Privacy notice - Wheatley Works

Wheatley Works - Privacy Notice

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.

To support this, the Foundation has developed the Wheatley Works programme to help prepare customers for training, work experience and job opportunities arising from a range of employability activities. Wheatley Works brings together all of our jobs and training programmes while putting in place pre-training programmes to ensure our customers are best placed to take the opportunities that the group and our partners have available.

Our Wheatley Works teams work with delivery partners based in our communities. They will both support residents to take part in training courses, secure employment, start up in business and regain the confidence that their future can be positive. Where we make referrals to any of the delivery partners , we will ask your consent and they will provide you with another privacy notice.

Wheatley Foundation and our delivery partners will be the "data controllers" of the personal information that you provide to us. This information is required to manage your Wheatley Works referral, 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 apply for assistance from the Wheatley Works employability and training programme, we will ask you for the following personal information:

  • Contact details – name, address, email address and telephone number;
  • Date of birth;
  • National Insurance number;
  • Employment history;
  • Financial circumstances;
  • Health issues;
  • Education, skills and training history; and
  • Equalities information.

We will ask you for this information to provide you with support throughout the programme and to monitor the jobs and training opportunities we provide.

Why we need your personal information
We will process your personal information through our legitimate interest to help our customers get into employment or training by supporting you through Wheatley Works. We will also ask you for you explicit consent to collect special categories of data. We will register you with Wheatley Works with your consent and provide you with support to access training and employment opportunities.

We will use your personal information to:

  • Assess your eligibility for the Wheatley Works scheme;
  • Identify existing skills, skills gaps and barriers to employment;
  • Identify any support requirements;
  • Arrange training and employment; and
  • Monitor your progress e.g. CV completion, training completed.

We collect your personal information from you via a variety of sources, including when you apply for one of our services, complete one of our forms, when you call, write, e-mail or meet with us or respond to a survey. We may collect information when you use our social media sites or websites.

Our landline phone calls to our Customer Service Centre are recorded for training and monitoring purposes and our recordings are usually held for a period of six months.

Other uses of your personal information

We may ask you if we can process your personal information for additional purposes.  For example, to promote the services provided through Wheatley Works or to report on the successes of the programme.  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.

Furthermore, in order to carry out research and evaluation 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 it’s 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

We may also share personal information with our partner agencies who provide the Wheatley Works training and employability programmes on behalf of the Foundation.

Wheatley Foundation employs third party suppliers to provide services, including our case management system AdvicePro.  These suppliers may process personal information on our behalf as "processors" and are subject to written contractual conditions to only process that personal information under our instructions and protect it.

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.

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.

We may be required to share personal information with Statutory or Regulatory authorities and organisations to comply with statutory obligations.   We will only share information on the basis of your consent or in accordance with UK data protection legislation.

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. We are moving many of our services on-line as this is usually more convenient for you and more efficient for us.

Our case management system Advice Pro allows us to share documents with you and send texts via the secure Advice Pro hub. You will be able to log on here to see any documents or messages that have been sent to you and you can send documents and messages back to your advisor. Only you and your advisor will be able to access this.

How we protect your personal information

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you. 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.

How long we keep your personal information

We will only keep your personal information for as long as necessary to manage your case, administer the Wheatley Works programme and safeguard the Foundation in the event of any claims, complaints, litigation, enquiries or investigations.  Unless you ask us not to, we will review and where possible delete your personal information 5 years after the end date of your engagement with Wheatley Works.

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 writing to us at Wheatley Foundation, 25 Cochrane Street, Glasgow, G1 1HL or by e-mailing foundation@wheatley-group.com

Your rights

You can exercise any of the following rights by writing to us at Wheatley Foundation, 25 Cochrane Street, Glasgow, G1 1HL or by e-mailing 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 the 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

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 1st August 2021. The latest full version will be available from our website at https://www.wheatley-group.com/better-lives/wheatley-foundation