Privacy Statement

Externally Funded People and Skills Programmes

North Lanarkshire Council

North Lanarkshire Council is a local authority established under the Local Government etc. (Scotland) Act 1994. Its head office is located at Civic Centre, Windmillhill Street, Motherwell, ML1 1AB, United Kingdom.

You can contact our Data Protection Officer, by post at this address or by email:  DataProtection@northlan.gov.uk.

Why we need your personal information and what we do with it?

You are giving us your personal information to allow us to assess your eligibility, progression and results/outcomes and analysis for programmes funded through Scottish Government/ UK Government/ North Lanarkshire Council funded employability programmes.  The Data Processors for this programme are Routes to Work or North Lanarkshire Council (dependent on who has completed the registration form with you) and as such, they will maintain all paper copies of paperwork – Registration Form, Assessment, Action Plan, evidence, meeting notes, etc. All electronic data is stored on our MIS System and will be maintained by North Lanarkshire Council.

We also use your information to verify your identity where required, contact you by post, email or phone and to maintain our records.

Legal basis for using your information.

We provide these services to you as part of our statutory function as your local authority. You can find more details of our role on our website. Processing your personal information is necessary for the performance of a contract with you (or to take steps to enter into a contract with you) and for compliance with a legal obligation to which the council is subject e.g. Equal Opportunities legislation, Race Relations/Equalities legislation, Child Protection etc.

If you do not provide us with the information we have asked for then we will not be able to provide this service to you.

As some of the data that is collected from you is classified under GDPR as special categories of personal data (i.e. those related to ethnicity, health disadvantages, details of criminal convictions and/or other Barriers to Employment), we require an additional legal bases to process it. This is provided under Article 9(2)(b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the Controller. We also need to process this data about you for reasons of substantial public interest as set out in the Data Protection Act 2018.

It is also necessary for us to process it to carry out key functions as outlined by our legal obligations in relation to employment, social security and social protection law. We will also use this information for archiving, research and statistical purposes.

Who do we share your information with?

We are legally obliged to safeguard public funds so are required to verify & check your details internally for fraud prevention. We may share this information with other public bodies (& receive information from these other bodies) for fraud checking purposes. 

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.

This data sharing is in accordance with our Privacy Policy and covered in our full privacy statement on our website. It also forms part of our requirements in line with our Information Governance Assurance Framework approved in terms of the Public Records (Scotland) Act 2012.

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The Information you provide on your registration and Assessment form will be shared by partners and organisations within North Lanarkshire Council and Funders as appropriate.  These include North Lanarkshire Council Employability Services, North Lanarkshire Council Community Learning & Development, North Lanarkshire Council External Funding and Routes to Work. This list is not exhaustive, but your records will only be shared with organisations in relation to your support through North Lanarkshire’s Working projects such as the No One Left Behind fund, Working for Families Fund and the UKSPF programme.

The information will be used for the purpose of supporting you while on the programme and into employment, training, further education or other positive destinations, recording interactions with us and also for research, marketing, statistics and funding requirements.  Your information will be used:

  • To comply with Scottish Government/ UK Government funder rules and regulations,
  • To allow us to monitor the success and performance of services offered and undertake evaluations,
  • To allow us to monitor outcomes of partners and funding streams,
  • To contact you in regard to your time with any of the services / partners,
  • To contact employers and Further Education / Training providers for evidence of outcomes,
  • To monitor compliance with equal opportunities legislation.

How long do we keep your information for?

We only keep your personal information for the minimum period amount of time necessary. The period is set out by the funding requirements and also based on the business need.

We maintain a records retention and disposal schedule which sets out how long we hold different types of information for. You can view this on our website or you can request a hard copy from the contact address stated above.

Information which we need to retain for purposes of UK Government audit requirements will be retained in accordance with the rules set out in the Council Retention Schedule. Currently the minimum retention date is to 31 March 2030 for the UKSPF programme.

Your rights under data protection law

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.  However, for UKSPF reporting purposes, the information you provide on your Registration Form, such as name, address, age, barriers, will continue to be reported as detailed at time of registration.

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 – see Objecting to how we may use your information below,
  • our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we may use your information.

You have the right at any time to tell us to stop using your personal information for direct marketing purposes.

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.

Please contact us as stated above if you wish to exercise any of these rights.

Profiling or automated decision-making processes

Current eligibility for programmes/projects is based on personal and sensitive data – this will have been discussed with you at registration before being asked to sign the Registration Form.

To assist you in the future we may provide information about new projects that you would be eligible for, this will be based on personal data you have provided as per legal basis above.

Complaints

We aim to directly resolve all complaints about how we handle personal information. If your complaint is about how we have handled your personal information, you can contact the Council’s Data Protection Officer by Email – DataProtection@northlan.gov.uk.

However, you also have the right to lodge a complaint with the Information Commissioner’s Office, who can be contacted by post at:

Information Commissioner’s Office- Scotland

45 Melville Street

Edinburgh

EH3 7HL

Telephone: 0303 123 1115

Email: Scotland@ico.org.uk

Please note if your complaint is not about a data protection matter or concerns the handling of personal information, please contact us using the complaints procedures in place.