Connexions Sandwell Privacy Notice (How we use young person’s information)

The categories of this information that we collect, process, hold and share include:

• First Names(s) and surname
• Date of birth
• Address, including postcode
• Telephone number / email address
• Gender (male or female)
• Ethnicity *
• School / College attended
• GCSE results if appropriate
• Indented destination – what you plan to do when you leave school or college
• Whether you have been submitted to or received offers for college courses, apprenticeships
  or jobs **
• Current destination – what you are doing (for example, in school, college, employed, unemployed)
• Level of support provided by Connexions Sandwell
• Record of all contacts you have had with Connexions Personal Advisers and other council staff
• Parent / carer contact name, if necessary
• Information on your health ***
• Any criminal convictions ***

* We are obliged to record ethnicity information to comply with The Equality Act.

** The Education and Skills Act under section 507B 1996 requires Councils to collection information on what you do when you leave school in order to ensure you are offered appropriate, education and training opportunities.

*** The processing of sensitive personal information is strictly controlled by law.  We will always try to gain your consent to record and share sensitive information, for example, about health or criminal convictions, but there may be times when we are legally required to record and share this information without your consent. Where there are issues in connection with safeguarding, child protection or child exploitation, we are required to share information with other organisations.

Why we collect and use this information

Connexions Sandwell hold information or data about you to help us provide you with the advice, guidance and support you require.  This is for support to progress in education, employment or training or to assist you with other services and support needs.

People who work with you, such as a Connexions Personal Advisers, will use your information to understand your circumstances and provide the best help available. This may involve sharing the information with other organisations. Your information will also be used to produce reports and statistics for the Department for Education.

The lawful basis on which we use this information

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing child and young person’s information are:

The law requires us to provide information about our clients as part of statutory data collections for the purposes of (Article 6 GDPR Lawfulness of Processing);

• processing is necessary for compliance with a legal obligation to which the controller is subject;
• 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;

In accordance with the legal basis of that the legislation and section that requires this is the DfE on statutory basis under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013 and Youth Support Services under section 507B of the Education Act 1996.

In addition, concerning any special category data (Article 9 GDPR Processing of special categories of personal data):

• processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;

Collecting this information

Connexions Sandwell is part of Sandwell Local Authority and this is where we get most of our information from to begin with.  We also get information about you from other organisations we work with, for example schools and training providers.

These organisations are required to give us certain information by law in order to monitor and report outcomes to the DfE (Department For Education)

Any further information kept about you will be information that you have given us when talking to a Connexions Personal Adviser. By talking to a Connexions Personal Adviser and providing them with information in order to provide a service to you, you are consenting to the collection of this information.

In order to comply with the data protection legislation, we will inform you whether you are required to provide certain information to us or if you have a choice in this.

Storing this informationYour information is kept on our secure database called IO and sometimes we may keep paper copies for example action plans. In either case your information is kept securely and only made available to authorised Connexions staff.  They can only access it on a “need to know” basis by using their unique password which they do not share with anyone else.

A Connexions Personal Adviser will agree with you what information is to be recorded after each contact you have with them.

Each time we record information about you, we will apply the following standards:

• We will only record information that is relevant.
• We will only record information and keep this up-to-date and accurate.
• We will record information clearly so that it is easy to understand.
• We will always show where information has come from.
• We will only keep information for as long as is necessary then remove it.

We follow a retention framework policy which determines how long we keep your information.  Any paper copies will be kept on file and destroyed after 12 months.

If you have participated in an Impact activity which is a European funded project then we are required under European law to keep paper records for 10 years.

Who we share this information with

Our policy is to be open with you about how we work with or share information with other organisations.

Sometimes we might need to share information about you if we have concerns about safeguarding, child protection or child exploitation.  Whenever we share information, we have to apply the following standards:

• We only use or pass on information if it is in your interests and relevant.
• We will only record information about you that is given to us by other organisations if it is relevant to our service.

This is not a complete list, but some of the organisations we work with and may share information with include:

• Teams within Sandwell Local Authority to improve outcomes for Children and Young People
• Children’s Trust
• Colleges
• Connexions services in other areas
• Department for Education
• Health Professionals
• Housing
• Jobcentres
• Police
• Schools
• Training Providers
• Youth Offending Service
• Voluntary organisations
• Uniconnect Project  2021/2022

Education and training

We hold information about young people living in our area, including about their education and training history. This is to support the provision of their education up to the age of 20 (and beyond this age for those with a special educational need or disability).  Under parts 1 and 2 of the Education and Skills Act 2008, education institutions and other public bodies (including the Department for Education (DfE), police, probation and health services) may pass information to us to help us to support these provisions.

Why we share this information

We share children and young person’s data with the Department for Education (DfE) on a statutory basis under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013. This data sharing underpins school funding, educational attainment policy and monitoring and enables them to; produce statistics, assess our performance, determine the destinations of young people after they have left school or college and to evaluate Government funded programmes.

We do not share information about children and young people without consent unless the law and our policies allow us to do so.

Data collection requirements

To find out more about the data collection requirements placed on us by the Department for Education (for example; via the school census) go to https://www.gov.uk/education/data-collection-and-censuses-for-schools.

Or please contact our Data Controller Officer on DP_officer@sandwell.gov.uk

The National Pupil Database (NPD)

The NPD is owned and managed by the Department for Education and contains information about pupils in schools in England. It provides invaluable evidence on educational performance to inform independent research, as well as studies commissioned by the Department. It is held in electronic format for statistical purposes. This information is securely collected from a range of sources including schools, local authorities and awarding bodies.

The law requires us to provide information about our pupils to the DfE as part of statutory data collections. Some of this information is then stored in the national pupil database (NPD). The legislation that requires this is the Education (Information About Individual Pupils) (England) Regulations 2013.

To find out more about the pupil information we share with the department, for the purpose of data collections, go to https://www.gov.uk/education/data-collection-and-censuses-for-schools.

To find out more about the NPD, go to https://www.gov.uk/government/publications/national-pupil-database-user-guide-and-supporting-information.

The Department may share information about our pupils from the NPD with third parties who promote the education or well-being of children in England by:

• conducting research or analysis
• producing statistics
• providing information, advice or guidance

The Department has robust processes in place to ensure the confidentiality of our data is maintained and there are stringent controls in place regarding access and use of the data. Decisions on whether DfE releases data to third parties are subject to a strict approval process and based on a detailed assessment of:

• who is requesting the data
• the purpose for which it is required
• the level and sensitivity of data requested: and
• the arrangements in place to store and handle the data

To be granted access to pupil information, organisations must comply with strict terms and conditions covering the confidentiality and handling of the data, security arrangements and retention and use of the data.

For more information about the department’s data sharing process, please visit: https://www.gov.uk/data-protection-how-we-collect-and-share-research-data

For information about which organisations the department has provided pupil information, (and for which project), please visit the following website: https://www.gov.uk/government/publications/national-pupil-database-requests-received

To contact DfE: https://www.gov.uk/contact-dfe

Requesting access to your personal data

Under data protection legislation, you have the right to request access to information we hold about you. To make a request for your personal information, or be given access to your record held, contact our Data Controller Officer on DP_officer@sandwell.gov.uk

You also have the right to:

• object to processing of personal data that is likely to cause, or is causing, damage or distress
• prevent processing for the purpose of direct marketing
• object to decisions being taken by automated means
• in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
• claim compensation for damages caused by a breach of the Data Protection regulations

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

Further information

If you would like further information about this privacy notice, please contact: Ami Crampton on 0121 569 2955 or email ami_crampton@sandwell.gov.uk