Privacy Notice for participants in the STEP Ahead Programme
World Jewish Relief (‘WJR’) is working as the principal contractor with the Home Office and the British Council to deliver the Specialist Training and Employment Programme (STEP Ahead) for up to 430 refugees across the UK. This Privacy Notice explains how and why personal information (or data) about participants in the programme is collected and used and where you can find more information about this and your rights.
Who we are
WJR is a not-for-profit registered charity based at 54 Crewys Road, London NW2 2AD.
If you have any questions about how your information is being used, you can email us at info@worldjewishrelief.org. You can also read more about your rights and the regulations concerning data protection by visiting https://ico.org.uk/for-the-public/.
Personal data collected from STEP Ahead programme participants is managed under the direction and control of the Home Office as the Data Controller, but will be shared with or collected directly by WJR and the British Council as Data Processor and Data Sub-processor respectively, and Ipsos UK as Data Sub-processor. Each of these organisations is obliged by law to keep your personal information private and secure and we have entered into formal legal agreements to ensure that it is only used for the purposes of the STEP Ahead programme.
IPSOS UK may, from time-to-time, ask you to participate in interviews to help understand your thoughts about the STEP Ahead programme and how it may be improved. Your feedback is very welcomed, but you do not have to complete these interviews to remain active on the STEP Ahead service.
The research team will collect the following information from the training provider about everyone who has taken part in the training:
• registration information
• short survey at first session
• short survey at completion / exit
• and participation information (e.g. class attendance)
All information will be anonymised. This means that none of the information passed to the research team will include your name, contact details or date of birth.
What personal information will be collected?
The following categories of data and information about you will be collected as it is considered necessary to deliver services to participants in the STEP Ahead programme:
Name, address, email address, telephone number
Date of birth and age
Visa details
BRP status (Biometric Residence Permit)
Employment status
Information about technical equipment and access to wifi
Access to DWP coach
Childcare needs
Qualifications
Photo
Resume (education and career summary)
Student unique identification numbers
National insurance numbers
Application numbers
Enrolment numbers
Region
Sex
Duration in UK
Date of asylum grant (if applicable)
Course stage – enrolled, initial assessment completed; active/inactive, mid-course assessment complete/incomplete, final assessment complete/incomplete
Attendance levels (days and hours attended)
Dropout levels and reasons as to why learners left the programme
English proficiency of attendees including assessment scores (initial, mid and final)
Employment outcomes (employment levels pre and post intervention)
The changes in the attitudes of learners to employment prospects/English language ability
Attitudes of attendees to employment prospects/language acquisition (through pre and post intervention surveys)
Our lawful basis for processing the data
Personal data may only be collected and processed if there a lawful basis for doing so. For participants in the STEP Ahead programme the lawful bases for the Home Office processing data are:
GDPR Article 6(1) (e) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller);
GDPR Article 6(1) (e) basis includes processing of personal data that is necessary for the exercise of a function of the Crown, a Minister of the Crown or a government department. The Home Office can process the personal data under discretionary executive powers of the Home Secretary;
DPA 2018 Part 2, Chapter 2, section 8 (d) – the exercise of a function of the Crown, a Minister of the Crown or a government department.
WJR and the British Council are Data Processor and Data Sub-processor respectively, each working for and at the direction of the Home Office as Data Controller and subject to the terms of formal data sharing agreements. Additionally, where applicable, WJR is able to process personal data on one or more of the following legal bases:
Express and informed consent has been given by the person whose data is being processed; and/or
WJR has a legitimate interest in processing the data; and/or
WJR has a legal obligation to process the data.
You can ask us not to process any or all of your data by telling us in writing, but this may affect our ability to assist you under the STEP Ahead programme. We may still need to retain some data about you in compliance with our other legal obligations.
How we use your data and keep it safe
We will process (collect, store, use and share) your data strictly in accordance with the law and with our legal agreement with the Home Office for delivery of the STEP Ahead programme; to give participants English language and employment support. For more details of how we generally process personal information and your rights, please refer to our Privacy Policy www.worldjewishrelief.org/privacy-policy.
The Home Office Personal Information Charter explains how the Home Office looks after information that is provided to them, including stating that the Home Office may use information we hold about you to:
- undertake statistical and analytical analysis
- undertake research, including social and ethnographic research.
We will also share some data, where strictly necessary for the delivery and evaluation of the STEP Ahead programme, with the British Council and Ipsos UK, and we will store and manage some of the data we collect using secure spreadsheets. Data will be held on servers in the United Kingdom and we have undertaken the appropriate checks and risk assessments in compliance with UK law. To ensure robust security, we are using an add-on of Hornet, our security system called 365 Permission Data. From 1 October, some data will be moved to be stored and managed using CaseWorthy, a sub contractor used by us to keep personal data safe and secure. Accordingly, some data may be held on servers in the United States (the State of Utah) and to ensure that your rights are protected, we have entered into formal international data transfer agreements with CaseWorthy and undertaken the appropriate checks and risk assessments in compliance with UK law.
If you have any questions or concerns
You have the right to know what personal information about you is being processed by us. If you have any questions or concerns about how your personal data is being processed, please email us at info@worldjewishrelief.org or telephone 020 8736 1250. We may require some enquiries to be submitted in writing and we will have to verify the identity of the person making the enquiry first. We cannot give out information about another person to someone who is not legally entitled to it.
If you have further concerns, or for independent advice about data protection, privacy and data sharing, you can contact:
The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745
https://ico.org.uk/
