PN132 - Connect, Engage, Listen, Transform (CELT) Project Privacy Notice
Torfaen County Borough Council is committed to protecting your privacy when you use our services. This Privacy Notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards in place to protect it.
TCBC Service Area: Neighbourhoods, Planning and Public Protection
Work area: Skills and Employability
Contact Details: Matthew Davies
Privacy Notice Name: Connect, Engage, Listen, Transform (CELT) project
Data Controller: Torfaen County Borough Council, c/o Civic Centre, Pontypool, NP4 6YB
If you wish to raise a concern about the handling of your personal data, please contact the Data Protection Officer on 01495 762200 or email firstname.lastname@example.org
This notice is intended for participants of the Connect Engage, Listen, Transform (CELT) project. Torfaen County Borough Council is the data controller with other Local Authorities acting as the data processors. Torfaen processes this data in order to monitor and evaluate the project performance as well as to verify the eligibility of participants, activity and expenditure.
Who provides your data to the Council?
For Torfaen County Borough Council, the personal information we process is provided to us directly by you on the forms that you complete as part of the project via the CELT delivery team.
We also receive information from forms completed with help of staff from the organisations that deliver the project, including:
- Blaenau Gwent County Borough Council
- Bridgend County Borough Council
- Caerphilly County Borough Council
- Cardiff Council
- Merthyr Tydfil County Borough Council
- Monmouthshire County Council
- Newport City Council
- Rhondda Cynon Taf County Borough Council
- Vale of Glamorgan Councils
We may receive personal information indirectly from third parties such as awarding bodies and placement or volunteering providers.
How does the Council collect this information?
- Application forms
- Other paperwork or electronic forms you complete on the project
- Data about the qualifications you attain may be collected from the awarding bodies of those qualifications
- Details of your work placement or volunteering will be obtained from the organisation that hosts you
What information does the Council collect about you?
The CELT project collects:
- Personal Identifiers such as Name, Date of Birth, National Insurance number, your previous surname (if any) and a project issued identification number
- Your contact details
- Household status data such as if you have caring responsibilities or are at risk of becoming homeless
- Employment status details such as if you are currently out of work and for how long, if in work your employment details
- Equality of Opportunity data such as gender, ethnicity, memberships of a minority ethnic group, migrant worker status and disabilities or work limiting health conditions
- Assessment and eligibility data such as your starting qualifications, your goals and barriers to employment and/or career progression
- Welsh language data such as your skills using the language and your preferred language for communication
- Data relating to the activities you undertake with the project such as course or group work details, dates, support received and agreed action plans
- Placement Details: Placement provider, placement dates and reviews
- Data relating to the outcomes of the activities you undertake with us such as qualifications attained, gaining employment or other changes in your employment status
We and our data processors will use this data for any or all of the following purposes:
- To contact you about matters relating to your current and future project activity (don’t worry this does not include marketing services from other service areas or providers)
- To assess your eligibility and suitability for and progression in the services offered by the project
- To keep track of your journey and all of the activities and support you may have taken up
- To make decisions about the effectiveness of the services we offer to continually improve our delivery
- To provide anonymous, aggregate, reports and support funding claims to our funding body
- To provide an audit trail of evidence of project activities
- To provide data for an evaluation of the project
Why does the Council process your personal data?
Under Article 6 of the UK General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is:
(e) We need it to perform a public task.
The authority comes from Section 50 of the United Kingdom Internal Market Act 2020 which permits the Secretary of State to fund such activities.
Special categories of personal data
We may collect the following special category data, you will be given the option to refuse to provide such data unless it is needed to demonstrate eligibility for the project:
- personal data revealing racial or ethnic origin
- data concerning health
We collect this under Article 9 of the UK GDPR. We process this data in order to comply with the Equality Act 2010. Health data is also used it to ensure that we provide the most appropriate and effective support that meets your needs and circumstances.
We do not collect any criminal data.
Who has access to your data?
Your data is shared internally only with the appropriate staff where it is necessary for the performance of their roles.
Your data may also be shared externally with organisations. These may include, but not be limited to;
- Awarding and/or certifying bodies (such as Agored Cymru, BCS etc) for your course in order for you to receive a qualification.
- A professional social and economic research organisation for the purposes of evaluating the project.
- Our contracted delivery providers in order for them to organise and run courses for us.
- Commissioned research organisations, who will undertake analysis and potentially interview participants so they can talk to them about their experiences. Not everyone who takes part in the project will be contacted. If a participant is contacted by researchers, the purpose of the research will be explained to the individual and will be given the option to not take part in the research. The research organisations will delete the participants’ contact details once the research is complete.
- Where we agree that you need additional support such as transport to venues or childcare, we may share your contact details with appropriate providers (taxi firms, crèche facilities etc.) in order to make bookings for you.
Where you agree that a referral to another provider would benefit you, we will request your consent to forward your details to another provider. This consent will be collected at the time of the referral and will only be used to share contact details with the provider named on the consent form.
Apart from where previously stated, we do not pass your details to third parties unless we are lawfully required do so.
Is the Data transferred out of the UK?
How does the Council keep your data secure?
The Council has internal policies in place to ensure the data it processes is not lost, accidentally destroyed, misused or disclosed. Access to this data is restricted in accordance with the Council’s internal policies and in compliance with the UK GDPR.
Data will be stored securely in:
Where the Council engages third parties to process personal data on its behalf, they do so on the basis of written instructions. These third parties are also under a duty of confidentiality and are obliged to implement appropriate measures to ensure the security of data.
Our representatives hold the original paper copies of the data in secure restricted access filing areas whilst Torfaen CBC holds the data in electronic form in a secure project data area accessible only to a small number of authorised staff.
How long does the Council keep your data?
The Council will hold your personal data only for the period that is necessary and will follow organisational and Local Authority standards in this area. At the end of the retention period the Council will securely destroy or dispose of the data in line with retention schedules. The CELT project has a separate retention period in line with the contract with the Secretary of State.
- The documents will be kept for 7 calendar years from the end of the project; this currently means 30th June 2029
Are we making automated decisions/profiling with your data?
You have a number of Rights you can exercise:
- Access - to obtain a copy of your data on request
- Rectification – to require the Council to change incorrect or incomplete data
- Object, Restrict or Delete - under certain circumstances you can require the Council to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
- Data portability – to receive and/or transmit data provided to the Council to other organisations (this applies in limited circumstances)
- Withdraw your consent at any time (where consent has been given)
- To know the consequences of failing to provide data to the Council
- To know the existence of any Automated Decision-making, including profiling, and the consequences of this for you.
- To lodge a complaint with a supervisory authority (Information Commissioners Office)
If you would like to exercise any of these rights, please contact: Matthew Davies, Croesyceiliog Community Education Centre, The Highway, Croesyceiliog, Torfaen, NP44 2HF, Matthew.email@example.com
The Information Commissioner can be contacted at: The Information Commissioner’s Office (Wales), 2nd Floor, Churchill House, Churchill Way, Cardiff, CF10 2HH. Telephone 0330 414 6421 or e-mail Wales@ico.org.uk.
Last Modified: 09/05/2023
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