Restart Privacy Notice

How we use your information

Ingeus UK Limited is committed to protecting your privacy. This document describes how we process your personal information in accordance with the General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.  It also contains important information about your rights and how to contact us. Further information is available on the Privacy section of the Ingeus UK website (www.ingeus.com/uk/privacy).  

Who are we? 

Ingeus UK Ltd has been commissioned by the Department for Work and Pensions (DWP) to provide the Restart programme in the Greater Manchester and Central and West London regions. Ingeus and our Delivery Partners (B2W (Back 2 Work), Bolton Council, Oldham Council, Rochdale Council, The Growth Company, Seetec Pluss and Wellfair2Work Limited T/A Get Set UK, with whom Ingeus has legal agreements), collect and use information obtained from you, DWP and Jobcentre Plus (JCP) in order to deliver the Restart programme. 

Restart supports individuals to find employment and remain in work, by providing an individual tailored package of support based on an individual’s skills, experience and needs. Through assessment, action planning and working in partnership with specialist partner organisations we aim to develop skills and build confidence to support your journey into work. 

• Ingeus and the DWP are joint Data Controllers for the processing of personal data in relation to the Restart services. 

How do we use your information?

All organisations must have a valid, lawful reason to process your information. Ingeus UK and its Delivery Partners will only collect and use your information for the lawful purposes of administering the services that we are contracted to deliver on behalf of DWP. 

We will collect information about you initially from DWP and yourself. The information we collect includes your name, address, National Insurance Number and any other information relevant to the aims of the programme, to provide you with a service. We ask you for information about you so that we can support you, and to identify services which we feel could benefit you on the programme.

Your information may also be used for:

• Performance monitoring and analysis to help us assess the quality and standard of our services
• Conducting investigations in response to a complaint or enquiry
• Accounting and record keeping e.g. keeping accounts related to business activities and financial management
• Research and evaluation such as participating in feedback surveys
• Referring you to partner organizations who provide specialist support, training or other services that will benefit you to gain employment as part of  the action plan we will develop with you  

Research and evaluation

In order to ensure that we provide you with the best possible service, we may from time to time conduct research and evaluation. Sometimes we will do this by aggregating and anonymising the data, which means that no one can identify you. On occasion we may ask you to take part in a new piece of research and provide additional information or share your information with a third party for the purpose of research, this will only ever be done with your knowledge and consent. Additionally, DWP/JCP have engaged a third party organisation to assess the satisfaction of participants on the Restart programme.  You have the right to opt out of research and survey activities.

Sharing your Personal Information 

When required to do so, we may share your information with DWP, JCP, your Local Authority, as per contractual obligations and in accordance with the GDPR. 
• Where applicable, we may contact your employer to verify your employment information and share employment details with DWP (see Annex A) 
• With your consent, we may share information with other services which we identify as being beneficial to you
• When necessary, for example, in the unlikely event for emergencies or safeguarding concerns, it may be in your vital interest to share your information with your GP, other Health Professionals or refer to external services that will provide help.

We will not share your information with others unless required to do so by law and unless we obtain your consent.

We do not transfer your personal information outside the EEA. 
How long will we keep your personal information?

Ingeus UK have defined retention periods for the information we hold and we will not keep your personal information any longer than we are legally and contractually required to do so.  Once we are no longer required to keep your information, it will be securely destroyed, in accordance with destruction guidelines.  

How the law protects you

The law protecting your personal information is the General Data Protection Regulation (GDPR).  As custodians of your personal information, Ingeus UK are committed to ensuring that your personal data is processed lawfully and respectfully, and by ensuring that we are compliant with the GDPR.

In accordance with the GDPR, Ingeus UK and its partners must have a valid lawful reason to process your information. If you want to know what the legal basis is for processing your information, please visit: www.ingeus.com/uk/privacy where you can find additional information. 

Consent 

Where we need your agreement to process your information, for example, by passing your contact details to someone offering a specific service, we will ask for your consent, and will clearly state why your information is needed and who we will share your information with.  If you agree to your information being shared, we will record your consent on your record.  We will regularly review consents to make sure that the relationships, and purposes for processing, have not changed. 

Right to Withdraw Consent

Where you have provided consent for us to share your information with a specific organisation or individual, you have the right to withdraw your consent at any time. Should you wish to withdraw your consent, please tell your key worker, or, send a written request to the Data Protection Officer (address below), who will process your request. 

Keeping your information safe

We are committed to taking all reasonable measures to ensure we maintain the confidentiality and security of personal data for which we are responsible, whether electronically or on paper. Our staff are required to undertake data protection training and are subject to the Common Law Duty of Confidence which requires us to protect your information, inform you of how your information will be used, and to allow you in most cases to decide if and how your information can be shared. 

Your rights in connection with Personal Information

You have a number of rights with regard to your personal data, including the right to: 
• be informed of why and how we process your data 
• request a copy of the information we hold on you
• have any incorrect information updated and put right 
• deletion of information, once we have no legal right to hold it 
• restrict processing in certain circumstances
• object to unwarranted processing 

Information Requests 

If you have any questions in relation to your rights, or if you would like to receive a copy of your records, correct or request erasure of your personal information, or object to the processing of your personal data, please contact the Data Protection Officer. 

To make a request: 

• You can tell your Restart Advisor who will start the process for you
• You can send your request in writing to: The Data Protection Officer, Ingeus UK Ltd, Fifth Floor, 18 Mansell Street, London, E1 8AA 
• You can email DataProtectionOfficer@ingeus.co.uk

Please note: Your request will need to include sufficient information to enable us to correctly identify your records (e.g. full name, address, date of birth and NI number if known).

Complaints and Disputes

If you raise a query or complaint in relation to your data rights we will endeavour to respond as soon as possible. Requests for a copy of your information will be responded to within a one month period. If you are not satisfied with how we have handled your complaint or request for information you have the right to complain to the Data Protection Officer. If you are still not satisfied with how Ingeus is processing your information, you can write to the Information Commissioner’s Office at:

• Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
www.ico.org.uk

Review of this privacy notice

We review this Privacy Notice to ensure we keep you up to date about what we are doing with your personal information and any changes in processing. This privacy notice was last updated on 26th May 2021.