Positive Moves is a project run by Clackmannanshire Economic Regeneration Trust (CERT). CERT is committed to protecting the privacy and security of your personal details.

Privacy Notice

Clackmannanshire Economic Regeneration Trust SCIO (CERT)

CERT takes the security of your personal data very seriously.  This Privacy Notice sets out why we need your information, what we need and how we will use it.

Who are we?

CERT is a charity whose head office is ecentre, Cooperage Way Business Village, Alloa, FK10 3LP

Employability Services

Other partners and organisations deliver a range of employability services which support local people of working age who are looking to get into work or progress in employment.

Why do we need your personal information?

You are giving us your personal information to allow us to confirm your eligibility for the particular employability programme you have been referred to and to help us assess your personal and employability needs with the aim of assisting you to move towards, into and progress in work and/or to support your training.

We also use your information to verify your identity where required, contact you by post, email or telephone and to maintain our records.  Our records will include the data captured on Referral and Registration Forms, Individual Training Plans, Training Agreements, Review Forms, Case Notes, Records of Achievements / Outcomes and any other documentation or correspondence relating to the support provided through CERT or one of our delivery partners / organisations.

What information about you is needed?

• Your contact details;
• Other personal data (e.g. your age, gender, National Insurance Number);
• Sensitive personal data (e.g. about your health, religion, ethnicity);
• We will also ask about your employment history and will hold information on the support you receive as a participant of the employability services provided.

What is the legal basis for using your information?

We provide these services to you as through .  Processing your personal information is necessary for:

• The performance of a task carried out in the public interest
• Compliance with a legal obligations in relation to funders and the need to adhere to the associated terms and conditions;
• The performance of a contract with Clackmannanshire Council and their funders with the need to adhere to the associated terms and conditions;
• For the purposes of the UK GDPR, Scottish Government and Clackmannanshire Council and those in partnership, are Joint Data Controllers of your personal information.

Who do we share your information with?

We are legally obliged to safeguard public funds so we are required to verify and check your details internally for fraud prevention.  We may share this information with other public bodies (and also receive information from these other bodies) for fraud checking purposes.  We are also legally obliged to share certain data with other public bodies, such as HMRC and will do so where the law requires this.  We will also generally comply with requests for specific information from other regulatory and law enforcement bodies where this is necessary and appropriate.  Your information is also analysed internally to help us improve our services. 

Your information may be shared with other organisations delivering support services.  The information shared with these organisations will include the information provided by you, referral organisations, Council Departments, external delivery partners, employers and specialist training providers.

CERT is required to pass your information to Clackmannanshire Council, funders, administrators and auditors of public funds, Scottish Ministers, Scottish Government, UK Government, the European Commission and/or other government departments (e.g. Department for Work & Pension, Skills Development Scotland, etc.).

On your approval, your information will be passed to Clackmannanshire Council for your more rapid registrations for other support programmes which are designed to support you such as No One Left Behind, Fair Start Scotland and/or European Structural and Investment Funds.

Evaluation of Programmes

To evaluate the support, funders may also:

• Link your information with data held on you by other government departments, such as Department for Work and Pensions, Her Majesty’s Revenue and Customs or the National Health Service Scotland. This is so we can find out how the services you received made a difference to you in the longer term. This linking will be done in an anonymous way, and you will not be identifiable in any information which is published. The information will be treated so that it is fully compliant with the General Data Protection Regulation;

• Contact you to invite you to take part in the evaluation of services.  Contact could be via third party contractors working on behalf of the funders for evaluation purposes. The feedback you give will be anonymized and will help shape future employability support services. The information collected will be used for research, evaluation and statistical purposes only. You do not have to take part in evaluation activities if you do not want to.

You will not be identifiable in any information which is published. Your experience with Scottish and UK Governments, or any other government agencies, will not be affected in any way, whether or not you take part in any research activities. We will not share your contact information for any marketing purposes.

How will we store your information?

Your data will not be transferred to, stored at, or processed in a destination outside the European Economic Area (EEA).  We will store your information on databases such as FIPS, Hanlon, Cognisoft, SQA Connect, MA Online and EUMIS in locations that have been tested for electronic and physical security and access will be permitted only to those with a need to know.

How long do we keep your information for?

We will only keep your personal information for the minimum period of time required by our funders for the programmes we deliver.  This is so that our funders can perform audit, monitoring and compliance checks to ensure that funding is being spent appropriately.

CERT maintains a Retention Schedule that sets out the periods of time that we apply to keeping particular information, some of which are set down in law. If you wish to get more information about the specific time limit for particular information, please contact the Data Protection Officer whose details are provided below.

Once CERT no longer needs to keep your information, it will be securely destroyed.

Your Rights

Please note that you have the following rights:

Access to your information – you have the right to request a copy of the personal information that we hold about you.

Correcting your information – we want to make sure that your personal information is accurate, complete and up to date.  Therefore you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information – you have the right to ask us to delete personal information about you where:

• you think that we no longer need to hold the information for the purposes for which it was originally obtained
• you have a genuine objection to our use of your personal information – e.g. you have the right at any time to tell us to stop using your personal information for direct marketing purposes 
• our use of your personal information is contrary to law or our other legal obligations.

Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information.  This right might apply, for example, where we are checking the accuracy of personal information that we hold about you or we are assessing the objection you have made to our use of your information.  This right might also apply if we no longer have a basis for using your personal information but you don’t want us to delete the data.  Where this right is realistically applied will mean that we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

If you wish to exercise any of the above rights, please contact the Data Protection Officer, details below.

Information you have given us about other people

If you have provided anyone else’s details when you register for any of our services, please make sure that you have told them that you have given their information to CERT. We will only use this information to assist with confirming your eligibility for the services available and help us assess your personal and employability needs.  Where possible, we attempt to avoid the documenting of identifiable data relating to a third party.  If they want any more information on how we will use their information, they can email info@clacksregen.org.uk.

Right to complain

If you are unhappy with the way CERT have processed your personal data, you have the right to complain.  Any complaints regarding your data should be addressed to:

The Data Protection Officer, Clackmannanshire Economic Regeneration Trust SCIO (CERT), ecentre, Cooperage Village Business Way, Alloa, FK10 3LP

Email:  info@clacksregen.org.uk

Telephone:  01259 272 017

If the matter is not resolved, you can contact the Information Commissioner’s Office at:

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel:  0303 123 1113 (local rate) or 01625 545 745

Web:  www.ico.gov.uk