Restart Scheme Privacy Notice

How we use your information

Ingeus UK Limited is committed to protecting your privacy. This document describes how we process your personal information in accordance with the General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.  It also contains important information about your rights and how to contact us. Further information is available on the Privacy section of the Ingeus UK website (www.ingeus.com/uk/privacy).  

Who are we?

Ingeus UK Ltd has been commissioned by the Department for Work and Pensions (DWP) to provide the Restart Scheme programme in the Greater Manchester and Central and West London regions. Ingeus and our Delivery Partners (B2W (Back 2 Work), Bolton Council, Oldham Council, Rochdale Council, The Growth Company, Seetec Pluss and Wellfair2Work Limited T/A Get Set UK, with whom Ingeus has legal agreements), collect and use information obtained from you, DWP and Jobcentre Plus (JCP) in order to deliver the The Restart Scheme programme.

The Restart Scheme supports individuals to find employment and remain in work, by providing an individual tailored package of support based on an individual’s skills, experience and needs. Through assessment, action planning and working in partnership with specialist partner organisations we aim to develop skills and build confidence to support your journey into work.

Ingeus and the DWP are joint Data Controllers for the processing of personal data in relation to the Restart Scheme services. 

How do we collect your information?

The DWP/JCP relay to Ingeus UK the Personal Data required in order to provide you with the services you need, to take part in the Restart Scheme.  

What Personal Data do we collect from you?

We collect different types of personal data from you, such as your name, contact details and National Insurance Number among other items. We only ever collect as much data as we need to, in order to meet the requirements of the DWP.  

What we use your information for

All organisations must have a valid, lawful reason to process your information. Ingeus UK and its Delivery Partners will only collect and use your information for the lawful purposes of administering the services that we are contracted to deliver on behalf of DWP. We ask you for information about yourself, so that we can support you and to identify services which we feel could benefit you on the programme. 

Your information may also be used for:

• Performance monitoring and analysis to help us assess the quality and standard of our services
• Conducting investigations in response to a complaint or enquiry
• Accounting and record keeping e.g. keeping accounts related to business activities and financial management
• Research and evaluation such as participating in feedback surveys
• Referring you to partner organizations who provide specialist support, training or other services that will benefit you to gain employment as part of the action plan we will develop with you  

Research and evaluation

In order to ensure that we provide you with the best possible service, we may from time to time conduct research and evaluation. Sometimes we will do this by aggregating and anonymising the data, which means that no one can identify you. On occasion we may ask you to take part in a new piece of research and provide additional information or share your information with a third party for the purpose of research, this will only ever be done with your knowledge and consent. Additionally, DWP/JCP have engaged a third party organisation to assess the satisfaction of participants on the Restart Scheme programme.  You have the right to opt out of research and survey activities. 

What is the Lawful Basis for processing your Personal Data? 

The law protecting your personal information is the General Data Protection Regulation (GDPR).  As custodians of your personal information, Ingeus UK are committed to ensuring that your personal data is processed lawfully and respectfully, and by ensuring that we are compliant with the GDPR. 

In accordance with the GDPR, Ingeus UK and its partners must have a valid lawful reason to process your information. If you want to know what the legal basis is for processing your information, please visit: www.ingeus.co.uk/privacy where you can find additional information.  

The law on data protection sets out a number of different reasons for which businesses may collect and process your personal data: 

1. To Meet Contractual Obligations

We are required by the DWP your personal data

2. To Meet Legal Obligations

In some circumstances we are required to pass on details to law enforcement of people who are involved in certain kinds of illegal or criminal activity. This includes disclosure under the requirements of Prevent and Safeguarding legislation. 

3. Legitimate interest

In order for us to provide the services you are expecting from us, we need your data to allow us to run our business effectively.  

For example  

• We will use your personal data to stay in contact with you whilst you are participating in our programmes.  
• We will use your personal data to check on your previous qualifications prior to you starting a government funded training course such as an apprenticeship.  
• We will use your personal data to register you with a qualification awarding organisation  
• We will use your personal data to track your progress through your journey on the Restart programme

How long is your information kept by Ingeus UK? 

We regularly review how long we keep your Personal Data; however, we do have certain legal obligations to retain some types of information for specific periods of time. We only hold on to Personal Data for as long as is necessary in order to process it for the relevant activity, or for as long as is set out in any relevant contract or agreement you hold with us. 

Who has access to your Personal Data? 

We may submit your data to the Department of Work and Pensions and/or funding agencies such as the Education and Skills Funding Agency;; Awarding organisations such as City and Guilds, BIIAB, CACHE.  

Third Part Providers? 

When required to do so, we may share your information with DWP, JCP or your Local Authority, as per contractual obligations and in accordance with the GDPR. 

• Where applicable, we may contact your employer to verify your employment information and share employment details with DWP (see Annex A) 
• With your consent, we may share information with other services which we identify as being beneficial to you
• When necessary, for example, in the unlikely event for emergencies or safeguarding concerns, it may be in your vital interest to share your information with your GP, other Health Professionals or refer to external services that will provide help.

We will not share your information with others unless required to do so by law and unless we obtain your consent.

We do not transfer your personal information outside the EEA. 

Consent 

Where we need your agreement to process your information, for example, by passing your contact details to someone offering a specific service, we will ask for your consent, and will clearly state why your information is needed and who we will share your information with.  If you agree to your information being shared, we will record your consent on your record.  We will regularly review consents to make sure that the relationships, and purposes for processing, have not changed.  

Right to Withdraw Consent

Where you have provided consent for us to share your information with a specific organisation or individual, you have the right to withdraw your consent at any time. Should you wish to withdraw your consent, please tell your key worker, or, send a written request to the Data Protection Officer (address below), who will process your request. 

Your rights

1. The right to Information Access

You have the right to access the information about you that Ingeus UK holds about you. Should you wish to contact us about this, then please contact us at dataprotectionofficer@ingeus.co.uk 

2. The right to Data Portability

You have the right to move, copy or transfer the Personal Data we hold from one IT environment to another in a safe and secure manner. Please be aware, this only relates to electronic information and not paper files. 

3. The right to Rectification

You have the right to correct any personal information that we hold that may be incorrect. To ensure that the information we hold about you is always as accurate as possible, please get in touch.

4. The right to Object to Processing

This right allows you to stop Ingeus UK using your Personal Data at any time for purposes such as direct marketing. Please note, there are exceptions to this right. For further information, please contact us at dataprotectionofficer@ingeus.co.uk  

5. The right to Erasure (Right To Be Forgotten)

You can use this right in certain circumstances, to ask us to erase any personal data that Ingeus UK holds about you. 

You can exercise this right if: 

• we no longer need your data for the reasons we captured it (we will make you aware of the issues that may arise from using this right). 
• you have withdrawn your consent for Ingeus UK to use your Personal Data 
• you have objected to your Personal Data being used for any kind of direct marketing 

You can make a request to erase your data verbally or in writing.  

6. The right to Restriction of Processing

You have the right to restrict the processing of your Personal Data. This means you can limit the way we at Ingeus UK process your information in certain circumstances.