Privacy notice - Changing lives programme

When you start a placement on the Changing Lives Programme we will ask you for information about yourself and your background. This information will be used to offer support to you throughout the programme, monitor our jobs and training opportunities and to make sure you are paid for the work you carry out.

Wheatley Foundation and the Wheatley Group will be "controllers" of the personal information that you provide to us throughout your time on the Changing Lives Programme.

We collect the following personal information about you:

• Your full name (and proof of your identity/photo ID)
• Your date of birth
• Your nationality
• Your contact details (phone, email or correspondence address)
• Your marital status
• National insurance number
• Information about your remuneration, including entitlement to benefits such as, pay, pension and holidays
• Information about your nationality and entitlement to work in the UK
• Other details - next of kin details, your expression of wish, information relating to maternity/paternity leave, if applicable and any information required in terms of the working time directive
• Personal characteristics such as gender, disability status and ethnic group
• Bank details
• Health information
• Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
• Assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence
• Details of your work pattern (days of work and working hours) and attendance at work
• Details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals
• Evidence of your qualifications
• Criminal record history (where relevant)
• The terms and conditions of your employment or engagement with us
• Details of your qualifications, skills, experience and work history, including start and end dates with previous employers and workplaces
• Correspondence with or about you, for example letters or emails to you about a pay rise or, at your request, a letter to your mortgage company confirming your salary.

We collect your personal information from you via a variety of sources, including when you complete one of our forms, for example our Changing Lives application form; when you call, write, email or meet with us.

You will be referred to in Group documents and records that are produced by you and your colleagues in the course of carrying out your duties and the business of the company. You should refer to the Group Data Protection Policy which is available on request.

We may receive information about you from third parties including:

• Your Local Council or benefits office
• Recruitment Agencies
• Your identification documents you have given us
• Background checks conditional for your engagement with us
• PVG/Disclosure/DVLA checks relating to criminal convictions/offences (where relevant)
• Former employers or other individuals whom you have given us permission to contact to provide us with a reference. This data will include:
  • Your work history with them, including your dates you were with them
  • the work tasks you did
  • your level of responsibility
  • job title
  • salary on leaving
  • reason for leaving their workplace and
  • whether they would be happy to have you work for them again
  • [Include any other data that you request in a reference].
• Medical professionals provide us with appropriate health information in order that we can manage any health- related situations that may have an impact on your ability to work with us.
• Details of your qualifications and training from your applicable professional body, if required for your position;
• Police, welfare, trade unions or support organisations dealing with you;
• Councillors, MPs or other representatives acting on your behalf/instruction.

We operate a CCTV system at our office premises and at various locations within the vicinity of our properties for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of our legitimate basis to keep our properties safe and secure. Our CCTV cameras operate continuously and recordings are held for one month.

From time to time we may operate CCTV / sound recording and / or use photography to capture evidence of alleged anti-social behaviour or crime. CCTV may also be used as part of formal investigations into alleged staff conduct issues.

We operate a fob system in some/all of or buildings for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of our legitimate basis to keep our properties safe and secure. Fob records are held for 1 year.

We will keep records to demonstrate that trainees and employees have read important documents or policies produced by the Group. These may include, but are not restricted to, documents or policies relating to legislation, duty of care to staff or customers, health and safety and fulfilment of duties set out in your contract of employment. We may use these records to demonstrate that we have complied with legislation and in our legitimate interest to defend any actions made against us.

We may take photographs and video footage at events we organise or take part in, at our offices and in our communities to use for general marketing and publicity. We may also ask you to take part in case studies to demonstrate the impact of the project. However, photographs of individuals will only be used for those purposes with your consent.

We also take photographs of all staff to be used on ID badges. We do this for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of our legitimate basis to keep our properties safe and secure. Photos and associated ID badges are held for the duration of your employment.

We would not normally require to process information relating to your children, under the age of 16, in the course of your placement unless you provide us with details about them. If we do require to process information relating to your children then we will issue you with a separate privacy notice.

We collect and use the above personal data for:

• The administration of your training agreement
• Payment of salaries
• Recruitment and selection
• Pensions and associated benefits
• Appraisal, disciplinary, training and development
• Membership of professional bodies
• Issue communications to you regarding your placement
• For any other purposes consistent with the proper performance of your training agreement
• To provide references about to you to potential employers on request
• Carry out on-going reviews as part of your training and development.

We are also under a legal obligation to process certain personal information relating to our staff and trainees for the purposes of complying with our legal obligations under UK employment law.

If you do not provide the information we need then you cannot be fulfil your placement with Wheatley Foundation.

We also process your personal information in pursuit of our legitimate interests to:

• Pursue any debts owed to us
• Offer support services to you
• Provide education, employment and training advice and opportunities
• Assist the organisations we work for to carry out audits or  reviews of the services we provide
• Undertake research and statistical analysis to help improve our business processes and the services offered to our customers and staff, as well as to evaluate our performance against other benchmarks.  Where possible, statistical information is anonymised or details will be changed
• Conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback
• Run recruitment and promotion processes
• Maintain accurate and up to date trainee records, contact details, emergency contact details
• Operate and keep a record of disciplinary and grievance processes
• Plan for career development, succession planning and workforce planning
• Operate and keep a record of absence management procedures, to allow workforce management and ensure that trainees are receiving the pay or other benefits to which they are entitled
• Obtain occupational health advice, ensuring that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that trainees are receiving the pay or other benefits to which they are entitled
• Operate and keep a record of other leave you may take including maternity, paternity, adoption, parental and shared parental leave, to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement, and to ensure that trainees are receiving the pay or other benefits to which they are entitled
• Ensure effective general HR and business administration
• Provide references on request for current or past trainees
• Respond to and defend against legal claims
• In the event of a business sale/transfer
• Any regulatory checks and/or statutory check/requirements in relation to your engagement with us.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes.  If you wish to object to any of the above processing, please contact us on InformationRequests@wheatley-group.com If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

We are required to use your personal information relating to your health, racial or ethnic origin for equality monitoring purposes as required by government departments and agencies, the Scottish Housing Regulator and auditors, with other organisations and agencies where we are legally allowed to do so.

We will process such personal information to identify and keep under review the existence or absence of equity of opportunity or treatment between groups of people within the same categories to promote or maintain equality within the Wheatley Group.

Where necessary, we may keep information relating to your health, which could include reasons for absence and GP reports and notes. This information will be used in order to comply with our health and safety and occupational health obligations – to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate. We will also need this data to administer and manage statutory and company sick pay e.g. health insurance or life insurance policies.

Where necessary, we will collect information about your criminal convictions history if it is appropriate given the nature of your role and where we are legally able to do so.  We will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us, or by a third party such as Disclosure Scotland or the Police. This information will be used in order to ascertain your suitability, or ongoing suitability, for employment with us, or where we are required by law to carry out such checks.

We offer a number of additional voluntary services to our staff including staff benefits, occupational health, counselling and physiotherapy.

For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent or use another lawful basis to proceed.

For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about the Data Controller and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.

We may ask you if we can process your personal information for additional purposes.  For example, in order to carry out research and evaluate around the performance of the programme we may ask you to complete questionnaires issued by or on behalf of Wheatley Group, and to participate in evaluations that Wheatley Group or its representatives may conduct.  Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

Throughout the Changing Lives programme you will receive support that is tailored to your needs. In order to establish and monitor the support and your journey throughout your placement, we will use the Outcome Star tool. We will issue a separate privacy notice and seek your consent before using this tool.

We may transfer information about you to other Wheatley Group companies for purposes connected with your employment or the management of the company’s business.

We may disclose to and share personal information about you with third parties for the purposes set out in this notice, or for purposes approved by you, including the following:

• To process your salary payments as set out in your training agreement
• To allow your pension provider to process pension information and handle your pension
• To allow electronic payslips to be produced and issued to you
• If the Group/part of the Group you work for enters into a joint venture with or are sold to another business entity, your information may be disclosed to our new business partners or to the new owners
• With a trade union, if you are a member
• With our professional and legal advisors for the purposes of taking advice
• To record details of your  placement lifecycle
• To achieve your trainee records
• To provide you with an trainee assistance service as part of your reward package
• To issue correspondence to you
• For recruitment purposes
• To instruct sheriff officers.

Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

We may need to share personal information with local authorities, government departments and agencies, with our regulators and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.

We may be required to share personal information with Statutory or Regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Care Commission, Local Authorities, Health and Social Care Partnerships Homelessness services, Health services or care and support organisations that we work with, local authorities, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies. We will only share information on the basis of your consent or in accordance with UK data protection legislation.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

As a Changing Lives trainee we need to communicate with you. This will usually be by email, in writing or by telephone. We are moving many of our services online as this is usually more convenient for you and more efficient for us.

Trainees will receive our newsletters with information about what is going on within the organisation.

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.

If any of your personal information is transferred outwith the European Union or the European Economic Area by any of our contractors we will ensure that there are adequate safeguards in place to protect your personal information in accordance with the General Data Protection Regulations and applicable UK Data Protection Legislation.

We will only keep your personal information for as long as necessary to provide fulfil the terms of our training agreement with you and to safeguard the Wheatley Group in the event of any claims, complaints, litigation, enquiries or investigations during or following the termination of your training agreement. Unless you ask us not to, we will review and where possible delete your personal information where your training agreement has been terminated for 5 years.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods for all information we hold about your tenancy. You can request a copy by contacting us at InformationRequests@wheatley-group.com

We review our data retention periods regularly and will only hold your personal information for as long as is necessary for the relevant activity or as required by law (we may be legally required to hold some types of information) or as set out in your employment contract with us.

You can exercise any of the following rights by writing to us at InformationRequests@wheatley-group.com

Your rights in relation to your personal information are:

• you have a right to request access to the personal information that we hold about you by making a "subject access request"
• if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information
• you have a right to request that we restrict the processing of your personal information for specific purposes
• if you wish us to delete your personal information, you may request that we do so.

Any requests received by Wheatley Group will be considered under applicable UK Data Protection Legislation.  You have a right to raise a complaint at any time with the Information Commissioner's Office at www.ico.org.uk

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal details.

Our privacy notice is regularly kept up to date and this version was updated on 18 June 2018. The latest version is always available on our website.