Privacy Policy - Sefton at Work

HOW WE USE CLIENT INFORMATION

Sefton@Work is Sefton Council’s job brokerage service and offers free, confidential and impartial information, advice and guidance to workless Sefton residents over 16 years on all aspects of jobs, education and training including self-employment.

The categories of this information that we collect, process, hold and share include:

personal information (such as name, client number, address, telephone numbers, email address, nationality, date of birth, national insurance number, employment status, length of unemployment, qualifications and attainment, household details including number of dependants and dependants aged 16-19, lone parent, information on your right to work in the UK)
characteristics (such as ethnicity, disability/learning difficulties, sexual orientation, religion, barriers to employment)
details of meetings and interventions (discussions with adviser, progress updates, details of support provided, referrals).

Why we collect and use this information

We use client data to:

enable us to support clients into employment and learning
enable us to carry out specific functions for which we are responsible
derive statistics which inform decisions about service provision
to contact clients in the event of emergency or appointment cancellation

The lawful basis on which we use this information

We collect and use this information under the provisions and obligations imposed by the UK General Data Protection Regulation (GDPR).

Article 6(1)(c) of the UK General Data Protection Regulation (GDPR) gives the Council a lawful basis for collecting and using personal data in order to comply with its legal obligations and Article 6(1)(e) gives the Council a lawful basis for collecting and using personal data where the 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 Council.

Section 8(c) of the Data Protection Act 2018: personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of the controller’s official authority includes processing of personal data that is necessary for (c) the exercise of a function conferred on a person by an enactment or rule of law

Further to this, Sefton@Work also collects and uses special category data such as race, ethnic origin and health related information.

The Council relies on Article 9(2)(b) of the UK GDPR: 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 domestic law or a collective agreement pursuant to to domestic law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;

The Council relies on Article 9(2)(g) of the UK GDPR: processing of special category personal data is ‘necessary for reasons of substantial public interest, on the basis of domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject’.

The Council relies on Article 9(2)(j) of the UK GDPR: processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) (as supplemented by section 19 of the 2018 Act) based on domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

Schedule 1, Part 2, paragraph 6 of the DPA: the processing of special category personal data is necessary for reasons of substantial public interest and necessary for the purpose of ‘the exercise of a function conferred on a person by an enactment or rule of law’ or ‘the exercise of a function of the Crown, a Minister of the Crown or a government department.’

Equalities data

In most cases it will be that the information is being gathered to assist the Council in meeting its public sector equality duty under section 149 of the Equality Act 2010 and will be anonymised.

The data is also used by Sefton@work and Sefton Council to monitor Service provision and help plan for future service development. Anonymised information will be used to provide data for bids to enable us to attract additional funding.

Collecting this information

The information you provide to us is voluntary and part of an agreement to enable you to access our services.

If you are placed onto an externally funded project the Privacy Notice for that project will also come into force.

Storing this information

We will store your information within our Aptem CRM system and in our secure filing system. If you no longer wish to work with us you can contact us at any time and we agree to delete your record.

We will hold your information for the period of time you are working with us. If we do not have any contact with you for 24 months we will remove your details from our records. If you have received any financial support your record will be retained for 7 years in accordance with Council Finance Policies. If you are engaged on an external employment programme your details will be held for the time specified in their Privacy Notice.

Who we share this information with

Sefton@work may share information with Sefton Adult and Community Learning to provide impartial Information Advice and Guidance to support clients in making next steps into learning.

Agencies we may share your client information if you choose to engage in an additional externally funded project includes the Liverpool City Region Combined Authority.

We do not share information about clients without consent unless the law and our policies allow us to do so.

Data collection requirements

The data we collect is required to enable you to access the information, advice and guidance services offered by Sefton@work, to enable us to source suitable support mechanisms. The lawful basis for processing can be found on page 1 of this document.

Requesting access to your personal data

Under data protection legislation, clients have the right to request access to information about them that we hold. To make a request for your personal information, or be given access to your educational record held by their education provider, contact

Linda Patterson: Employment Programme Delivery Manager Tel 0151 934 2610 email seftonatwork.info@sefton.gov.uk

The rights to access, erasure, rectification and data portability all need careful consideration, along with the right to object to direct marketing, profiling and processing under legitimate interests.The GDPR provides the following rights for individuals:

the right to be informed about the collection and use of their personal data.
the right to access their personal data and supplementary information.
the right to have inaccurate personal data rectified, or completed if it is incomplete.
the right to have personal data erased. This is also known as ‘the right to be forgotten’.
the right to request the restriction or suppression of their personal data.
the right to data portability, where any automated processing of your information based on your consent or as part of a contract is made available for your reuse.
the right to object to direct marketing or any processing based on the performance of a task in the public interest/exercise of official authority or for the purposes of scientific/historical research and statistics.
rights in relation to automated decision making and profiling.

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

the right to lodge a complaint with the supervisory authority (the Information Commissioner’s Office)

Under data protection legislation you have the right to request access to the information we hold about you.

To make this request please contact: