Privacy Notice

How We Use Your Personal Information

About this Privacy Notice

This Privacy Notice explains how CSW uses your personal information to deliver the #Focus5 service and who we share your personal information with.

Within this Privacy Notice, we use the following terms:

  • Data controller – means the organisation which decides the purposes for which, and the way in which any personal data are, or are to be processed. 
  • Data Processor - means the organisation which processes the data on behalf of the data controller.
  • Processing - includes most operations involving data including obtaining, recording, sharing, deleting, adapting or altering the information.

About #Focus5

#Focus5 is a voluntary project which is managed by Devon County Council (DCC) and delivered by CSW on behalf of The Department for Work and Pensions (DWP). The project is funded by The National Lottery Community Fund’s (TNLCF) “Building Better Opportunities Programme” and the European Social Fund (ESF) which funds projects across England that tackle poverty and promote social inclusion.

More information about the #Focus5 project and what CSW do can be found in the ‘'What We Do’ pages of our website.

Participation in the #Focus5 Project is voluntary, however, if you choose to participate, regulations relating to CSW’s project funding require us to share certain information about participants with the DWP, TNLCF and the ESF for monitoring purposes.

 

Who are the Data Controller and Data Processors for the Building Better Opportunities Programme?

The Data Controller for the Building Better Opportunities Programme is DWP. The DWP is the controller for all personal data required to deliver the European Social Fund (ESF) programme under the terms of its ESF Funding Agreement.

CSW is the data processor of personal information relating to the #Focus5 project which CSW is delivering on behalf of the DWP. CSW processes the data on behalf of Devon County Council (DCC) who is the grant holder and accountable body for the project. As CSW is in receipt of grants from the ESF (via DCC as the grant holder), it is a data processor in respect to information processed which relates to participants in the operations and projects funded by the ESF.

 

The type of personal information we collect 

We collect and process personal information which may identify you as an individual.  Examples of the types of personal data that we may collect, use, store and share (when appropriate) are outlined in Appendix 1.

 

The purposes of the data processing

CSW processes personal information for the purposes of delivering the #Focus5 project including the provision of one-to-one support to young people aged 15-18 across Devon, Plymouth, Torbay and Somerset, who may be struggling to move forwards in life. We use personal information to help young people take steps back into education, employment, or training for example through the development of key skills such as communication and teamwork.

 

Examples of what we may use personal information for might include helping a young person with opening a bank account, learning about financial independence, navigating public transport, creating a CV and applying for jobs, finding training opportunities, mentoring, support with returning to education or developing life skills.

 

Information sharing

The information that you provide to CSW Group will be shared with the DWP and used to evaluate this project and to report to The National Lottery Community Fund and European Social Fund for monitoring purposes, in line with European Commission regulatory requirements.

Your information will also be shared with research organisations working on behalf of the DWP who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary. If you do not wish your personal data to be used for ESF evaluation purposes please contact ESF.EVALUATIONS@DWP.GSI.GOV.UK and we will delete your data held for these purposes and you won’t be contacted about participating in research.

 

The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left. This information may also be shared with research organisations working on behalf of the DWP however individuals will not be identifiable, and you will not be contacted about this research.

Your personal information will not be used or shared for any commercial or marketing purposes.

At all times your information will be kept securely, and nobody will have access to it who shouldn’t.

 

The lawful basis for the processing

For the purposes of the General Data Protection Regulation (GDPR) and related data protection legislation, the DWP is the data controller in respect to information processed which relates to all participation in the ESF.

As CSW is in receipt of grants from the ESF (via DCC as the grant holder), it is a data processor in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund. CSW process this data on behalf of DCC.

Data Protection law requires us to have a lawful reason (‘lawful basis’) for processing the personal data we use. These reasons are listed under Article 6 of the ‘General Data Protection Regulation’ (GDPR). The lawful basis for processing your personal information is included below.

Consent is the lawful basis for processing personal data up until the point that a young person is accepted on to and starts #Focus5.

If consent is the only legal basis we have to use your personal information, you have the right to withdraw consent at any time by contacting data.protection@cswgroup.co.uk.

 

The lawful basis for processing personal data once the young person starts on the #Focus5 programme under the ESF is:

  • Article 6 (1) (e) GDPR: ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’.

Special Category Personal Data (Sensitive Data)

We may also collect, store, and use information about you that falls into "special categories" of more sensitive personal data which has extra protection in law and requires us to identify a condition for processing under Article 9 of the GDPR. For example, this might include some of the reasons that are included on the Referral Form or on the Participant Entry Form to assess eligibility for the project.

Special category data is personal data including:

  • Ethnicity
  • Gender
  • Data concerning health/learning difficulties and disabilities.

 

 

The GDPR provides the DWP (and CSW as the data processor on behalf of DCC) with the following special category condition for processing `special category’ (sensitive) data:

  • Article 9(2) (b) “processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;”

Consent and other Lawful Bases:

The DWP is not the controller for any other data collected by CSW Group that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by CSW Group.

Where CSW processes any personal data that is not essential for delivering the ESF programme, or that would normally be collected anyway by CSW Group then this will usually be processed with your consent (or explicit consent for special category data).

The ESF Programme Action Note 018/18 sets out further information about the DWP’s lawful basis for processing personal data under ESF.

 

How long we keep your personal data (Retention Periods)

All personal data held by DWP or research contractors for the purposes of evaluation (e.g. evaluation of the success of the project/programme) will be permanently deleted no more than six months after the research has been completed (i.e. when the final report is published on GOV.UK).

Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK at:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/591617/ESF_Guidance_on_document_retention.pdf

In accordance with our ESF Funding Agreement, ESF Grant Recipients (i.e. CSW) are required to keep accurate records, including retention policies. Retention periods for personal data held by CSW for ESF purposes will be in line with the ESF Guidance on Document Retention (see link above).

All personal data collected by CSW is securely stored and is held for no longer than is necessary in line with requirements of data protection law. We will then securely dispose of your information.

 

Your Data Protection Rights

Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal information.
  • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure - You have the right to ask us to erase your personal information in certain limited circumstances
  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances, if you object to the continued processing of your data, we will weigh up your objections against our grounds for continuing with the processing.
  • Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
  • You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
  • Please contact us at data.protection@cswgroup.co.uk if you wish to make a request.

 

More information about how and why DWP uses your personal information, including how to ask for a copy of the personal information that the DWP holds about you can be found in DWP’s Personal Information Charter at:

https://www.gov.uk/government/organisations/department-for-work-pensions/about/personal-information-charter

 

Information about how to ask for a copy of the information DWP holds about you (known as a ‘Right of Access Request’) can be found at:

https://www.gov.uk/guidance/request-your-personal-information-from-the-department-for-work-and-pensions

 

Contact Details

If you have any questions, queries or complaints, and to exercise your personal data rights including your right to access your personal information, please in the first instance discuss this with your Key Worker or you can contact the CSW Data protection lead at data.protection@cswgroup.co.uk.

If you have any questions relating to how the DWP are processing your personal data or if you wish to exercise your data protection rights relating to information processed by the DWP then please contact the Data Protection Officer at the Department of Work and Pensions rightofaccess.requests@dwp.gsi.gov.uk  .

You can contact the Information Commissioner’s Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

 

 

Appendix 1 - Non exhaustive list of examples of the types of personal data which we collect about the young person and person referring the young person (e.g. parent, carer, teacher).

 

  • Name
  • Date of Birth
  • Address
  • Age of young person at referral
  • National Insurance No
  • E-Mail Address
  • Phone No
  • Position/Agency (of referrer)
  • Reason for referral, and any other supporting information
  • Economic / employment status
  • Educational establishment and course information
  • Gender
  • Ethnicity
  • Qualifications
  • Household situation (e.g. employment status of household members, dependents etc.)
  • Homelessness
  • Offender / ex-offender status
  • Health conditions / disability