We keep this privacy notice under regular review and was last updated on 14 October 2026.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

View an easy read version of the Marmot Sheppey Accelerator privacy notice (PDF, 619.3 KB).

Who we are

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information.

Marmot Coastal Region Accelerators are funded projects within the Kent Marmot Coastal Region that aim to reduce inequalities by improving access to good, stable employment, particularly for groups who experience multiple disadvantage.

The Marmot Sheppey Accelerator project will trial and review new ways of supporting young people aged 25 and under over a 12-month period to help them develop the skills and experience needed to find work. Working with employers across the Isle of Sheppey (Swale), the project aims to improve employment opportunities for young people.

The project will provide personalised support to young people and help employers and young people better understand each other's expectations. It will also help identify the challenges that can make it difficult for young people to find work and highlight what support works best to help them gain employment and succeed in the work. We will then be able to take what we learn and use it in projects in other parts of Kent. This will help more young people receive the support and they need. It will also help employers to understand how they can adapt their recruitment processes to better attract young people to work for them, which will help their business.

We have commissioned Breaking Barriers Innovations Ltd (BBI) to lead on this project. Pyramid CIC, Oasis and other employment support providers will provide the support to young people and identify suitable young people to take part in the project. You have a choice as to whether you take part in the project. If you do not wish to take part, Pyramid CIC, Oasis and other partners in the local area will still provide you with support. You may withdraw from this project at any time.

The personal information collected and used

We and BBI are joint data controllers.

Partners such as Oasis and Pyramid will ask your agreement to be referred into the project. Only information considered proportionate to provide a good level of support, safeguarding, and effective evaluation, is collected.

Data collected by our partners and provided to BBI

Oasis, Pyramid CIC and other partners will identify young people through their normal delivery and referral activity. Where you agree to be referred into this programme, they may pass limited information to BBI so that BBI can coordinate the programme and evaluation. This may include your:

  • name and contact details
  • age range and local area
  • referral route and which partner is supporting you
  • broad support needs, goals and readiness for programme activity
  • attendance, engagement and progression information
  • outcomes and achievements such as work experience, training, employment, volunteering or other positive destinations.

Detailed case notes held by Oasis, Pyramid, or any other provider will not be routinely shared with BBI unless this is necessary, proportionate, agreed, and covered by the project’s data protection process.

Data collected by BBI directly from you

BBI may collect information directly from you through consent forms, feedback forms, surveys, interviews, workshops, follow-up calls, emails or meetings. This may include your views on barriers to work, confidence, job readiness, recruitment experiences, employer contact, support received and progress during or after the programme. Information that may be collected includes:

  • basic contact details: name, phone number, email address and preferred contact method
  • eligibility and referral information: age range, gender, local area, organisation who referred you and whether the programme is suitable for you
  • programme information: attendance, support received, goals, progression, feedback and agreed next steps
  • employment and skills.

We also want to understand more about the barriers certain groups of young people face in gaining employment. This information is ‘special category data’ (personal data which is more sensitive and is treated with extra care and protection) when you provide it to BBI. With your agreement, BBI may collect information about your:

  • ethnic origin
  • disability or special educational needs
  • sexual orientation
  • mental or physical health.

During interviews or discussion with BBI about your barriers to work, you may disclose other special category information, or information which is not special category data but will also be treated sensitively, such as any experiences of domestic abuse, economic situation, family composition, safety, housing needs, and any involvement with other services. We will also treat any information of this nature with special care.

Employers

BBI may also collect some basic personal data from employer representatives taking part in the programme, for example, name, email address and details of your experience of making reasonable adjustments for young employees in your workplace.

How your personal information is used

BBI will use your personal information to:

  • contact you about the project
  • decide whether the programme is suitable for you and to support your participation
  • help partners coordinate support and avoid asking you to repeat the same information unnecessarily
  • measure progress, including confidence, work readiness, skills development and movement towards employment or training
  • evaluate the programme and understand what should change for future young people and employers
  • produce reports for us and programme partners, using anonymized or aggregated information
  • meet safeguarding, legal, contractual, audit and information governance requirements.

Employers

BBI will use your information to make contact with you and involve you in the project, and to also understand your experiences from an employer perspective.

BBI will collect and analyse data and intelligence to present evidence of the effectiveness and impact of the support a young person has received, and the impact and experience of employers. This may include summaries of your feedback or your journey into employment, or the adaptations an employer has successfully made. This data and information will be shared with our Public Health consultant and specialists who lead on the Marmot programme in Kent but will be anonymised.

Your personal information will be removed from this information before it is shared or published in any report. If we want to use photos or videos, or identify you, we will contact you about this separately to seek your participation.

Reasons your personal information is collected and used

When your personal data is collected, we rely on the following legal basis:

  • 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.

When we collect or share your special category personal data (such as health information) we rely upon the following legal basis:

  • Article 9(2)(g) - processing is necessary for reasons of substantial public interest.

We rely on the 'equality of opportunity or treatment’ condition in the Data Protection Act 2018 when relying on Article 9(2)(g) to process your special category data

We rely on the ‘Consent’ condition in the Data Protection Act 2018 to process your criminal offence data.

Criminal offence data will only be processed where if you voluntarily disclose this information and provide consent for it to be processed. You may withdraw your consent at any time by contacting BBI; their contact details can be found in the ‘Your Right to Withdraw your Consent’ section of this privacy notice. Upon receipt of a withdrawal request, BBI will take appropriate steps to suppress the data and cease further processing.

We take the following appropriate safeguards in respect of your special category and/or criminal offence data when relying on the conditions above:

  • we have an Adult Social Care and Health Directorate Appropriate Policy Document in place when using your special category and/or criminal records data. This policy is retained throughout the time we use your data and for 6 months after we cease to use it.
  • we maintain a record of our processing in our ‘Record of Processing Activities’ and record in it any reasons for deviating from the periods in our Retention Schedule.

How long your personal data will be kept

All information gathered as part of this work will be kept securely by BBI until 31 August 2028 - 12 months after the end of the project. The information will then be securely destroyed.

Aggregated data, which includes numbers and percentages and does not identify you will be kept by us for up to 7 years.

Who your personal information is shared with

Information may be shared only where necessary and authorised for this programme. This may include Oasis, Pyramid CIC and other employment support organisations, where they are supporting your participation.

Anonymised information, which is information with your identifiable information removed, may be shared with us for contract management purposes.

Relevant information may be shared between partners and employers taking part in the project. Information shared will always be with the explicit agreement of each individual concerned and will be limited to the minimum information required. This may occur, for example, when introducing a young person to a prospective employer.

Names of employers taking part in the project may also be shared with us for monitoring purposes.

Safeguarding concerns may require information to be shared without agreement where there is a risk of harm or a statutory duty to act.

Published reports will not identify any project participants (employers or young people). Quotes or case examples will be made unidentifiable unless you give separate written permission to be identified.

Your rights

Under UK GDPR you have rights which you can exercise free of charge which allow you to:

  • know what we are doing with your information and why we are doing it
  • ask to see what information we hold about you (Subject Access Requests)
  • ask us to correct any mistakes in the information we hold about you
  • object to direct marketing
  • make a complaint to the Information Commissioners Office
  • withdraw consent (if applicable).

Depending on our reason for using your information you may also be entitled to:

  • ask us to delete information we hold about you
  • have your information transferred electronically to yourself or to another organisation
  • object to decisions being made that significantly affect you
  • object to how we are using your information
  • stop us using your information in certain ways.

We will always seek to comply with your request. However, we may be required to hold or use your information to comply with legal duties. Please note: your request may delay or prevent us delivering a service to you.

For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the United Kingdom General Data Protection Regulation.

If you would like to exercise a right, contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk .

Your right to withdraw your consent

Where we rely on your consent to process your criminal offence data, you can withdraw your consent to its use at any time. You can do this by contacting BBI at jon.bashford@bbi.uk.com .

You can also tell a BBI team member or your usual support worker, who will pass your request to Jon. You do not have to give a reason. Give your name or participant reference, if known, and say which permission you want to withdraw. You do not need to repeat any offence details.

For criminal offence information covered by your withdrawal, BBI will promptly stop the affected use and sharing, restrict access while dealing with the request, and securely delete information that can still be linked to you from the relevant project records. BBI will coordinate this with us and any authorised holder of a copy and confirm the outcome to you.

Information already made genuinely anonymous cannot be traced back to you for removal. If particular information must legally be kept, we will explain what, why and for how long; it will not continue to be used for the activities you have withdrawn from. Any backup copy awaiting scheduled deletion will be kept out of use. Withdrawing does not affect the lawfulness of earlier use with your consent.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Contact

Contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

Contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk .

The United Kingdom General Data Protection Regulation also gives you the right to lodge a complaint with the Information Commissioner who may be contacted via the Information Commissioner's website or telephone 0303 123 1113.

Read our corporate privacy statement.