This page sets out our privacy notice concerning Working Wales customers' data and how we process it. It explains how we comply with General Data Protection Regulation (GDPR) regulations.
In accordance with General Data Protection Regulation (GDPR) which came into force on 25 May 2018, this notice sets out how Careers Wales manages and shares the information we collect while you are a participant of the Working Wales programme. The information in this notice will be kept under review to incorporate any further changes communicated by the Information Commissioner’s Office (ICO)and updated versions will be available on our website careerswales.gov.wales.
In order to deliver our statutory function of the provision of careers advice and guidance to adults over the age of 16 on the Working Wales suite of programmes, it is necessary for Careers Wales to collect and use (or ‘process’) personal data. The purpose of this notice is to allow us to be open, honest, and upfront about the purpose of why we collect your personal data, and also to identify the sources and type of data we receive from other organisations and how we share the data we hold. This will provide confidence that the personal data we hold is being used in the right way and your privacy is protected.
Data Controller
Career Choices Dewis Gyrfa Ltd trading as Careers Wales is the data controller for the personal data we process. We are registered as a data controller with the Information Commissioner’s Office (ICO), registration number: Z276256.
Purpose
The purpose of this privacy notice is to provide information about how we use, collect and share the data that we hold as a company. This notice covers the following areas:
1. Why we process the personal data
The purpose of processing personal data is to provide careers advice and guidance to young people and adults who access the Working Wales Service.
Background to Working Wales
Working Wales is a Welsh Government-funded service designed to provide streamlined and efficient employability support that is responsive to an individual’s needs. We provide a wide range of support including accessing training, upskilling, funding, and help with CV writing and interview techniques.
The service acts as a free gateway into tailored employment support that is available to anyone aged 16 or above and living in Wales. In addition to providing direct impartial careers support and guidance, Working Wales careers advisers can identify an individual’s needs and refer them to other suitable services and programmes, given their extensive knowledge of local and national support offers. As a result, the Working Wales service is able to extend the reach of careers support services into communities and to help people across a wider range of needs and labour market positions.
The service enables individuals through a needs-based assessment to talk to accredited careers advisers about employment and skills, their aims and aspirations, and any challenges that they face in obtaining and maintaining work, education or training or advancing their career.
Employability support is delivered by Working Wales employability coaches, assisting customers with job searches, applications, and interview preparation.
The Welsh Government’s Young Person’s Guarantee provides everyone aged between 16 and 24 in Wales with the offer of support to gain a place in education, training, or an apprenticeship, find a job or become self-employed.
Our service offering consists of the following programmes:
- Jobs Growth Wales+
- Personal Learning Accounts
- React+
- Communities for Work Plus
2. Our lawful basis for processing personal data
Public Task, Article 6(1) (e) 9(2)(a) and 9(2)(j) – 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. We receive Article 10 using the consent model.
Necessary for reasons of substantial public interest, Article 9(2)(g)
Schedule 1, Part 2, Para 6 Statutory etc and government purposes
This Condition is met if the processing:
- Is necessary for a purpose listed in sub-paragraph (2)
- Is necessary for reasons of substantial public interest
Those purposes are:
- The exercise of a function conferred on a person by an enactment or rule of law
- The exercise of a function of the Crown, a Minister of the Crown or a government department
The following legislation provides the powers allowing Careers Wales to undertake the Working Wales provision:
- CCDG’s Term of Government remit letter, underpinned by CCDG’s Articles of Association and Framework Document
- Under section 14 of the Education Act 2002, Welsh Ministers may give, or make arrangements for the giving of, financial assistance to any person in connection with the provision of education (which includes the preparation of young people for employment in general)
- Section 10 of the Education Act 1996
- Section 14 of the Education Act 2002
- Sections 31-35 of the Learning and Skills Act 2000
- Section 2 of the Employment and Training Act 1973
- Sections 60, 61, 70 and 71 of the Government of Wales Act 2006
3. Who and where we get the personal data from
We may receive personal information from the following organisations, this is not an exhaustive list:
- DWP – Jobs Growth Wales+ starters
- DWP Data on universal credit claimants aged 16-24 for the Young Person’s Guarantee
- Probationary Service – make referrals to working Wales
- Welsh Government
- Training Providers
- Local Authority
- Third Sector providers of employment services
- Prison Service
- Youth services
- Further Education
4. The Categories of personal data we process
We process the following categories of data relating to the Working Wales Programmes:
- Identity Data includes first name, last name, title, date of birth, gender, national insurance number, proof of identity information such as driving licence, passport
- Contact Data includes home address, temporary contact address, email address and telephone numbers
- Education and Career Data includes details about your status (for example whether you are at school, college or in employment or looking for employment and whether you are at risk of becoming NEET (not in employment, education or training)), details of the school or college that you attend / have attended, details of any employer you may have, details of any qualifications that you may have or that you are working towards, redundancy information. Barriers preventing you from entering into employment
- Funding Data includes details of any other funding or assistance that you may have received such as any work placement schemes that you have participated in and / or any benefits that you have receive
- Special Category Data includes details of your race or ethnicity, details about any religion you may have, information about any special educational needs that you may have, information about any disability you may have, information about any criminal convictions or offences you may have
5. Who we share personal data with
We share personal data with a number of key organisations to fulfil our statutory functions. It should be noted that not all the personal data outlined above is shared with every organisation. Only relevant information is shared in relation to the purpose.
ReAct+
ReAct+ offers tailored support to those trying to re-enter the labour market by removing barriers and providing grant support for vocational training, travel costs and care (including childcare) related to training. This is a voluntary program and customers cannot be mandated to participate. This is an interaction between the customer and Welsh Government, and Welsh Government is therefore the controller of the information.
If a customer is assessed as being eligible and suitable to apply for a ReAct+ grant, Careers Wales (and Working Wales) will act as a facilitator to share data on behalf of the customer either via the portal or via Objective Connect, but this is always done with customer consent.
Careers Wales may receive information back from Welsh Government to support customer applications for ReAct+ funding. Careers Wales will become the controller of this data.
Fields shared between Careers Wales and Welsh Government may include:
- Name
- React Number
- Whether the grant has been successful
- Amount of grant award
- Date of approval
- Course and provider details
Jobs Growth Wales+
Jobs Growth Wales+ is for young people aged 16-19 in Wales. It is a programme that gives you the skills you need to get a job or progress to further learning in the future. You will be paid an allowance on Jobs Growth Wales+ Engagement and Advancement, and a wage if you are on Jobs Growth Wales+ Employment.
Following meetings with the Careers adviser, the adviser will complete an Assessment Referral Report. This is an outcome of the guidance process, health related issues, barriers and schemes you apply for. This is then sent to a prime training provider on the Jobs Growth Wales provider list:
- Act
- Coleg Cambria
- Grwp LLandrillo Menai
- ITEC
- Pembrokeshire College
Information shared following consent of the individual with the training provider:
- Title
- Surname
- Forename(s)
- Address
- Postcode
- Home Telephone Number
- Mobile Telephone Number
- E-mail Address
- Date of Birth
- National Insurance Number
- Next of Kin
- Next of Kin Contact Number
- Gender
- Ethnicity
- Nationality
- Preferred Language of communication
- Current Status - Please note that JGW+ participants cannot be in Education, Employment over 15 hours per week or Training at the point of starting the programme
- Background, employment information
- Career aspirations
- Education, qualifications
- Barriers faced by the customer
HM Prison and Probation Service in Wales
We work in partnership with the Prisons and Probation Service to ensure offenders can:
- Improve their knowledge and awareness of learning opportunities and of the labour market
- Have any barriers to employment, education or training identified and removed
- Make informed decisions about their future employment choices
- Apply career management and employability skills to enable them to gain and sustain employment, education or training
Each prison has a dedicated careers advisor who provides careers advice and guidance within the prison. A member of the prison staff refers an individual who has requested our services to our careers service. We share details of the interaction with the prison team. This may include career plans and potentially any safeguarding issues. The individual is made aware of the sharing of this data. We may also contact the probation office if the individual consents to us providing further employability support when they have left the prison estate.
Probation Service
We receive referrals from the Probation service. Prior to referring, the individual’s give their consent for the probation service to share information relating to their offending, risk and personal information for the purpose of helping them with employment, training and education. They also give consent for Careers Wales to share information back to the Probation Service. This will include:
- Name
- Date of Interview
- Attendance
- Outcome of Interview
- Whether a follow-up interview has been arranged
- Outcome (i.e. Employment, Education, Voluntary Work etc.)
There is a data sharing agreement in place between the Probation service and Careers Wales covering the sharing of the data.
Where a customer self refers and is on probation, we will ask consent to discuss their details with their probation officer. If a safeguarding issue is raised, although we will endeavour to seek their consent, there may be occasions where we will seek advice from the probation service without their consent where appropriate.
Referrals to Employability Programmes
We refer to communities for work plus or a triage body, who will determine the best provision - upon consent of the individual. They provide a community-based employability support package to those aged 20 and above. This intensive mentoring programme helps those most disadvantaged in the labour market to overcome barriers to become more employable.
An assigned mentor will provide individuals with a tailored support package, addressing issues and barriers to help find sustainable employment. We may also refer to other employability providers with the consent of the individual.
Data Shared:
- Title
- Surname
- Forename(s)
- Address
- Postcode
- Mobile Telephone Number
- E-mail Address
- Date of Birth
- National Insurance Number
- Employment Status
- Customer career aspirations
- Employment history
- Any support needs
Job Centre Plus Referrals
We work closely with the Job centre to help people find the most suitable job opportunities for individuals referred to us. When liaising with the job centre we will share the following information:
- Existing skills (linked to previous employment/ training)
- Skills gaps linked to career aspirations
- Barriers Identified (e.g. finance, literacy, numeracy, single parent, digital exclusion, transport, homelessness, substance misuse etc.)
- Actions needed to address barriers
Research and Evaluation
For Research and evaluation and auditing purposes, we will only provide data for a specific purpose and for a limited time period, after which the organisation must confirm that it has been destroyed. For research purposes wider than education, we will use techniques that ensure the data are anonymised before any research takes place. Sharing of anonymised data is outside of the GDPR.
6. How Do We Keep Your Personal Data Safe?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those of our employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. How long do we keep your personal data for?
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting our data privacy team using the contact details set out below. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes or for reporting information to our funders in which case we may use this information indefinitely without further notice to you.
8. Individual rights
Under GDPR, you have the following rights in relation to the personal information you provide. Specifically you have the right:
- To access a copy of your own data
- For us to rectify inaccuracies in that data
- To object to or restrict processing (in certain circumstances)
- For your data to be ‘erased’ (in certain circumstances)
- To lodge a complaint with the Information Commissioner’s Office (ICO) who is our independent regulator for data protection
The contact details for the Information Commissioner’s Office are Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Phone: 01625 545 745 or 0303 123 1113. www.ico.gov.uk
9. Further Information
Careers Wales Data Protection Officer can be contacted in relation to data protection matters, by post at: Unit 4 Churchill House, 17 Churchill Way, Cardiff, CF10 2HH, or Email: personal.data@careerswales.gov.wales.