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Privacy Notice

Vestia Community Trust on behalf of Fusion & identified Delivery Partners

Introduction

This privacy notice solely concerns the work of Vestia Community Trust activity on behalf of Fusion and the identified Delivery Partners where there is a need to collect and process personal data to deliver;

  1. Delivering Building Better Opportunities programme, funded by Big Lottery and European Social Funds to help long term unemployed into employment.
  2. The Charter for Inclusive Growth and encouraging Worcestershire employers to give employment opportunities to people who may have been out of the labour market for some time and are economically and socially excluded.

We are committed to handling your personal information fairly, lawfully and securely in line with current data protection laws.

We take your privacy seriously and this privacy notice explains the categories of personal data we process and for what purposes. It explains the personally identifiable information we will collect and hold about you. This information may be provided by you or from a third party.

By reading this notice you will understand what to expect when Vestia or a Fusion Delivery Partner processes your personal information and your rights in relation to your data. It applies to information about BBO Programme service users and Businesses who have signed the Worcestershire Inclusive Growth Charter.

We keep our privacy notice under regular review and we will place any updates on our website. If you would like to receive a printed copy of our privacy notice, please contact a member of the Fusion team on fusion@vestia.org.uk.

Vestia Community Trust is part of The Community Housing Group and if you have any questions about how we use your personal information, the Groups' Data Protection Officer can be contacted by email at dataprotection@communityhg.com or by post at "The Data Protection Officer", 3 Foley Grove, Kidderminster DY11 7PT.

For independent advice about data protection and privacy concerns in the UK, you can contact the Information Commissioner (ICO) online at www.ico.org.uk or by phone on 0303 123 1113

This privacy notice replaces any previous notices that we have published about using your personal identifiable information.

Fusion was created in 2014 with the vision of Worcestershire not for profit Housing Partners and Voluntary Community Sector organisations come together to deliver Worcestershire wide services to help long term unemployed move into employment.

Vestia on behalf of Fusion Partnership has secured three contracts to deliver Worcestershire Building Better Opportunities programmes. These 3 BBO projects has received £3m of funding from the Big Lottery Fund and the European Social Fund as part of the 2014-2020 European Structural and Investment Funds Growth Programme in England. The Department for Work and Pensions is the Managing Authority for the England European Social Fund programme. Established by the European Union, the European Social Fund helps local areas stimulate their economic development by investing in projects which will support skills development, employment and job creation, social inclusion and local community regenerations. For more information visit https://www.gov.uk/european-growth-funding.

Where we refer to "we" or "us" in this Privacy Notice, we are referring to Vestia Community Trust or one of the Fusion Delivery Partners

With reference to Building Better Opportunities, the Department of work and Pensions are "data controllers" of your personal identifiable information. The data controller is responsible for determining the means of collection and the use of this information.

Vestia Community Trust and the Fusion Delivery partners are ‘data processors’ who process data on behalf of the Data Controller (Department of Work and Pension) in order to deliver the Building Better Opportunities Programme.

Vestia Community Trust and The Community Housing Group are registered with the ICO as follows:

  • The Community Housing Group - ZA045493 ICO Notification Number
  • Vestia Community Trust - Z2965897 ICO Notification Number

You will find details of Fusion Delivery partners own Privacy Notices on their Websites:

  1. Bromsgrove District Housing Trust www.bdht.co.uk
  2. Fortis Living www.fortisliving.com
  3. Onside Advocacywww.onside-advocacy.org.uk
  4. Redditch Borough Council www.redditchbc.gov.uk
  5. Rooftop Housing Group www.rooftopgroup.org
  6. The Community Housing Group www.communityhg.com
  7. Worcestershire YMCA www.ymca.org.uk/location/ymca-worcestershire
  8. St Pauls Hostel www.stpaulshostel.co.uk
  9. West Mercia Homes www.wmhousing.co.uk
  10. Willowdene www.ritesocialenterprises.org.uk
  11. Worcester Community Trust www.worcestercommunitytrust.org.uk
  12. YSS www.yss.org.uk

Depending on the products and services we deliver to you, the types of personally identifiable information used will vary. We will only collect personal information when we need it. When you provide your information, we will explain why we need it. We will also explain when information is optional and the impact of not providing this.

For Business supporting the Inclusive Growth Charter and employment or work placements of BBO Participants we will hold contact details (name, email address, telephone number and business address) for representatives of the business in order for us to contact them for events and possible opportunities.

For Building Better Opportunities Participants, we need to use some or all the following items of personally identifiable information about you.

  • Contact details - name, address, email, home and mobile telephone numbers
  • Age - date of birth, age range
  • Gender
  • Identification - information to allow us to check your identity (e.g. official documents)
  • Photograph -When producing good news stories and only with your explicit permission
  • National insurance numbers - information to carry out functions such as universal credit and/or personal care services

Special Category Information

  • Health - to support your journey and refer you to professional support if required
  • Ethnicity - to support our equality monitoring purposes
  • Sexual life; or sexual orientation - to support our equality monitoring purposes
  • Convictions - to support your journey and refer you to professional support if required
  • Education – to support your journey and offer additional support if required
  • Household Situation – Information to confirm your suitability and eligibility to join the BBO Programme
  • Employment Status – Information to confirm your eligibility to join the BBO Programme

Supplying your personally identifiable information will be essential to enter into a contract/agreement with you if you wish to access the BBO programme and for Vestia Community Trust to meet our legal or regulatory duties. Examples of these are:

  • Processing identification to confirm eligibility
  • Providing programme funders with progress data
  • Equality monitoring and regulatory reports

If you choose not to supply the personal information required, then we cannot enter you onto the BBO Programme.

Most of the time the personal information we hold about you is information you have given to us or has been gathered by us when we provide BBO programme services to you.

Examples of our means of collecting data include:

  • Directly from you - in person, by email, telephone, text message, letter or form
  • From other organisations such as your landlord, former employers, training providers, support providers, health and social care agencies, law enforcement agencies and benefit agencies.

Sharing your personal information with others

Vestia Community Trust will share your personal information within The Fusion partnership and with others outside the partnership where we need to do that to support you to gain skills and overcome barriers to help you into employment, maintain funding for the BBO programme, meet or enforce a legal obligation or where it is fair and reasonable for us to do so.

For the BBO Programme we will share your personal information if it is in our legitimate interests to do so without seeking your consent first. This may be with:

  • The Big Lottery Fund
  • European Social Fund
  • Third parties providing services on behalf of BBO Programme. For example, an external company undertaking project
  • Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative
  • Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty
  • Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions

Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.

We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.

Vestia Community Trust and the Fusion Delivery Partners will never sell your personal data to 3rd party organisations for marketing purposes.

We only use your personal information where it is permitted by the laws that protect your privacy rights.

We only use personal information where:

  • We need to use the information to comply with our legal obligations
  • We need to use the information to perform a contract with you
  • We determine it is fair to use the personal information either in our interests or someone else's interests, but there is no harm to you as a result - this may include where it is in our interest to contact you about relevant products or services or collaborate with others to improve our services
  • Where we need to seek your consent - If we ask for your consent, you have the right to subsequently withdraw it. We will let you know how to do that at the time we gather your consent

Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial of ethnic origin, political views, religious or similar beliefs, sexual orientation, or criminal convictions and allegations.

We will only use this kind of personal information where:

  • We have a legal obligation to do so (e.g. to protect vulnerable people)
  • It is necessary for us to so do to protect your vital interests (e.g. if you have a severe and immediate medical need)
  • It is in the substantial public interest
  • It is necessary for the prevention or detection of crime
  • It is necessary for insurance purposes or
  • You have specifically given us consent to use the information.

We will share your personal information within The Community Housing Group and with others outside the Group where we need to do that to provide support and services to help you gain skills and overcome barriers to secure.

Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.

We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.

Vestia Community Trust and Fusion Delivery Partners will never sell your personal data to 3rd party organisations for marketing purposes.

We only use your personal information where it is permitted by the laws that protect your privacy rights.

We only use personal information where:

  • We need to use the information to comply with our legal obligations
  • We need to use the information to deliver BBO Programme service with you
  • We determine it is fair to use the personal information either in our interests or someone else's interests, but there is no harm to you as a result - this may include where it is in our interest to contact you about relevant products or services or collaborate with others to improve our services
  • Where we need to seek your consent - If we ask for your consent, you have the right to subsequently withdraw it. We will let you know how to do that at the time we gather your consent.

Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial of ethnic origin, political views, religious or similar beliefs, sexual orientation, or criminal convictions and allegations.

We will only use this kind of personal information where:

  • We have a legal obligation to do so (e.g. to protect vulnerable people)
  • It is necessary for us to so do to protect your vital interests (e.g. if you have a severe and immediate medical need)
  • It is in the substantial public interest
  • It is necessary for the prevention or detection of crime
  • It is necessary for insurance purposes or
  • You have specifically given us consent to use the information.

To provide you with our services we may collect and use your information as follows:

To assess service user eligibility for Building Better Opportunities Programme;

To complete our assessments and subsequently if eligible we will collect detailed personal information about you including age, gender, date of birth, ethnicity, income, National Insurance number, income and benefits details, employment status, relationship status, any disabilities, any communication and accessibility requirements, religion, nationality, caring responsibilities, medical information, details of any spent or unspent criminal convictions.

We have a legal duty to confirm a person(s) eligibility for BBO employment programmes. We will need to obtain details of your citizenship, and a copy of identification documents (such as passport, home office residence papers and driving license).

To help support BBO Participants who have a vulnerability and/or receive a support service, we might also need health and social care information (such as physical, social or mental health information or medication) so we can support you identify the right support and employment for you.

To manage and administer our BBO employment programme

We may use personally identifiable information to meet the conditions set out in the contract/agreement with you or to meet our, contractual, legal or regulatory obligations, as follows:

Up to date contact details (telephone number and email address) so we can reach you when we need to discuss your services,

We may ask you for supporting information about any change in circumstances or to make changes to your details. For example; if you want to change your name on our records.

We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.

Without this information, we may be unable to adequately support you gain skills and overcome barriers to finding work.

To fulfil our health & safety and crime prevention obligations and to support our vulnerable people;

We process your personally identifiable and special category information for this purpose to meet our legal and regulatory obligations for health and safety and crime prevention.

We may hold information about vulnerabilities or your behaviour if we need to ensure services are tailored to meet your needs, or to look after our staff or anyone else working on our behalf or helping you as part of the BBO Programme.

We may capture your image on our CCTV systems if you visit one of our offices covered by this facility.

To report or share information with agencies where it is believed you or other persons' vital interests are at risk;

We use your personally identifiable and special category information for this purpose because it is necessary to protect the vital interests of you or others and to meet our legal and regulatory obligations.

We do this where you or another person is at risk of physical, mental, sexual, harm or damage.

Where you or another person needs to be protected as a vulnerable person from significant harm or serious exploitation.

When you engage with our teams to obtain extra support, guidance or advice

We use your personally identifiable information for this purpose because it is our legitimate interest to ensure you are offered the best service and it is necessary to fulfil the contractual relationship formed with you when you engage with us.

To monitor our performance

It is in our legitimate interests to use your personally identifiable information for this purpose to understand how we are performing so we can meet our goals and objectives.

We may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.

We undertake call recordings for training and quality monitoring purposes.

To perform statistical analysis to manage and reduce complaints, or to help us target our resources and prioritise services. There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example equality laws.

Keeping in touch with you, understanding your needs, and inviting you to events

To fulfil our contractual obligations, we will process your personal information to communicate with you for operational purposes using the most appropriate contact details you have given us e.g. by post, email, text message, or social media.

It is in our legitimate interests to communicate with you about products and services which relate to services you already receive from us and to keep you up to date with news and events which meet our objectives around social inclusion and helping to build communities.

Where you have given us consent to receive marketing, you can withdraw consent and update your marketing preferences by contacting us by phone 0800 169 5454 or by visiting any of our websites.

Meeting the requirements of our regulators

We may use your personally identifiable information to meet the legal or regulatory obligations set out for us by our regulators.

Fusion do not use automated decision making.

To ensure the safety and security of information you provide, it will not generally be transferred or processed outside of the UK/EEA.

There may be occasions where we need to process your information outside of the European Economic Area (EEA). Where we do this, any personally identifiable information will be limited, we will communicate where the information you provide will be stored, and we will take all necessary steps to ensure that your information remains as secure as possible.

The length of time we keep your personal information for depends on the services we deliver to you. We will never retain your personal identifiable information for any longer than is necessary for the purposes for which we need to use it.

Vestia Community Trust and the Fusion delivery partners will apply appropriate technical and organisational measures to ensure your personal information is secure.

When we need to engage a contractor or third-party suppliers to process your personally identifiable information, our contracts with them shall include strict controls on their security and confidentiality protocols.

We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you.

From the 25th May 2018 you will have eight rights:

The right to be informed

Through our privacy notices we will informed you of who is obtaining and using your personal identifiable information, how this information will be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information.

The right of access

You also have the right to obtain a copy of the personal identifiable information we hold about you. This is known as a "subject access request" (SAR).

SARs need to be made in writing and we ask that your written request is accompanied by proof of your address and identify. If you are seeking to obtain specific information, it helps if you clarify the details of what you would like to receive in your request. If someone is requesting information on your behalf, they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).

Click here to access our Subject Access Request Form

The right to rectification

You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.

The right to erasure

The right to erasure is also known as "the right to be forgotten". In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for Vestia Community Trust or one of the Fusion Delivery Partners to continue to hold it. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data, and any legal/regulatory requirements for the data.

The right to restrict processing, and the right to object

You can object and ask us to restrict processing if you feel that Vestia Community Trust or one of the Fusion Delivery Partners Group is using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a detrimental impact on you and /or has an impact on your rights.

The right to data portability

For such companies as debt advisors you can request that information you've provided to them, be transferred to another company. If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this.

Rights in relation to automated decision making and profiling

To make enquiries for further information about exercising any of your rights in this privacy notice, then please contact us by email at dataprotection@communityhg.com or by post at The Data Protection Officer, 3 Foley Grove, Kidderminster DY11 7PT.

You can also make a complaint to the data protection supervisory authority, where your personal identifiable information is being held and processed. Where your personal identifiable information in held and processed in the UK, you can complain to the Information Commissioner's Office, at www.ico.org.uk.