to best support you to complete the programme, achieve your goals and track your progress in your employment, skills or training situation.
Access to information which can identify you as an individual will be limited to a small number of people who are working for us on this project, and they will only use this personal data to:
- Deliver services and support to you, including to organise and/or review your sessions with any training providers or career support services.
- Contact you about your participation in, and experience of, the programme to review the delivery and operation of Skills Connect and Future Bright.
- Monitor programme delivery, including research and statistical work.
- Allow required audits to be carried out to ensure quality and compliance.
- Make you aware of any updates, changes, or promotions in relation to Skills Connect and Future Bright.
Your information will not be used for profiling, or to make automated decisions.
Statistics, drawn from the participant information held within the Combined Authority’s data lakehouse, will be used to evaluate and report on the programme. As well as reporting on the programme within the Combined Authority, we also report to Government, Local Authorities and partners about the outputs and outcomes of the project to demonstrate the impact of the project, and this information may be published.
Where applicable, you may be asked if you would like to share your own story as a Skills Connect and Future Bright participant and be considered for a “case study”. This may then be published in line with your preferences selected on the form.
How do we protect your information?
We are committed to keeping your data secure, and have set up systems and processes to prevent unauthorised access or disclosure of your data. Examples of our security may include:
- Encryption, meaning information is hidden so it cannot be read without special knowledge (such as a password).
- Pseudonymisation, meaning we will use a different name or reference to hide parts of your personal information from view so someone could work on your information without ever knowing it was yours.
- Controlling access to systems and networks, for example our data lakehouse, allowing us to stop people who are not allowed to view your personal information from getting access to it.
- Training our staff to make them aware of how to handle information and how and when to report when something goes wrong.
Where information is not stored electronically, e.g. it is collected in a paper format, we will ensure it is kept secure, and destroyed when no longer required.
Confidentiality and sharing of information from discussions with your facilitator with others
We want you to feel you can speak freely and openly in discussions with your facilitator. We are open to considering any aspect of your life you feel is relevant to your situation, which may include sensitive or private information, and so it is important that you trust your facilitator to keep this information safe and not share it with others. Personal information you choose to share with your facilitator will be treated as confidential and will not be shared externally with other authorities or private businesses unless you give us your permission to do so. However, records of conversations and interactions including signposting and advice provided are kept within our organisation.
The only exceptions to this would be if you told your facilitator something which had to be shared with others to protect you, or other people, from serious harm, or if you tell us about a crime, fraud or a terrorist threat which we have a duty to tell the police. Even in such exceptional cases, you would still have the right to be informed about such reporting (what information we need to report, with whom, and for what purpose) so long as this would not increase the risk of harm to others.
Confidentiality and sharing of your personal data with others
Information which can identify you (such as your name, contact details and photographs of you) will only be accessed by authorised personnel. Personnel includes employees and any external agents / partner organisations who may be contracted by any Party to work for, or in support of, the programme, and who are legally bound to comply with that Party’s data protection instructions and policies about use of participants’ personal data. Data may be processed abroad, but all legal requirements will be in place for this to happen. If you choose to access support or training from another provider, you will need to refer to their privacy notice to understand how they handle your information.
Your information may be shared within the Authority to ensure you are receiving the most suitable support available, including offering ongoing support after completion or withdrawal. This internal sharing will be limited to that which is necessary, based on specific internal referral criteria.
If you are referred to the programme by another professional, or where we work in partnership with another provider or your employer to help aid your progression, it may be beneficial to update them at stages regarding your progress. Before any of your information is shared in this way, you will be told what may be included in such a discussion and then asked for your permission to share this information.
Skills Connect and Future Bright have been funded by the West of England Combined Authority. For this reason, the Combined Authority will need to share outputs and outcomes with government. Data shared will not be personal or identifiable data, however, we will report intelligence around overall progression information.
How long will we keep your personal data?
Information which can identify you will be retained for a maximum period of 7 years from the later of when your engagement with or your participation on the project has ceased. Information which cannot identify you will be retained after this period for statistical and research purposes.
Legislation tells us how long we need to keep some information to perform any statutory or contractual duties. Some data must be held to meet the requirements for public grant funding and auditing requirements. Personal information kept for this reason will be restricted to a minimum.
What happens if you no longer wish to participate in the programme?
You may choose to withdraw from participating in Skills Connect and Future Bright at any time. It would be valuable for us to understand why the programme is no longer of interest to you, and so we would request your feedback on your experience and your reasons for withdrawal.
If at this point you do not want to be contacted again, we will ensure that no further contact is made, unless you inform us that you have changed your mind. Your information will be retained securely in case you choose to participate again in the future. However, you may request that we remove any details which can identify you from our records and we shall do so to the extent possible in line with our statutory or contractual duties. You may request we do this by contacting us directly or raising this with your local team.
You have the right to refuse information or object to the usage of your information
You have the right to refuse to provide information requested of you. In some cases, this may mean you cannot participate in Skills Connect and Future Bright, but we will explain this to you before you make a decision.
You also have the right to object to our use of your information. This means you can request that we stop using any information that you have already given which can be used to identify you, and request that we delete this from our database.
You have the right to access the personal data we hold about you
To request a copy of your records you may submit a “Subject Access Request”. Further details on this process, including the easiest way to submit your request, can be found at: https://www.westofengland-ca.gov.uk/cookie-policy/subject-access-request/.
Full details about your rights as an individual can be found at: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/.
Contact for privacy concerns and Subject Access Requests
If you have any concerns or questions about our handling of your personal data, please contact the Data Protection Officer at West of England Combined Authority:
Data Protection Officer
West of England Combined Authority
70 Redcliff Street,
Bristol
BS1 6AL
Your right to appeal
If you are not satisfied by our response to your concerns, you may lodge a complaint to the Information Commissioner’s Office (ICO) as the regulator for data protection issues. They will investigate your complaint and decide about what we need to do. You can find out how to make a complaint here: https://ico.org.uk/make-a-complaint/.
Through the above link, you can contact them through their live chat or their online form. Alternatively, you can call them on 0303 123 1113.