This privacy notice tells you what to expect when your personal information is processed in connection with the Love London Working (LLW) programme. It applies to information about all LLW applicants, participants and other service users. Personal Data will be processed in accordance with all relevant data protection law. In the event of the United Kingdom exiting the European Union, all parts of this privacy notice shall still apply.
You should also refer to the privacy notice(s) of the Department of Housing Communities and Local Government (MHCLG), the Department of Works and Pensions, the GLA and the Delivery Partner(s) you are working with for full details on how your information will be managed by them. These can be found on their websites, or you can ask them to send you a copy.
1. What and who is Love London Working?
LLW is a training and employment project part funded by the European Social Fund and delivered by a partnership of 13 social housing providers (see below), each with a significant presence in London.
The Data Controller for LLW programme is the Department of Housing Communities and Local Government/ The Department of Work and Pensions. For the purposes of the General Data Protection Regulation (GDPR), the DWP is the data controller in respect to information processed which relates to all participation in the European Social Fund. ESF grant beneficiary organisations are data processors in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund.
DWP is not the controller for any other / additional data collected by your delivery partner that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by your delivery partner. The Greater London Authority is the London Intermediate Body. These bodies are responsible for the funding and strategic management of the LLW Programme (‘the Managing Authority’).
For the purposes of this partnership the following companies are known as ‘Delivery Partners’:
Clarion Housing Group is the lead Delivery Partner. The following Delivery Partners are also Data Processors for LLW:
- A2 Dominion
- Clarion Futures
- Charlton Triangle Homes
- Hexagon Housing
- Hyde Housing
- One Housing
- Poplar HARCA
Each ‘Delivery Partner’ is a Data Controller for how your personal information is processed within their organisation and has its own data protection policies, procedures and registrations with the Information Commissioner's Office. Further details can be found here: https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/
2. Why does LLW need to process my Personal Data?
LLW processes your Personal Data:
- To confirm your eligibility for participation in LLW and to match and register you with your potential Delivery Partner who will support you on your LLW journey.
- To work with you assessing training and personal needs, employment barriers, competence levels and understand your career goals leading to the development of individual action plans and support programmes.
- For referral purposes e.g. to connect you with specialist support agencies and local partners.
- To broker training and employment opportunities by matching you with suitable placements.
We cannot offer services without checking you meet the eligibility criteria (including special categories of data) for this purpose. We will make you aware when we collect data whether this is optional.
- Maintaining records of support and engagement in accordance with the requirements of the European Social Fund, MHCLG and the Department of Works and Pensions.
- To evidence appropriate use of European Social Fund monies.
We are obliged by our regulators to provide this information.
- For monitoring and reporting purposes; for research and development, customer administration and to identify areas for service improvements.
We are obliged by our regulators to report on the program. It is also in our legitimate interests to understand how we are performing so we can make improvements to our service.
The DWP ESF Managing Authority process personal data in the ESF programme according to Article 6(1)(e) of GDPR, as it 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.
Special category data is processed according to article 9(2)(b) of GDPR. processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
More information about how and why DWP uses your personal information, including how to ask for a copy of the personal information DWP holds about you can be found in DWP’s Personal Information Charter at: https://www.gov.uk/government/organisations/department-for-work-pensions/about/personal-information-charter
3. Information that may be collected from you and how this is used
You will only be asked to provide personal information that is relevant and appropriate to enable Delivery Partners to provide project related services. You can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact a Delivery Partners’ ability to provide some services to you if you refuse to provide information that prevents them from doing so. The information collected about you will concern your relationship with the LLW project and will be used for the purpose of delivering LLW related services including:
- Name and Date of birth
- Address and Contact details (phone /mobile /email)
- Household type and household members
- Economic status
- Skills level and details of previous work experience, training and education
- Details of any dependents
- Right to work information such as details of immigration status and nationality
- Racial or ethnic origin*
- Trans identity and gender reassignment*
- Physical or mental health condition*
- Convictions, proceedings and criminal acts*
- Employment references – to include confirmation of employment start and end date
- Any additional support requirements detailed in your action plan or plan review (which will be agreed with you).
*These items constitute Special Categories of Data (sensitive personal information). We will only process this information with your consent or when we are legally obliged or permitted to do this. We collect this data to ensure our services are accessible; that we take account of any support needs in our dealings with you and to assist in tailoring the LLW services you receive to best meet your needs. Where you give your consent for us to process any data, you can withdraw this consent at any time by contacting your Delivery Partner.
Generally the information processed by LLW will have been provided by you (e.g. on application forms or in communications with you), but information may also be provided by third parties where this is relevant to your involvement with the LLW project e.g. from an employer or support services.
Markers may be applied to your information (for example, in relation to your vulnerability or health status) to enable Delivery Partners to tailor and deliver services to you.
We do not undertake automated decision making or profiling which has legal or similarly significant effect on you (where a computer system makes a decision about you without human intervention e.g. deciding if you are eligible for a loan). We do use software tools but any decisions about you are made by our staff rather than ‘automated’. Should this change in the future, we will inform you and explain your rights relating to this, for example that you have the right to challenge the validity of any decisions made in this way or object to automated decision making and ask us not to use this method of processing.
4. How your Personal Data is managed
When you apply to participate in LLW, you will be assigned to work with a Delivery Partner(s), based on:
- Whether you are a current resident of a Delivery Partner
- Your location in London (if you are not a current resident of a Delivery Partner)
- If you have specific needs/requirements which would be best met through the specialist expertise of a particular Delivery Partner
All organisations involved with LLW will retain your personal data in accordance with data protection law and their data retention policies. If you’d like further information about this, please ask your Delivery Partner.
In addition, LLW is legally bound by the retention requirements of the project funder (European Social Fund) to keep relevant data until 2030 in order to demonstrate the success of the project.
All personal data held by DWP or research contractors for the purposes of evaluation will be permanently deleted no more than six months after the research has been completed (i.e. when the final report is published on GOV.UK).
Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK, which can be found here.
5. Sharing your personal information
Your information will primarily be accessible and processed by the Delivery Partner(s) with whom you work, and by Clarion Futures (who have oversight of all LLW participants given their responsibility for managing the project on behalf of the partnership). Delivery Partners will comply with all aspects of data protection law including ensuring that access to such personal information is restricted to authorised individuals on a strictly need to know basis. Additionally, the relationship between the Delivery Partners is administered by appropriate data sharing and confidentiality protocols to further protect your information.
The information you provide to your delivery partner will be shared with the Department for Work & Pensions (DWP) and used to evaluate this project and to report to the Greater London Authority and European Social Fund for monitoring purposes, in line with European Commission regulatory requirements.
Your information will also be shared with research organisations working on behalf of the Department for Work & Pensions who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary and you will be asked to consent before taking part in any research activity you may be contacted about.
The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left. This information may also be shared with research organisations working on behalf of the DWP however individuals will not be identifiable and you will not be contacted about this research.
Data will not be used or shared for any commercial or marketing purposes. Your information will be kept securely and all times, and nobody will have access to it that shouldn’t.
There may be times when relevant information will be shared with third parties in order to offer the services outlined in section two, and where necessary your consent will be sought. However, we may also share data without your consent:
- where there is a legal requirement to do so
- In connection with legal proceedings (or where instructed to do so by Court order)
- to protect the vital interests of an individual (in a life or death situation)
Your personal information will not be passed to external organisations for marketing or sales purposes or for any commercial use without your prior express consent.
There may be occasions where your Delivery Partner may need to process your information outside of the European Economic Area (EEA), for example where they use a computer system that stores data in the USA. Where they do this, all necessary steps will be taken to ensure that your information remains secure. You can ask your Delivery Provider for more information about if and how International Processing arrangements could affect you.
6. Your rights in relation to your Personal Information
The right of access – (Subject Access Request / SAR)Under the data protection law, you have a right to ask what personal information is held about you and to request a copy of your information. SARs should be requested from the Delivery Partner you have been assigned to work with. You should check requirements with your Delivery Partner directly. There is a statutory obligation for partner to respond within one calendar month.
Information about how to ask for a copy of the information DWP holds about you (known as a ‘Right of Access Request’) can be found at: https://www.gov.uk/guidance/request-your-personal-information-from-the-department-for-work-and-pensions
The right to rectification- You can ask your Delivery Partner to rectify your personal data if it is inaccurate or incomplete and to inform any relevant third parties of any changes arising as a result. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure – In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention requirements.
The right to restrict processing - In some circumstances you can ask us to restrict processing, for example
- if you disagree with the accuracy of personal data
- if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
The right to data portability - If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact you Delivery Partner to discuss.
The right to object - You can tell us if you object to our processing of your personal data:
- based on legitimate interests
- for the purpose of direct marketing
Rights in relation to automated decision making and profiling
You can ask us to review any decisions that are determined by automated means. You can also object to our use of your personal data for profiling. As explained earlier, we do not currently undertake this and will advise you if this position changes.
Changes to this Privacy Notice
This privacy notice will be kept under review and updates will be placed on the LLW website. It is recommended that you keep up to date via the website; however any major changes will be brought to your attention.
Further Information and how to make complaint
For further information on how to exercise any of your data rights, to ask about how and why we process your information, or to raise concern or complaint you should contact your Delivery Partner directly. Contact details are available on the LLW website.
Alternatively, you may wish to lodge a complaint with the Information Commissioner (ICO), who is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the data protection law.
Information Commissioner’s Office
Cheshire SK9 5AF
0303 123 1113