Policy
While a person is participating in our programme activity, it is reasonable to keep all personal / identifying details including contact details, job history, visa status etc.
For someone who has registered for our programme but not participated because they are ineligible, we will remove their data.
For someone who has registered for our programme but has not participated for another reason (for example, the programme is full or the participant cannot start at the proposed time) we will keep their data for a further 12 months to offer the opportunity for future programmes in that period. If they do not participate in the programme during that time, then we must ask if they are happy for us to keep their details to send information about future activity. If they consent, then their details must be moved to Caseworthy. If they do not consent, then all personal detail must be deleted.
Once the programme activity has concluded, or the person has withdrawn, it is not necessary to keep any records including e.g. case notes of meetings, attendance at employment / English sessions etc. We might want to keep any records related to jobs obtained.
We will keep participants’ data for 18 months after the completion of the programme to enable us to keep up to date with participants’ employment opportunities. At the end of this period, we can ask departing participants if they are happy for us to keep their contact details to be informed about future activity and / or to understand any outcomes / the long-term benefits of their participation. For participants who do not consent, all personal detail must be deleted.
Information should only be stored on Caseworthy and any other documents (spreadsheets etc) should be deleted immediately after use.
If participation has not been part of a time-bound programme, then data must be deleted at the end of the second financial year following their participation.
A deletion exercise should take place every June and is the responsibility of Programme Managers.
For STEP Ukraine / STEP Ahead
All records will be kept until 31 March 2026.
In advance of that date we must ask participants / registrants if they are happy for us to keep their details to send information about future activity and / or to understand any outcomes / the long-term benefits of their participation.
For those on the waiting list or who did not ‘start’ we should ask for their permission to keep their contact details to send information about future activity and / or to understand any outcomes / the long-term benefits of their participation ASAP.
