Privacy Statement

Privacy Notice - Employability Projects Referral Pathway

This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect and use personal data for the purposes of assessing your eligibility for various schemes and projects which support employability.

Why we need your information (purposes of processing)

We will collect and use your personal information so that we can:

• Provide you with up to date, impartial information, advice and guidance.
• Monitor the support and services being provided to our customers.
• Share information with appropriate internal department's and external organisations to ensure compliance with safeguarding policies and procedures if required.
• Evidence your eligibility for funding support through our grant funded projects
• Evidence your eligibility for funding support through our grant funded projects as follows:
• Workways+ - Part funded through the European Social Fund through Welsh Government, led by Neath Port Talbot County Borough Council and managed locally by Pembrokeshire County Council.
• Workways+ STU – Part funded through the European Social Fund through Welsh Government, led by Neath Port Talbot County Borough Council and managed locally by Pembrokeshire County Council.
• Tackling in work Poverty Pembrokeshire (TiwPP) – Part funded through the European Social Fund through Welsh Government, led and managed locally by Pembrokeshire County Council.
• Supported employment programme managed by Pembrokeshire County Council.  Part funded through Pembrokeshire County Council, Department for Work & Pensions, Welsh Government and income generation
• To refer you to the following projects if we are unable to provide support directly
• Programmes operated by Futureworks for which you may be eligible for
• Programmes operated by Careers Wales

The information that you provide will be processed according to the UK General Data Protection Regulation, the Data Protection Act 2018 and EU legislation - Welsh European Office ESF grant funded scheme

We will also make any disclosures required by law and we may also share this information with other bodies responsible for detecting/preventing fraud/crime or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost effective way. In order to achieve this, information will be shared with our Audit Service within Pembrokeshire County Council and with The Auditor General for Wales (Audit Wales Privacy Notice (opens in a new tab)).

We will not make any disclosures to third parties for marketing purposes.

Your data will be secure and confidential at all times and we will only collect the personal information that is required to provide you with our service.

What personal data are being collected?

The categories of personal data being collected are:

• Biographical (name, contact details, address etc.)
• Demographical (gender, date of birth)
• Current economic situation (receipt of benefits, employment situation and details)
• Detail of current support you are in receipt of and what support you might like or need, if applicable
• The barriers that are preventing you from progressing in employment or training.

In some cases we may need to ask you for additional data or share more sensitive data such as that relating to:

• Health, disability, criminal conviction, MAPPA information (sex offenders register). This is known as special category data and will only be processed where it is necessary to do so.

What is our lawful basis for processing your personal data?

The UK General Data Protection Regulations (UK GDPR) requires specific conditions to be met to ensure that the processing of your personal data is lawful. These relevant conditions are below:

• Article 6 (1)(e) Public task: the processing is necessary for the performance of a task carried out in the public interest of in the exercise of official authority vested in the controller;

Some types of personal data are more sensitive than others, and need more protection. This is classed as ‘special category data’ and could include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic or biometric data, health and sex life and sexual orientation.

We process this type of special category data as it is necessary for reasons of:

• Article 9 (2)(g) Substantial public interest.

The relevant Data Protection Act 2018 condition is – Schedule 1 Part 2: Equality of Opportunity and treatment

Who we will share your information with

We may need to share your personal data with internal departments, other organisations and third parties, this will include:

• Department for Work and Pensions
• Funding Body - Welsh European Funding Office (WEFO)
• Welsh Government
• European Commission
• Partner local authorities (Ceredigion County Council, Carmarthenshire County Council)
• Other teams and services within Pembrokeshire County Council for example Social Services, Housing
• Evaluators procured to measure the success of projects
• Evolutive - who are our system provider
• RCS Wales – who sub contract the WG In Work Support Service to us
• City and County of Swansea Council
• UK Government – Ministry for Housing, Communities and Local Government (MHCLG)

If we cannot support you we will forward your information onto one of these projects who may be able to offer help:

• Futureworks – Pembrokeshire County Council
• Careers Wales

We use data processors (third parties) who provide services to us in terms of IT provision and disaster recovery.  We have contracts in place with these data processors and they cannot do anything with your personal information unless we have instructed them to do it.  They will hold your data securely and your personal information will only be shared in accordance with UK GDPR.  When it is necessary for your personal information to be transferred outside of the UK as part of these contracts, this will only be done in accordance with the UK GDPR.

Pembrokeshire County Council has a duty to protect the public fund it manages. Therefore, the information that you have provided to use may be used for the prevention and detection of fraud and for auditing purposes both internally and externally.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting CIFAS (opens in a new tab) 

How long do we keep hold of your information?

Pembrokeshire County Council will only keep your information for as long as is necessary. The information provided by you will be held securely and retained in line with Pembrokeshire County Council’s Retention Schedule (10 years after last contact) and/or the Welsh European Funding Office Retention Guidance which can be accessed via the Welsh Government website; WEFO Eligibility rules’ currently no later than 31 December 2027

Your information will be securely disposed of once it is no longer required. This will depend on which employability project you access. Should you wish to know further details about retention periods please contact the relevant Employability team.  

Your Rights

Under data protection law, you have rights including:

• The right to Rectification – you have the right to ask to have your information corrected.
• The right to Restrict processing may apply – you may request that we stop processing your personal data however, this may delay or prevent us delivering a service to you.  We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
• The right to Object – this is not an absolute right and will depend on the reason for processing your personal information.
• The right to Erasure - you may request that we erase your personal data however, this may delay or prevent us delivering a service, or continuing to deliver a service. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
• The right to not be subject to Automated decision making and profiling.
• The right of Access – you have the right to ask us for copies of your personal data.  To make a request, please contact:

Access to Records

Pembrokeshire County Council

County Hall

Haverfordwest

SA61 1TP

Email: accesstorecords@pembrokeshire.gov.uk       

Telephone: 01437 764551

Complaints and Queries

Pembrokeshire County Council endeavours to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring to our attention if they believe that our collection or use of information is unfair, misleading or inappropriate. 

This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below:

Data Protection Officer

Pembrokeshire County Council

County Hall

Haverfordwest

SA61 1TP

Email: dataprotection@pembrokeshire.gov.uk

Telephone: 01437 764551

If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office as the statutory body which oversees data protection law:

Information Commissioner’s Office – Wales

2nd Floor, Churchill House

Churchill Way

Cardiff

CF10 2HH

Email: wales@ico.org.uk

Telephone number: 0330 414 6421

Our Details as Data Controller

Employability Team

Tel: 01437 776609

email: getinvolved@pembrokeshire.gov.uk

Changes to this privacy notice

We keep our privacy notice under regular review.