Privacy Policy

Protecting your privacy

Routes to Work South

1.Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here but we want you to be fully informed about your rights, and how Routes to Work South uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

When you are using the Routes to Work South website, Routes to Work South is the data controller.

2. Who is Routes to Work South?

Routes to Work South is a registered charity and Limited Company supporting South Lanarkshire’s unemployed into further education, training and/or sustainable employment. With a commitment to supporting the community and promoting local economic growth.

3. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you register with RTWS to receive our services

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if you register with us to access our services.

Public Task

Your personal data will only be processed if it is necessary for Routes to Work South to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.

For example, if you register with us and will receive services provided by our funders

Legal obligation

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Routes to Work South to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use demographic information to inform our service delivery or contact you to let you know about new services.

We will also use your address, email and telephone details to send you direct information by post, email and web text telling you about our services.

4. When do we collect your personal data?

• When you visit any of our website to seek further information regarding training or advertised jobs
• When you register with us and fill in any forms.
• When you engage with us on social media.
• When you join a Routes to Work South programme
• When you contact us by any means with queries, complaints etc.
• When you book any kind of appointment with us or book to attend an event
• When you choose to complete any surveys we send you.
• When you comment on or review our services e.g. when you complete a satisfaction survey
• When you’ve given a third party permission to share with us the information they hold about you.

5. What sort of personal data do we collect?

• If you use our website to apply for a job: your name, telephone number and email address.
• If you join one of our programmes: your name, address, telephone number, email address, work history, barriers to employment.
• Details of your interactions with us through contact with staff.

For example, we collect notes from our conversations with you, details of any complaints or comments you make.

• Copies of documents you provide to prove your identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
• Personal details which help us to recommend training or job opportunities
• Your image may be recorded on CCTV when you visit our premises

For example, you might tell us your job aspirations, which we’ll use to help source suitable training and/or vacancies.

We’ll only ask for and use your personal data collected for the purposes stated. Of course, it’s always your choice whether you share such details with us or if you wish to withdraw your consent to use your personal data.
• Your comments and reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

6. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to source appropriate training and job vacancies that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

• To access our services. If we don’t collect your personal data during registration, we won’t be able to process your details and comply with our legal obligations.

For example, your details may need to be passed to a third party to supply or deliver a service and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations.

• To respond to your queries and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business. This includes using your personal data to maintain, update and safeguard your details. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website. We’ll do all of this as part of our legitimate interest.
• With your consent, we will use your personal data and preferences to keep you informed by email, web, text and telephone about relevant training and job opportunities.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
• To send you relevant, personalised communications by post in relation to training and job opportunities. We’ll do this on the basis of our legitimate business interest.
• You are free to opt out of hearing from us by post at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our premises and car parks which record images for security. We do this on the basis of our legitimate business interests.
• If we discover any criminal activity or alleged criminal activity through our use of CCTV, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law.

• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account

• To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from third parties and data from publicly-available lists as we have described in the section What Sort of Personal Data do we collect? We’ll do this on the basis of our legitimate business interest.

For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customers’ histories to identify trends and requirements in the community. This may then guide which services we provide and in which areas.

To process your booking/appointment requests (such as with a training provider or prospective employer).

Sometimes, we’ll need to share your details with a third party who is providing a service (such as training). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.

7. Combining your data for personalised direct marketing

We want to offer you services that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered as described above, for example your training history. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as our funders.

8. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

9. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:
Registration Forms
When you register with us, we’ll keep the personal data you give us according to our contractual and funding requirements so we can comply with our legal and contractual obligations.
Inactive Customers
If you’ve not been in contact with us or used our services, your data will be flagged as inactive and we will periodically contact you to ask whether you want to keep your data active.

10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, training providers, prospective employers and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Training Providers who provide training opportunities
• Employers who supply vacancies

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party to access funding.

For example, if you register with us to receive services provided by our funders you are consenting to your information being shared with that third party.

• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
• For further information please contact our Data Protection Officer.

To help personalise your journey through Partnership websites we currently use the following companies who will process your personal data as part of their contracts with us:

• South Lanarkshire Council
• Department of Work and Pensions
• Jobcentre Plus
• Skills Development Scotland
• The Wise Group
• Remploy
• Facebook

11. What are your rights over your personal data?

An overview of your different rights

You have the right to request:
• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You can contact us to request to exercise these rights at any time as follows:

To ask for your information please contact the Data Protection Officer, Routes to Work South, 1-15 Main Street, Cambuslang Glasgow G72 7EX or email info@rtws.org.   To ask for your information to be amended please contact your assigned advisor.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.

We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

12. How can you stop the use of your personal data for direct marketing?

You can stop direct marketing communications from us:

• Write to RTWS, CTEC, 1-15 Main Street, Cambuslang, G72 7EX
• Email us at info@rtws.org

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.