Welcome to the Working Chance Privacy Notice
This Privacy Notice is designed to help you to understand everything you need to know about the what, why and how of our data gathering and processing operations, and what your legal rights are. We hope you’ll take some time to read this document; we’ve tried to keep it all as simple as possible and we will keep you informed if there are any changes to the way we process your personal data in the future, before making them.
Working Chance takes its responsibility of protecting your data very seriously and we do advise you get to know our practices – if there’s anything in this policy you don’t understand or if you want to ask any questions, please feel free to contact us using any of the details below.
Who are we?
We are Working Chance, a charity helping women with convictions to find employment, or to take steps towards gaining employment. You can contact us at any time at info@workingchance.org, or on 0800 035 1570 between 10am-5pm, Monday to Friday.
Working Chance has appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. This person is Ruth Daniells, our Head of Finance. She can be contacted at ruth@workingchance.org.
It is important that the personal information we hold about you is accurate and up to date. Please let us know if any of your personal information changes (e.g. If you change your home address or phone number) during your relationship with Working Chance so that our records can be updated. Working Chance cannot be held responsible for any errors in your personal information in this regard unless you have notified us of the relevant change.
What categories of personal information do you collect about me?
We need all the types of personal information listed below primarily to enable us to carry out our support for you, so we can comply with our legal obligations and to undertake equal opportunities monitoring.
- Your contact details, including your name, telephone number and email address
- Date of birth
- Gender
- Nationality
- Caring responsibilities
- Recruitment records, such as CV, application form, cover letter, interview notes and feedback, referee details, copies of qualification certificates (if requested by an employer we place you into work with)
- Right to work in the UK information and documentation
- Bank details (if needed for expenses claims)
- Education and qualifications
- Main household occupation when aged 14.
Sensitive data
Working Chance also collects, uses, and processes some information about you that is called in the data legislation ‘special categories’ data’, such as:
- Information about your health, including any medical condition, mental health issue or disability, medical reports and related correspondence.
- Information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation .
- Information about any risks to you or others around you.
Criminal offence data
Criminal offence data is given extra protection under the law and we ensure that this is followed by protecting your data. We can process this data as we are supporting you with your employment following your experience with the criminal justice system. Information that we collect includes:
- Information about your conviction including other convictions if applicable and whether convictions are spent.
- Information about your sentence, release data and prison details if applicable.
- Any license conditions.
- Probation information and contact details.
Why and how do you use my ‘special category’ and criminal data?
We will only collect and use your special categories of personal information when the law allows us to.
Some special categories of personal information, e.g.. information about your health or medical conditions and information about criminal convictions and offences, is processed so that we can better understand your personal needs in order that you gain maximum benefit from our support programmes.
Where Working Chance processes other special categories of personal information, e.g. information about your racial or ethnic origin, religious or philosophical beliefs or sexual orientation, this is done for a) equal opportunities monitoring and in line with our data protection policy, or b) for the purposes of policy and research work carried out by us to improve the criminal justice system and the experience of women with convictions. Personal information that Working Chance uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.
We may also occasionally use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise or defence of legal claims.
What if the purpose changes?
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you.
How do you collect my personal information?
We will usually collect information about you by asking you for it. Occasionally we may also collect personal information from other external third parties, such as references from former employers.
What is the legal basis for using my data?
Working Chance will only use your personal information in ways that the law allows (these are called ‘lawful bases’.) We will use your personal information in under one or more of the following situations:
- Consent: Most of the time we rely on asking you for provide consent for our use of your personal information.
- Legitimate interests: Where it is necessary to pursue our legitimate interests. Our legitimate interests in this case are supporting you with your employability in our role as a charity that exists to support women with convictions into employment.
- Performance of a contract: Where we need to do so in order to provide you with our services.
- Legal obligation: Where we need to comply with a legal obligation.
- Vital interests: We may also occasionally use your personal information where we need to protect your vital interests (or someone else’s vital interests).
What if I don’t want to provide personal information?
It is entirely your choice to provide personal information. If you don’t want to provide certain personal information when requested, we may not be able to support you through our services as well as we would otherwise (e.g. we need your conviction information to support you to disclose this to an employer if needed), or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.
Who has access to my personal information?
Your personal information may be shared with third-party service providers (and their designated agents), including:
- Potential employers for the purposes of introductions if there was a job you were interested in.
- Third party organisations may on occasion have access to your data through their delivery of services to us. These include: our external IT company; our secure database company Salesforce; other external organisations that we may refer to you to for additional support, if needed .
We may share your personal information with third parties where it is necessary to administer the agreement we have entered into with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).
How does Working Chance protect my personal information?
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. Your data is held on a secure database. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We also employ user permissions on our database to ensure that members of staff only have access to appropriate data. For example, equalities data is not viewable by frontline teams, only by the Impact and Evaluation team.
We have also 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.
How long will my data be kept for?
Once your relationship with Working Chance has ended, we will delete any information that could identify you after three years. After this time all your personal data is anonymised so no one can identify you. We still use the anonymised data for research and statistical purposes and this information may be used indefinitely.
Important notice: The length of time we keep your data has changed from one year to three years with effect from 1 August 2024. Those who consented to having their data collected and stored before this date will still be subject to the previous privacy policy and will have their data deleted one year following their last engagement with Working Chance. Any new referrals from this date (even if previously engaged with us) will require new consent based on the updated policy.
Reason for the change
We have increased the length of time we retain the personal data for the following reasons:
- The number of returning clients we work with means there is benefit to both the client and organisation to retain records for longer than one year.
- Some of our work is funded under a contract that requires the data to be reported on over a three-year period and this will allow us to meet this requirement for those clients.
- To ensure that there is a consistent data protection policy across all client data to provide clarity to our clients however they access our service and help maintain accurate and robust internal data protection processes.
- To help evaluate and understand the longer-term impact of our service.
This change does not affect your rights as outlined in both this policy and the Data Protection Act 2018.
What are my rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include 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.
- Withdraw your consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at: info@workingchance.org.
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month, although in practice we are likely to respond much sooner than that. Occasionally it may 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.
Right to be forgotten
Where you have provided your consent to the processing of your personal information you have the right to withdraw your consent at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our Data Protection Officer (DPO) at ruth@workingchance.org. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
If you believe that Working Chance has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues.
They can be contacted by telephone: 0303 123 1113, or any of the other reporting methods listed on their website: https://ico.org.uk/
Transferring personal information outside the European Economic Area
Working Chance will not transfer your personal information to countries outside the European Economic Area.
Changes to this privacy notice
Working Chance reserves the right to update or amend this privacy notice at any time, including where we intend to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will issue you with a new privacy notice when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.
Date created: May 2020
Date reviewed: September 2024
Date of next review: May 2025