Privacy Statement

Privacy Notice - Youth Engagement and Progression Framework

This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data for the purposes of delivering Welsh Government’s Youth Engagement & Progression Framework. This is a Local Authority-led, young-person centred network of brokers, responding to those identified as at risk of disengagement and then providing alternative curriculum support and provision to help young people make genuine progress. In addition it supports the Local Authority’s partnership working with post-16 providers (e.g. the Pembrokeshire Federation), to maximise learner choice. It supports learner’s aspiration to engage in careers in regionally important career pathways as part of the SPARC Project (Sustainable Power & Renewable Construction). It also supports more able and talented learners in aspiring to progress into Higher Education through the Seren Network.

Why we need your information (purpose of processing)

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

• Identify young people most at risk of disengagement
• Assess eligibility for our services
• Deliver better brokerage and co-ordination of support and provision activities that you may need
• Provide stronger tracking and more effective transition of young people through the stages of education, training and employment
• Ensure the provision we provide meets your needs
• Strengthen employability skills and opportunities for employment
• Demonstrate greater accountability of our services

The information that you provide will be processed according to the UK General Data Protection Regulation, the Data Protection Act 2018, the Learning & Skills Act 2000 (s33, 40, 138 & 140), the Children’s Education Act 2004 (s25), and The Education (Information about Individual Pupils (Wales) Regulations 2007, European Regulations 1303/2013 and 1304/2013, The SEN Code of Practice for Wales, Youth Engagement and Progression Framework, Local Government Act 2000 (s2), Government of Wales Act 2006 (s60), Employment and Training Act 1973 (s8, 9 & 10).

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 and Cookie Policy (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 is being collected?

The categories of personal data being collected are:

• Name (including aliases) 
• Date of Birth
• Address
• National Insurance Number, ULN and UPN, Cynnydd Operation Identifiers
• School and Year group
• Personal profile
• Education/training history including examinations results, attendance and exclusion history, predicted grades
• Barriers to learning and/or engagement
• Wellbeing indicators
• Risk/safeguarding issues
• NEET status
• Young person’s aspirations
• Health/medical information
• Intended Post-16 and post-18 destination (further/higher education, training or employment)
• SEN and ALN status
• Eligibility for Free School Meals entitlement
• Looked After Child status
• Ethnicity 

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 you to perform a task in the public  interest or for your official functions, and the task or function has a clear basis in law.

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 in accordance with the above listed legislation.

(The relevant Data Protection Act 2018 condition is – Schedule 1 Part 2: Statutory and Government purposes)

Processing of special category data is necessary for the purposes of exercising the functions outlined above and it will not be possible to deliver these functions without the processing of both personal data and special category data.

Who will we share your information with?

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

• Internal departments: The Youth Service, The Inclusion Service, Futureworks, the Cynnyd Operation, Social Care & Housing, Performance & Community Team, School Improvement Service, External Funding Team for SPF funded projects (e.g. PEPs Pre-Engagement Transition Programme)
• The Welsh European Funding Office (WEFO) as part of the Cynnydd Operation
• Third Party education/training & support providers: Pembrokeshire College, Coleg Sir Gâr & Coleg, Ceredigion, PRP Training, SPPOT, Really Pro, MPCT, Milford Youth Matters, Fishguard and Goodwick Young Person’s Trust Ltd (POINT), Pembrokeshire Association of Voluntary Services, The Tanyard, The Hive
• Careers Wales
• The Dyfed Seren Hub comprising Carmarthenshire & Ceredigion County Councils
• The Sustainable Power and Renewable Construction (SPARC) Project comprising Pembrokeshire College, Pembrokeshire Coastal Forum and the University of the West of England

Sharing Special Categories of personal data is necessary for the reasons of substantial public interest to identify barriers/potential barriers to education, training and employment so that it is possible to implement a strategy to prevent young persons from becoming NEET (not in education, employment or training).  The aim of these strategies is to prevent young persons from becoming NEET and to promote equality of provision and opportunity which is in the substantial public interest as in addition to supporting individual data subjects concerned, such strategies will support wider economic and social wellbeing in Wales and will support the effectiveness of expenditure on education and training.

Sharing special category personal data with other organisations interested or concerned in the delivery of education, training and careers services will, where required / appropriate, facilitate the above in the substantial public interest.

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 funds it manages. Therefore, the information that you have provided to us 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 the following –

Transitioning Pupils – till 25 years of age

Post 16 NEETS – till 25 years of age

SPARC Project – Until pupils leave School at 16 or 18

The Cynnydd Operation: These records will be retained until we are advised by WEFO (or replacement body) that they can be destroyed / discarded.  We cannot predict precisely how long this will be. The rules for document retention are set out in The WEFO Project Closure Guidance and indicate records will need to be retained until at least 2026. Please see the Cynnydd Privacy Notice for further details.

Your information will be securely disposed of once it is no longer required.

Your Rights 

Under the UK General Data Protection Regulation and Data Protection Act 2018, you have rights as an individual 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 or 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 Contact Details as Data Controller are:

Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP. 

Telephone number: 01437 764551 or enquiries@pembrokeshire.gov.uk

Our Data Protection Officer’s information is detailed above in the Complaints and Queries section.

Changes to this privacy notice

We keep our privacy notice under regular review.