Privacy notice - My Money service

When you start working with the My Money service we will ask you for information about yourself and your background. In accordance with European Social Fund Participant Guidance, you will be asked to provide documentation to evidence the following:

• legal right to reside in the UK
• employment status
• education status
• housing status
• equality information – for example, disability, ethnic origin.
• documentation to verify your contact details - for example name, address, email address, date of birth, National Insurance number
• in work poverty – Bank statement or award letter detailing in-work benefits, for example Working Tax Credits, Income support (if less than 16 hours a week), Child Benefit, Housing Benefit.
• lone parent – Award letter detailing benefits, for example Child Benefit, Housing Benefit, Council Tax Reduction.

The legal basis which allows for processing of your personal data is Article 6(1) (e) public task as the processing is necessary for implementation of the My Money project – a task carried out in the public interest in a partnership between Wheatley Group, The National Lottery Community Fund and The European Social Fund.

The Wheatley Foundation secured funding through the European Social Fund programme to deliver this service. The Scottish Government is the Managing Authority of this funding stream.

We will use your information to:

• offer support and advice
• help you to access specific services
• help you increase your money management skills
• reducing debt as a barrier to social inclusion.

We need your personal information to allow us to assess the evidence of your eligibility on the programme, progression and results/outcomes and analysis for programmes funded by European Social Fund and The National Lottery Community Fund. Our funders require this information so they can meet the legal obligations placed on them by the European Commission.

We may ask you if we can process your personal information for additional purposes. For example, in order to evaluate 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.

In order to deliver the services outlined in this notice, the Wheatley Foundation works with 15 partners. Relevant information regarding yourself, and relating only to your participation in the My Money service, with your consent, will be passed to appropriate delivery partners. They will use this information and work with you with the sole objective of increasing your money management skills or reducing debt as a barrier to social inclusion.

The list of delivery partners are as follows:

• Money Matters
• GEMAP Scotland
• General Citizens Advice Bureau
• Ethnic Minorities Law Centre
• Legal Services Agency
• Govan Law Centre
• Castlemilk Law & Money Advice Centre
• Wise Group
• SWAMP
• Move On
• Impact Arts
• Glasgow Life
• Volunteer Glasgow
• One Parent Families Scotland
• CAD.

In order to receive the funding for delivering this service, we must share your information with The National Lottery Community Fund, the Scottish Government and European Social Fund. This is to verify that we have worked with you and achieved the service objectives. Your information will only be shared with the above funders for the purpose of the My Money Programme.

We may also share personal information with our professional and legal advisors for the purposes of taking advice.

Wheatley Foundation employs third party suppliers to provide services, for example IT. These suppliers may process personal information on our behalf as "processors" but are subject to written contractual conditions and will only process personal information upon instruction. All information will be stored in accordance with strict ESF requirements.

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

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 regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.

Your personal information is stored on our CRMS (electronic filing system) called FORT which may be copied for testing, backup, archiving and disaster recovery purposes. This is only accessible by employees, approved delivery partners and The National Lottery Community Fund for the purposes of the My Money programme. All data is held within the UK.

If any of your personal information is transferred out with 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 is necessary to provide you with services and to meet the requirements of our funders. We are required to keep your information until 31 December 2023. This is a legal requirement in line with ESF Document Retention Guidance.

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 and you can request a copy by contacting us at 0141 274 8514 or foundation@wheatley-group.com

You can exercise any of the following rights by writing to us at 25 Cochrane Street, Glasgow, G1 1HL or foundation@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; and
• if you wish us to delete your personal information, you may request that we do so.

Any requests received by Wheatley Foundation will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.ico.org.uk

If you would like to see a copy of the Scottish Government privacy notice for ESF participants please click on the link.

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 information.

Our Privacy Notice is regularly kept up to date and this version was updated on 26 October 2018. The latest full version is always available from our website.