Privacy notice - Way Ahead

Way Ahead is an employability service provided by the Wheatley Foundation.

The service supports residents in Glasgow who have previous criminal convictions, have an addiction or who are homeless.

The Wheatley Foundation is the charitable trust set up by the Wheatley Group. It is funded by the Group and its subsidiaries to benefit our customers. Maximising social inclusion, jobs, and training and education outcomes for disadvantaged customers is a key Wheatley Group priority.

Wheatley Foundation will be the "data controllers" of the personal information that you provide to us. This information is required to assess your eligibility for assistance and to help you access specific services, as more fully described in this Privacy Notice.

Our Data Protection Officer is Ranald Brown who can be contacted on wheatleydataprotectionofficer@wheatley-group.com.

What we need
 

When you start working with the Way Ahead service, we will ask you for information about yourself. This information will be used to offer support to you throughout the programme, monitor our jobs and training opportunities and provide evidence of this support to our funders.

We will ask you for the following information:

  • Contact details, for example name, address, email address, contact number
  • Date of birth
  • Employment history
  • Equality information – for example disability, ethnic origin.
  • Health issues
  • Information regarding barriers to employment – convictions, addictions, homelessness or any other barriers you face.

In accordance with European Social Fund Participant Guidance, you will be asked to provide documentation to evidence the following:

  • Date of birth
  • Your address to confirm you live within the Glasgow City Council area
  • Legal right to work in the UK
  • Employment status.

Why we need your personal information – public task
 

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 Way Ahead project – a task carried out in the public interest in a partnership between Wheatley Foundation and Glasgow City Council.

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

We will process your information so we can provide you with the support as part of the Way Ahead service. We will use your information to:

  • Offer you one-to-one mentoring
  • Help you to access specific services
  • Give you support with training and learning based on your needs
  • Support when you are in work

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 Glasgow City Council and European Social Fund. Our funders require this information so they can meet the legal obligations placed on them by the European Commission.

Other uses of your personal information
 

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 Foundation and to participate in evaluations that Wheatley Foundation or its representatives may conduct.

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.

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.

Who we share your personal information with
 

In order to receive the funding for delivering this service, we must share your information with Glasgow City Council, the Scottish Government and European Social Fund. This is to verify that we have worked with you and achieved the service objectives.

Members of staff from the Wise Group have been seconded to Wheatley Group to support the delivery of the service. These staff will have access to your information in order to support you throughout your journey.

As part of Way Ahead service, we may also share your personal information with external organisations who you allow us to contact on your behalf. This may include sending CVs to potential employers or making referrals to other support organisations. This will only be in relation to the Way Ahead service and only carried out with your consent before distributing your personal information.

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 that 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.

How we will communicate with you
 

If you are taking part in Wheatley Works we need to communicate with you. We will ask you what your preferred method of contact is. We will usually contact you by email, in writing or by telephone.

How we protect your personal information
 

Your personal information is stored in our secure offices within our office in Glasgow. We will also store some of your information on our electronic systems and our secure servers which are based in the UK. We will also use the case management system Hanlon which is owned by Glasgow City Council. Way Ahead staff from the Wheatley Group and Wise Group as well as our funders will have access to this information.

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.

How long we keep your personal information
 

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

Your rights
 

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 Glasgow City Council privacy notice for ESF participants you will find a copy via the link below:

https://www.glasgow.gov.uk/index.aspx?articleid=22715

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

Changes to our Privacy Notice
 

Our Privacy Notice is regularly kept up to date and this version was updated on 18 June 2018. The latest full version is always available from our website.