Privacy

Introduction
Wise Steps is one of several Building Better Opportunities projects funded by the National Lottery Community Fund (NLCF) and the European Social Fund (ESF). NLCF and ESF are investing in local
projects tackling the root causes of poverty, promoting social inclusion and driving local jobs and growth. The European Commission decides how ESF money must be managed, spent and evidenced. The Department for Work and Pensions (DWP) is the ESF Managing Authority in England meaning they are responsible for administering the ESF funds across England.

This privacy notice describes how your personal information is collected and used in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Data Protection Act 2018 (DPA18). This notice does not form part of any contract of employment or another contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably possible.

Who we are
The Wise Group is the lead organisation for the Wise Steps project and we are responsible for the funding received from NLCF and ESF. We also deliver the WiseSteps project along with oursubcontracted delivery partners (project partners). Wise Steps helps people in Tyne and Wear to change their lives through work - we provide people with individualised support to help them take positive steps towards employment.

Personal data
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). For the purposes of GDPR, the DWP is the data controller in respect to information processed which relates to all participation in the European Social Fund. ESF grant beneficiary organisations are data processors in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund. DWP is not the controller for any other / additional data collected by us that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by us.

We will collect other / additional data about you which is specific to the Wise Steps project (as opposed to the ESF programme). The Wise Group is the data controller for additional information that we may need to deliver Wise Steps but are not strictly required for ESF participation. Our subcontracted project partners are data processors. The additional information we collect allows us evidence that that local Building Better Opportunities provision (Wise Steps) is tailored to meet the specific needs and priorities of Tyne and Wear and its residents. It helps us to better understand and assess your circumstances, needs and aspirations, and use this information to agree and deliver the best form of support to help you meet these needs. Specifically the additional information we collect includes:

Whether at the time of enrolment you:

• reside in the 20% most deprived areas in England (we will process this based on a check of your residential postcode against the official Index of Multiple Deprivation);
• are a lone parent (which you can choose not to answer);
• are an unpaid carer or care leaver (which you can choose not to answer);
• your sexual orientation (which you can choose not to
  answer);
• whether you have any addiction issues with drugs or alcohol (which you can choose not to answer).
• Information about your friendships, relationships and other forms of networks as an indicator of social inclusion.
• Assessments on factors related to employment at regular intervals throughout participation.
• Your perception of the support provided to you.

The purposes for which personal data is processed
We use personal information about you to deliver the Wise Steps service and monitor your progress and the project’s success. Specifically we will: assess your eligibility using guidance from NLCF and ESF; conduct risk assessments; assess your personal support needs; develop and agree a tailored action plan and activities to support your progress towards employment; and monitor your progress and achievements.

We may use your personal data to generate statistics or produce case studies to help us evaluate or demonstrate the impact of the Wise Steps project. We may share these statistics and case studies with third parties with an interest in the programme, such as NLCF or the Local Enterprise Partnership. In these cases, we will not disclose your personal information unless you provide us with consent to do
so. We may also use your personal data to share with other Wise Group services and departments that can provide additional support to help you to meet your goals or improve your personal circumstances. The information you provide to Wise Steps will be shared with the DWP and used to evaluate the project and to report to ESF for monitoring purposes, in line with European Commission regulatory requirements. Your information will also be shared with research organisations working on behalf of DWP who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary and you will be asked to consent before taking part in any research activity you may be contacted about. The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left. This information may also be shared with research organisations working on behalf of the DWP however individuals will not be identifiable and you will not be contacted about this
research. Data will not be used or share for any commercial or marketing purposes. At all times your information will be kept securely, and nobody will have access to it that shouldn’t. The lawful grounds for the processing. The ESF Programme Action Note 018/18 sets out the lawful basis for processing personal data under ESF. It states that The DWP ESF Managing Authority processes personal data in the ESF programme under:

• Article 6 (1) (e) of the GDPR: ‘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’.
• Article 9 (2) (b) of the GDPR: ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject’.

The lawful grounds we have for processing your data are:

• Consent – if you agree to the specific data processing activities described above you will be asked to provide your consent in writing. Your consent is freely given, and you are not obliged to provide it for participating in the New Routes programme. New Routes is based on your voluntary participation. You have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Legitimate Interests – We may rely on the Legitimate Interests of the Wise Group (or those of a third party) to use your personal data to inform you of additional support services available to you through the Wise Group to enhance the support provided by New Routes. Legitimate Interest means our interest in conducting and managing our activities and projects to enable us to give you the best service and experience. We consider and examine any potential impact on you and your rights before we process your personal data for our legitimate interests to ensure that those interests do not override your interests and fundamental rights. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

How do we collect this data?
We will collect information from you directly.

How long do we keep your data?
Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK at:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/591617/ESF_Guidance_on_document_retention.pdf.

All personal data held by DWP or research contractors for the purposes of evaluation will be permanently deleted no more than six months after the research has beencompleted (i.e. when the final report is published on GOV.UK). The information we collect will be kept until the completion of the programme and of any legal and audit purposes. More specifically, we will retain your personal data until 31 March 2034 unless otherwise instructed by NLCF, the DWP ESF Managing Authority or the European Commission. Following this period, we completely and irreversibly erase your personal data, unless we are required by law to do otherwise.

Sharing your personal data
We will share your personal data with third parties where required by law, where it is necessary to administer our relationship with you or where we have another relevant, carefully assessed legitimate interest in doing so. We will not disclose your personal information to third parties unless there is a lawful ground for this. We will not share your personal information for marketing purposes unless you consent to this processing. Personal information held by the Wise Group may be shared with other governmental organisations and departments to enable them to exercise their statutory duties as required by law. These third parties include:

• The DWP ESF Managing Authority and NLCF for monitoring, evaluation and audit purposes.
• Potential employers and education or training providers to match you with

Home Energy Advice Team (HEAT) Services Privacy Notice
The Wise Group delivers a range of energy advice and advocacy services aimed at reducing fuel poverty. Our Home Energy Advice Team (HEAT) employs a team of qualified Energy Advisers to provide practical advice about energy efficiency.

Our service aims to: help you use your heating system; help you to use energy more efficiently; identify and address challenges in relation to energy usage and bills; identify and access other financial and non-financial support and access other relevant services.

Who we are
The Wise Group is the data controller. This means that we are responsible for determining the purposes and means of this personal data processing. We need to process information about you to provide energy advice and advocacy support. We will do this in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Data Protection Act 2018 (DPA18).

Personal data
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect and process the following information:

• Your personal details (e.g. name, address, contact details, date of birth).
• Information about personal circumstances including some financial information (e.g. employment status, whether you live in or in fear of fuel poverty, income/expenditure, arrears).
• Information about your household, who lives there and how much energy you use (e.g. property type, occupancy details, heating systems, energy suppliers, meter readings).

Details of the service we provide to you
This can include any financial support, any savings achieved, specific activities undertaken and your perception of the support provided.
We may collect special categories of personal data about you, including information about heath and racial / ethnic origin. We may also collect special categories of personal data about members of your household, including health information. Please note - when we collect information about other people in your household, we will not record any information that could directly identify them.

Purpose of personal data processing
We use personal information to assess whether you are eligible to access our services and deliver the service to you. We may use your personal data to generate statistics and case studies to evaluate the impact of our service, market the service or share with organisations that provide funding for our services. Your personal data will not be disclosed unless you provide us with consent to include identifiable information about you.

In evaluating our services we may contact you to understand your perception of the service, your level of satisfaction and if you benefited from engaging with us. If we do contact you for this purpose, you can refuse to participate in this activity. We may use your personal data to share with other Wise Group services and departments that can provide additional support to help you meet your goals or improve your personal circumstances. We would like to contact you about other services which may be of interest to you in the future. You will be asked for your explicit consent for this and you are under no obligation to agree to this. The lawful grounds for processing your data are:

• Consent – if you agree to the specific data processing activities described above you  will be asked to provide your consent in writing. Your consent is freely given, but we may not be able to deliver the service to you without it. You have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Legitimate Interests – We may rely on the Legitimate Interests of the Wise Group (or those of a third party) to use your personal data to inform you of additional support services available to you through the Wise Group to enhance the support provided to you. Legitimate Interest means our interest in conducting and managing our activities and projects to enable us to give you the best service and experience. We consider and examine any potential impact on you and your rights before we process your personal data for our legitimate interests to ensure that those interests do not override your interests and fundamental rights. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

How do we collect this data?
We collect information directly from you.

How long do we keep your data?

The information collected will be kept until the completion of the programme, and for the duration required for any legal and audit purposes. More specifically, we will retain your data for a period of 7 years from the end of the funding period in order to demonstrate the support provided to you and how the funding has been spent. Following this period, we will completely and irreversibly erase your personal data, unless we are required by law to do otherwise.

Sharing your personal data
We will share your personal data with third parties where required by law, where it is necessary to administer our relationship with you or where we have another relevant, carefully assessed legitimate interest in doing so. Personal information held by the Wise Group may be shared with governmental organisations and departments to enable them to exercise their statutory duties as required by law. We will not disclose your personal information to third parties unless there is a lawful ground for this. We will not share your personal information for marketing purposes unless you consent to this processing. The third parties your information may be shared with include:

• Organisations that provide funding to deliver the service for monitoring and audit purposes.
• Energy suppliers for the purpose of understanding, negotiating or reducing you energy costs.
• Home Energy Scotland to conduct further assessments to maximise your household income and access the financial support you are eligible for and entitled to. This may include a benefit entitlement check with the Department for Work and Pensions.
• Specialist providers who can provide additional support to help you meet your goals or improve your personal circumstances (e.g. housing associations, local authorities, health providers etc.)

Additional Information
For more information about the Wise Group’s commitment to data protection, your rights under data protection law, our fees policy or how to contact our Data Protection Officer please read our Privacy Notice Supporting Information document, available on our website:

https://www.thewisegroup.co.uk/wpcontent/uploads/2019/04/QCS009-PrivacyNotice-Supporting-Information-v1-April2019.pdf.

About this privacy notice
We keep our privacy notices under regular review. This notice was last updated 3 September 2019. This notice does not form part of any contract of employment or another contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably possible. We want to hear from you and keep your data safe, accurate and complete. Please keep us informed about any changes regarding your personal data during your relationship with us.

ReConnect is a rapid access counselling service that ensures people get the support they need, when they need it.

Our counsellors help customers through whatever is affecting their mental health, like depression, anxiety, stress, or addiction.

ReConnect also delivers Cognitive Behavioural Therapy (CBT) group sessions to provide you with a self-care toolkit to minimise escalation of mental ill health, improve wellbeing and reduce the impact of isolation.

The services may be delivered face-to-face, over the phone, or using video/audio conferencing facilities.

Who we are
The Wise Group is the data controller. This means that we are responsible for determining the purposes and means of this personal data processing. We do this in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Data Protection Act 2018 (DPA18).

Personal data
Personal data means any information about an individual from which that person can be identified, does not include data where the identity has been removed (anonymous data). We may collect and process the following information:

• Name and contact details including email address, postal address and telephone number
• Date of birth and age
• Gender
• Other equal opportunities monitoring information including special category data - disability, sexual orientation, religion and ethnicity
• Referral information
• Information regarding counselling appointments
• Information about your mental health and wellbeing
• Counselling notes from any counselling
  sessions undertaken
• Wherever possible we de-personalise our records so you are not directly identifiable

For example, we may assign a reference number or use coded case notes as an added security measure.

Purpose of personal data processing
We use personal information to deliver the ReConnect service to you, including records of your participation and attendance. We may also use it to:

• Communicate with you and provide details of our services
• Arrange, cancel or reschedule appointments or otherwise manage our relationship with you
• Request your participation in surveys,
  case studies, and other evaluation and
  service improvement activities
• Monitor the performance and impact of
  our services
• Monitor diversity and equal opportunities
• Publicise the service
• Report the performance of the service internally and to relevant third parties
• Share with other Wise Group services that can provide additional support to help you meet your goals or improve your personal circumstances
• Flag risks

The lawful grounds for the processing
The lawful grounds for processing your data are:

• Consent – if you agree to the specific data processing activities described above you will be asked to provide your consent in writing. Your consent is freely given, but we may not be able to deliver the service to you without it. You have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Legitimate Interests – We may rely on the Legitimate Interests of the Wise Group (or those of a third party) to use your personal data to inform you of additional support services available to you through the Wise Group to enhance the support provided to you. Legitimate Interest means our interest in conducting and managing our activities and projects to enable us to give you the best service and experience. We consider and examine any potential impact on you and your rights before we process your personal data for our legitimate interests to ensure that those interests do not override your interests and fundamental rights. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

How do we collect this data?
If you are referring yourself to the ReConnect service then we will collect information directly from you. If you have been referred to the service from another source, we may collect basic information such as your name and contact details from the referring organisation.

How long do we keep your data?
The information collected will be kept for the duration required for any legal and audit purposes and in line with our record retention policy. Unless otherwise required we will retain counselling records for 3 years following your last engagement with the service. Following this period, we will completely and irreversibly erase your personal data, unless we are required by law to do otherwise.

Sharing your personal data
We will only share your personal data with third parties where required by law, for safeguarding purposes, to administer our relationship with you or where we have another relevant, carefully assessed legitimate interest in doing so.

Personal information held by the Wise Group may be shared with government organisations and departments to enable them to exercise their statutory duties as required by law.

We will not disclose your personal information to third parties unless there is a lawful reason for doing so. We will not share your personal information for marketing purposes unless you consent to this processing.

We may use reputable third parties to process your information to help us deliver the service to you. We will ensure all data processors have agreements in place to ensure they only process your data on our instruction and in accordance with this privacy notice and the UK’s data protection laws. The third parties your information may be shared with include:

• Organisations that provide funding to deliver the service for monitoring and audit purposes
• Organisations who provide other services that enable us to deliver the service to you such as those who provide survey and audio/video conferencing software
• Other contracted data processors such as external evaluators

In exceptional circumstances (such as where your counsellor believes that someone may come to harm) we may have to share information with the relevant authorities or an emergency contact you have provided.

From time to time we may provide you with links to other websites. These websites are not under our control and as a result, we will not be liable to you for any issues arising in connection with their use of your personal data, the website content or the services offered to you. You should exercise caution and look at the privacy statement applicable to the website in question.

Additional Information
For more information about the Wise Group’s commitment to data protection, your rights under data protection law, our fees policy or how to contact our Data Protection Officer please read our Privacy Notice Supporting Information document, available on our website: www.thewisegroup.co.uk/privacy/

About this privacy notice
We keep our privacy notices under regular review. This notice was last updated 29 May 2020.

This notice does not form part of any contract of employment or another contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably possible.

We want to hear from you and keep your data safe, accurate and complete. Please keep us informed about any changes regarding your personal data during your relationship with us.