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Employer privacy notice

Careers Wales and Working with Employers

Introduction

Welcome to CAREER CHOICES DEWIS GYRFA LTD's privacy policy.

CAREER CHOICES DEWIS GYRFA LTD respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how CAREER CHOICES DEWIS GYRFA LTD uses personal data when working with / engaging with employers (Employer Engagement Programme).

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

CAREER CHOICES DEWIS GYRFA LTD (Careers Wales) is the controller and responsible for your personal data (collectively referred to as "Careers Wales", "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (see below for details), please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: CAREER CHOICES DEWIS GYRFA LTD (company number: 07442837)

Email address: personal.data@careerswales.gov.wales

Postal address: Unit 4, Churchill House, 17 Churchill Way, Cardiff, CF10 2HH

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or personal information, 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title, gender and job title
  • Contact Data includes work address, email address and telephone numbers
  • Preferences Data includes any preferences that you may have indicated as to how you wish to work with us / schools and colleges and the areas in which you are happy to volunteer
  • Transaction Data includes details of your engagements with us / through us (for example details of any mentoring session you may have provided to a school)
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Transaction Data to calculate the percentage of employers who engage with us / schools and colleges in a particular way. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data and you fail to provide that data when requested, we may not be able to work with you. We will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Preferences, & Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign up to the Employer Engagement Programme and when you give us feedback or contact us
  • Automated technologies or interactions. As you interact with our websites, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policies (available on our websites) for further details
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Your employer (for example, where you are nominated by your employer as the point of contact)
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register

 4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for the performance of a task carried out in the public interest or in the exercise of the official authority of Careers Wales (Public Task)
  • Where we need to comply with a legal obligation (Legal Obligation)

Generally, we do not rely on consent as a legal basis for processing your personal data although where required by law we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Table displaying the ways we plan to use your personal data
Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you / the organisation that you work for as a new “employer”
  1. Identity
  2. Contact
  3. Preferences
  4. Marketing and Communications
  • Public Task
  • Legal Obligation

To work with you under the Employer Engagement Programme which will include:

  • Notifying you of events / opportunities that may be of interest to you
  • Facilitating a mentoring opportunity at a school / college and / or facilitating your attendance at a careers fayre etc
  1. Identity
  2. Contact
  3. Preferences
  4. Transaction
  5. Marketing and Communications
  • Public Task
  • Legal Obligation

To manage our relationship with you which will include:

  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Preferences
  4. Transaction
  5. Marketing and Communications
  • Public Task
  • Legal Obligation
To manage and protect our business which will include monitoring and assuring quality of provision, financial reporting, resolving disputes etc
  1. Identity
  2. Contact
  3. Preferences
  4. Transaction
  5. Marketing and Communications
  • Public Task
  • Legal Obligation

 

To carry out research and write reports that are of public interest
  1. Identity
  2. Contact
  3. Preferences
  4. Transaction
  5. Marketing and Communications
  • Public Task
  • Legal Obligation

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table at section 4 above:

  • Schools and colleges who are seeking employer engagement
  • Welsh Government and other public bodies involved in education, careers, training and employment services
  • Service providers who provide services to us such as IT and business support services
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, accounting and audit services
  • Ofsted
  • HM Revenue & Customs, regulators and other authorities
  • Marketing and market research agencies
  • Researchers, research agencies and academic institutions
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We do not allow our third-party service providers (who are acting as our data processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We store and therefore process your personal data in the United Kingdom and European Economic Area (EEA). Generally, we do not transfer your personal data outside the United Kingdom / EEA area. However, we may transfer your data outside the United Kingdom / EEA area where this is allowed by applicable data protection legislation. You can find out more about this by contacting our data privacy team.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. Our employees will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  Under certain circumstances you have the right to:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

 If you wish to exercise any of the rights set out above, please contact our DPO using the contact details set out above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

August 2019