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Skills Bootcamps (learners) privacy notice

This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you. We are required to give you this information under data protection law.

Who we are

This privacy notice explains how we collect, store and use your personal information for the purpose of evaluating the Skills Bootcamps programme.

Skills Bootcamp is a government-funded programme which aims to support learners in gaining new skills and improving their employment prospects. This involves Kent County Council (KCC) and our external partner training organisations designing and delivering a wide range of courses. In order to report to the Department for Education (DfE) and to gain feedback from learners, personal information will need to be collected directly from learners by the training organisation delivering the Skills Bootcamp Programme. This will then need to be shared with KCC and the DfE.

For the purposes of relevant data protection legislation, KCC is the Data Controller for personal information processed for this programme. KCC collects, uses and is 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 (DPA). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

Personal information we collect and use

Information collected by us

In preparation and delivery of the training courses we collect the following personal information when you provide it to us:

  • Name, title, legal sex, date of birth
  • Contact details (address, telephone number, email address)
  • Residency status
  • Employment status
  • Type of benefits received
  • National Insurance number
  • Qualifications
  • Criminal offence data (UK GDPR).

We also collect the following special category data:

  • Ethnicity
  • Specified health conditions, disabilities and learning difficulties.

How we use your personal information

We use your personal information to:

  • provide reports to the DfE for the purposes of funding and potential research purposes
  • gain feedback on the course from the learner to assess and inform future service delivery
  • check that learners have attended a course and to investigate suspected inconsistencies in attendance data
  • research purposes and analysis.

How long your personal data will be kept

We will keep your personal data as part of the Learner Record Service for 7 years (from the end of the academic year in which the learning took place) after which the information is made inaccessible to system users or securely destroyed.

Reasons we can collect and use your personal information

We collect and use your personal information to carry out tasks in the public interest. We rely on the following legal bases under UK GDPR:

  • Article 6 (1)(e): Public task: the processing is necessary to perform a task in the public interest or for official functions (task or function has a clear basis in law).

When we collect or share special category personal data, we rely upon the following lawful bases under UK GDPR:

  • Article 9(2)(g) of the GDPR – Reasons of substantial public interest.

We rely on the statutory and government purposes condition from Schedule 1 of the Data Protection Act 2018 to process your special category data.

We take the following appropriate safeguards in respect of your special category data when relying on the conditions above, we:

  • have a retention schedule which explains how long data is retained
  • maintain a record of our processing in our ‘Record of Processing Activities’ and record any reasons for deviating from the periods in our retention schedule.

Where we collect criminal offence data, we do so under UK GDPR and our legal basis for doing so is Condition 36 (substantial public interest) in Schedule 1, Part 3 of the Data Protection Act 2018.

Who we share your personal information with

  • Teams within KCC. Access to personal data is limited to authorised KCC personnel who have passed security checks.
  • Commissioned providers
  • Partner organisations signed up to the Kent and Medway Information Sharing Agreement, where necessary, which may include DfE and other government departments as required. We sometimes need to make personal data available to other organisations. We plan to track participants’ longer-term outcomes through links to administrative data held by DfE, DWP and HMRC.

We will share personal information with law enforcement or other authorities if required by applicable law or in connection with legal proceedings. We will share personal information with our legal and professional advisers in the event of a dispute, complaint, or claim. We rely on Article 9(2)(f) where the processing of special category data is necessary for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity.

Your rights

Under 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 request)
  • 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 at any time (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. 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 GDPR.

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

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.

You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.

UK GDPR also gives you right to lodge a complaint with Information Commissioner, who may be contacted via the Information Commissioner's website or call 03031 231113.

Read our corporate privacy statement.