Participant Privacy Notice – Youth Guarantee Trailblazer

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Participant Privacy Notice – Youth Guarantee Trailblazer

The Youth Guarantee Trailblazer (YGT) is run by the West of England Combined Authority and Funded through the Department for Work and Pensions (DWP).

Participation in this programme 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”?

Youth Guarantee Trailblazer is led by the Combined Authority, and we are working closely with [insert delivery partner and consortia if relevant] to deliver this programme on our behalf. As such, the Combined Authority is the data controller for the Youth Guarantee Trailblazer. 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/.

Purposes: Why do we want to use your information?

We collect your data to deliver the Youth Guarantee Trailblazer service 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 employability support, skills and training or volunteer goals, and find a path towards a career that is right for you. This will be through training, mentoring and support with transition into employment, enabling you to increase your skills, income and job security.

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 you being involved in this programme is to provide you with recognition that you have taken part and what you have achieved including skills you have developed. We will do this by issuing a digital badge or badges when you accomplish key milestones which may be completion of the programme.

Your organisation or the Combined Authority may issue you with an electronic badge which will detail what you have achieved. The programme will provide more information on this at the right time, but when you accept a badge, you can carry this with you on social media platforms and on your CV.

To issue you a badge your name and email address will be shared with Open Badge Factory Platform delivered by Social Impact Software.

Outcome Star

Measuring the progress and results you achieve is central to the support we provide throughout this programme. To support this, we use a tool called Outcome Stars to help measure and reflect on your development during the programme.

To do this, some personal information such as your name, Date of birth, and progress data will be shared securely with the Outcome Stars platform, managed by Triangle Consulting Social Enterprise. This helps us create your individual Outcome Star and track your achievements.

More details about how your data is used and protected by Outcome Stars can be found in their privacy policy here: https://outcomesstar.org/privacy-policy/.

We will only share the minimum information necessary, and your data will be handled with care in line with data protection laws. This helps us provide you with clear insights into your progress and improve the support you receive throughout the programme.

How will we use your information?

We will use the information you provide to develop a personalised action plan with you, to help you complete the programme, achieve your goals and 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 the Youth Guarantee Trailblazer.
  • 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 Youth Guarantee Trailblazer.

Your information will not be used for profiling, or to make automated decisions.

Statistics, drawn from the participant information held on the YGT database, will be used to evaluate, and report on the programme. We 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.

You may be asked by your mentor (linked person in the organisation who will support you among the programme) if you would like to share your own story as a YGT 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 do all that we can to keep your data secure. We have set up systems and processes to prevent unauthorised access or disclosure of your data. Examples of our security may include:

  • Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password).
  • Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the organisation could work on your information for us without ever knowing it was yours.
  • Controlling access to systems and networks allowing us to stop people who are not allowed to view your personal information from getting access to it.
  • Training for 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 understand that a relationship of trust may only develop over time. Personal information which you choose to share with your facilitator will be treated as confidential and we will not share it externally with other authorities or private businesses unless you give us your permission to do so.

The only exception to this would be if you told your mentor something which had to be shared with others to protect you, or other people, from serious harm. We also have a duty to tell the police if you tell us about a crime, fraud or a terrorist threat. 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 (including information such as your name, address, contact details and photographs of you) will only be accessed by authorised personnel. Personnel includes employees of the Combined Authority and any external agents/partner organisations, such as the Department for Work and Pensions (DWP), the Department for Education (DfE) who may be contracted by any Party to work for the YGT, 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 Combined 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.

Youth Guarantee Trailblazer has been funded by the Department of Work and Pensions (DWP). 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 when your participation has ceased on the project. Information which cannot identify you will be retained after this period and will be used only 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 your participation in the YGT at any time.

It would be valuable for us to understand why the programme is no longer of interest to you so we would simply ask you for your feedback on your experience and reasons for withdrawal.

If at this point you do not want us to contact you again, we will respect your wishes and ensure that no further contact is made unless you tell us you have changed your mind. Your information will be retained on our secure system 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 which is requested of you. In some cases, your refusal may mean you can no longer be a YGT participant, 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

ig@westofengland-ca.org.uk

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.

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