How Clear Links Uses Data

Introduction

Clear Links respects your privacy and is committed to protecting your personal data.

The information on this page explains how we process your personal data and how, in doing so, we comply with our legal obligations to you.

Privacy Notices

If we process your personal data we will have provided you with a Privacy Notice which provides accessible information about our use of your personal data. It is important that you read this so that you are fully aware of how and why we are using your data and your rights over this data.

Links to our privacy notices for each category of data subject are provided below.

Students/Learners

Support Worker Applicants

Support Workers

Staff at education providers, assessment centres or funding bodies

Assistive technology service clients

Suppliers / business contacts

Referees (people who have provided Clear Links with a reference)

Emergency contacts for Clear Links staff / support workers

Service communication contacts

Recruitment Contacts

Third party contacts for support arrangements

Clear Links Applicants

Clear Links Employees

Data Privacy Notice for Access to Work clients

We may amend this information from time to time. Please visit this page if you want to stay up to date, as we will post any changes here.

Data security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those who have a business need to know.

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

Website Use and Cookies

Information about website use and cookies can be viewed here.

Further information

If you have any questions relating to data protection policy, guidance and practice please contact our Data Protection Officer – Dexter Johnstone, dexter.johnstone@clear-links.co.uk, 0114 278 6866.

Data Privacy Notice for Support Worker Applicants

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to determine your suitability for work and to contact you regarding this. If you are applying for work in Scotland we are required to carry out a Protecting Vulnerable Groups (PVG) check which will involve processing personal data about criminal convictions or offences.

Our lawful basis for processing personal data is 6 (1) (b) – Contract. Processing is necessary for the performance of a contract with you or to take steps to enter into a contract.

Our lawful basis for processing personal data about criminal convictions or offences is 6 (1) (c) - Legal Obligation - processing is necessary for us to comply with the law. Our processing of personal data about criminal convictions or offences meets the Data Protection Act 2018 Schedule 1, Part 1, Condition 1 ‘Employment, social security and social protection’.

Categories of personal data

The personal data we will process includes your name, your contact details (address, phone number and email), date of birth, information about your education, qualifications, training and right to work in the UK, your CV, references and professional body membership, date of birth and gender.

We will process personal data about any criminal convictions you may have if you apply for work in Scotland, or at an education provider for a role where a criminal record check is required.

Any recipient or categories of recipients of the personal data

We will share your personal data with Trust ID for the purposes of carrying out right to work checks.

If you are applying for work in Scotland or at an education provider for a role where a criminal record check is required we will share your personal data with Due Diligence Checking for the purposes of carrying out a PVG/DBS check.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

If your application is unsuccessful all your personal data will be deleted 6 months from the date the application was unsuccessful.

If your application is successful we will require further personal data from you. You will be provided with a new privacy statement explaining the retention period of the existing and new personal date we have.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you, except the references which came from the referees you provided. It did not come from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to fulfil our obligations under a contract of services. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for Support Workers

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to match you with students/learners, monitor the support you deliver and provide associated services such as payroll.

Our lawful basis for processing personal data is 6 (1) (b) Contract and 6 (1) (c) Legal Obligation. Processing is necessary for the performance of a contract with you or to take steps to enter into a contract and processing is necessary for us to comply with the law.

Our lawful basis for processing special category personal data is 9 (2) (a) – you have given explicit consent to the processing of those personal data for one or more specified purposes – or 9 (2) (b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law.

Our lawful basis for processing personal data about criminal convictions or offences is 6 (1) (a) Consent - you have given explicit consent to the processing of those personal data for one or more specified purposes - or 6 (1) (c) - Legal Obligation - processing is necessary for us to comply with the law. Our processing of personal data about criminal convictions meets the Data Protection Act 2018 Schedule 1, Part 1, Condition 1 ‘Employment, social security and social protection’ or Part 3, Condition 10 ‘Consent’.

Categories of personal data

The personal data we will process includes your name, your contact details (address, phone number and email), right to work details, information about your education, employment and training, your bank account details and NI number, a photo for your ID, your CV, your date of birth, your gender, references, emergency contact details, information about your use of our online systems (your IP address, pages accessed, time of page access, browser information), professional body membership and information about the support work you have delivered.

The special category personal data we may process is information about your disability and health. We always request your explicit consent to process information about your disability and it is only used for specific purposes (i.e. for the purposes of workplace reasonable adjustments). If you are unable to attend assignments due to ill-health we may process this information because we are required by law to process sickness absence data to facilitate the payment of statutory sick pay.

Any recipient or categories of recipients of the personal data

We will share some of your personal data with the student/learners you work with, the education provider and the funding body of the student/learner you work with, Her Majesty’s Revenue and Customs and Nest – the pensions provider we use.

We may share some of your personal data with the Department for Education if we are audited by them.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The type of data determines the retention period and some personal data will need to be retained for longer than others.

For example, we will delete your contact details after 1 year from the date your employment ceases. Other information, for example pay details, will need to be kept for 6 years from the date your employment ceases.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you. It did not come from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to fulfil our obligations under a contract of services or to comply with our legal obligations. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for Education Provider, assessment centre or funding body staff

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing is to liaise with you about the support of students/learners at your education provider or who have attended the assessment centre you work for, or whose funding you administer.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process includes your name, your work contact details (address, phone number and email), information about your use of our online systems (your IP address, pages accessed, time of page access, browser information), the name of the education provider, assessment centre or funding body you work for and your job title.

Any recipient or categories of recipients of the personal data

We may share your name and contact details with students or learners that we support.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Some personal data will need to be retained for longer than others.

The type of data determines the retention period.

At the end of the retention period the data will be reviewed and deleted.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you or by the institution, assessment centre or funding body you work for. The data was not from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

The provision of your personal data is not part of a statutory or contractual requirement or obligation.

If you do not provide us with your personal data we would not be able to discuss the support of students/learners.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for Assistive Technology Clients

Identity and contact details of the data controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

We will process your personal data for the purposes of providing and supporting your assistive technology.

Our lawful basis for processing personal data is 6 (1) (b) – Contract. Processing is necessary for the performance of a contract with you or to take steps to enter into a contract. The contract is the provision of technical support to you.

Categories of personal data

The personal data we will process includes your name, your contact details (address, phone number and email) and any communication preference you have, your funding body name and customer reference number, information about your assistive technology and support for this technology.

Any recipient or categories of recipients of the personal data

We will share some of your personal data with your funding body.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Some personal data will need to be retained for longer than others.

The type of data determines the retention period.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you or by your education provider, assessment centre or funding body. It did not come from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to provide our services to you. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for suppliers / business contacts

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing to communicate with you and to arrange payments for services.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process includes your name, your work contact details (address, phone number and email), the name of your employer.

Any recipient or categories of recipients of the personal data

We will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Some personal data will need to be retained for longer than others.

The type of data determines the retention period.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you or your employer. The data was not from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

The provision of your personal data is not part of a statutory or contractual requirement or obligation.

If you do not provide us with your personal data we would not be able to discuss the provision of business services to Clear Links.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for referees

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to obtain a reference from you for someone who has applied to work for Clear Links.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process about is: your name, your contact details (address, phone number and email), your relationship with the applicant, your role/job title.

Any recipient or categories of recipients of the personal data

We will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will keep your details for as long as the person who you provided the reference for works for Clear Links.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we will process about you originates from the applicant. It is not from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

The provision of personal data is not part of a statutory or contractual requirement or obligation. Without your personal data we would not be able to obtain a reference for the applicant.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for emergency contacts

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to contact you in the case of an accident or emergency involving the person who provided your details.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process about is: your name, your phone number and your relationship with the Clear Links employee/worker who provided your details.

Any recipient or categories of recipients of the personal data

We will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will keep your details for as long as the person who provided your details works for Clear Links or until they provide an alternative emergency contact.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we will process about you originates from the Clear Links employee/worker. It is not from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

The provision of personal data is not part of a statutory or contractual requirement or obligation. Without your personal data we would not be able to contact you in the event of an accident or emergency.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for service communication contacts

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to send you relevant information about our services.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process about is: your name, your contact details (address, phone number and email), the institution you work at and your role/job title.

Any recipient or categories of recipients of the personal data

We will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

At the end of the retention period the data will be reviewed and deleted.

You can remove yourself from our e-mail list at any time by contacting us or clicking unsubscribe on the email.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we will process about you either originates from you or came from publicly available sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

The provision of personal data is not part of a statutory or contractual requirement or obligation. Without your personal data we would not be able to send you relevant information about our services.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for recruitment contacts

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to contact you regarding potential work for Clear Links Support.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process includes your name, your contact details (address, phone number and email) and the support role you are suitable for.

Any recipient or categories of recipients of the personal data

At this stage of the application process we will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

If you are interested in work your contact details will be deleted from our recruitment candidates list but your name will remain on the list so we don’t contact you again.

If you are not interested in work your contact details will be deleted from our recruitment candidates list but your name will remain on the list so we don’t contact you again.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was from a publicly accessible source – the database of the professional body which you are registered with.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to fulfil our obligations under a contract of services. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for third party contacts for support arrangements

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to discuss the support arrangements of a named student/learner with you.

Our lawful basis for processing personal data is 6 (1) (f) – Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Categories of personal data

The personal data we will process about is: your name, your phone number and your relationship with the student/learner who provided your details.

Any recipient or categories of recipients of the personal data

We will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will keep your details for as long as the person who provided your details is supported by Clear Links or until they provide an alternative third party contact or withdraw consent to discuss their support arrangements with you.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we will process about you originates from the student/learner supported by Clear Links. It is not from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

The provision of personal data is not part of a statutory or contractual requirement or obligation. Without your personal data we would not be able to discuss the support arrangements of the student/learner with you.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for Clear Links Applicants

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

The purpose of processing your personal data is to determine your suitability for work and to contact you regarding this.

Our lawful basis for processing personal data is 6 (1) (b) – Contract. Processing is necessary for the performance of a contract with you or to take steps to enter into a contract.

Our lawful basis for processing special category personal data is 9 (2) (a) – you have given explicit consent to the processing of those personal data for one or more specified purposes.

Categories of personal data

The personal data we will process includes your name, your contact details (address, phone number and email), information about your qualifications, employment and training, your CV, photo and references.

The sensitive personal data we may process is information about your disability. We always request your explicit consent to process this data and it is only used for specific purposes (i.e. so we can do our best to provide reasonable adjustments during the interview process).

Any recipient or categories of recipients of the personal data

At this stage of the application process we will not share your personal data with anyone else.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for.

If your application is unsuccessful all your personal data will be deleted 6 months from the date the application was unsuccessful.

If your application is successful we will require further personal data from you. You will be provided with a new privacy statement explaining the retention period of the existing and new personal data we have.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you, except the references which came from the referees you provided. It did not come from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to fulfil our obligations under a contract of services or to make steps to enter into a contract. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for Clear Links Employees

Identity and contact details of the controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

Our lawful basis for processing personal data is 6 (1) (b) Contract and 6 (1) (c) Legal Obligation. Processing is necessary for the performance of a contract with you or to take steps to enter into a contract and processing is necessary for us to comply with the law.

Our lawful basis for processing special category personal data is 9 (2) (a) – you have given explicit consent to the processing of those personal data for one or more specified purposes – or 9 (2) (b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law.

Categories of personal data

The personal data we will process includes; your name, gender, date of birth, your contact details (address, phone number and email), the name and phone number of your emergency contact, your right to work details, information about your qualifications, employment and training, your application and CV, references, your bank account details, National Insurance Number, ID photo, pay, holiday, performance, pension and benefits information, and employment records (including job titles, work history, working hours and training records).

The special category personal data we may process includes information on any medical conditions or disabilities you disclose to us. We always request your explicit consent to process information about your disability and it is only used for specific purposes (i.e. for the purposes of workplace reasonable adjustments). If you are unable to attend work due to ill-health we will process this information because we are required by law to process sickness absence data to facilitate the payment of statutory sick pay.

Any recipient or categories of recipients of the personal data

We will share some of your personal data with Her Majesty’s Revenue and Customs, Hollis and Co Ltd Chartered Accountants, Alexander Calder Financial Ltd, The Royal London Mutual Insurance Society Ltd and Friends Life Group.

Depending on your role in the company we may share your personal data including your name, role and ID photo with the students, learners, support workers and staff at the education provider that you work with.

If you opt into an employee benefit scheme, we will also share some of your personal data with Westfield Contributory Health Scheme Ltd and TransaveUK Credit Union.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for. The type of data determines the retention period. Some personal data will need to be retained for longer than others.

For example, we will delete your contact details after 6 months from the date your employment ceases. Other data, for example payroll information, will need to be kept for 6 years from the end of the last company financial year it relates to.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for 3 months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to fulfil our obligations under a contract of services. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.

Data Privacy Notice for Access to Work clients

Identity and contact details of the data controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

We will process your personal data for the purposes of providing, monitoring and invoicing your Access to Work support.

Our lawful basis for processing personal data is 6 (1) (b) – Contract – and 6 (1) (f) – Legitimate Interests. Processing is necessary for the performance of a contract with you or to take steps to enter into a contract (the provision of Access to Work support to you) and the processing is necessary for our legitimate interests or the legitimate interests of a third party.

Categories of personal data

The personal data we will process includes your name, your contact details (address, phone number and email) and any communication preference you have, the name of your employer, information about your use of our online systems (your IP address, pages accessed, time of page access, browser information), information about your support and any additional information you provide to assist us with matching you to a suitable worker.

Any recipient or categories of recipients of the personal data

We will share some of your personal data with your employer.

We will share some of your personal data with the support worker(s) you are matched to.

Details of transfers to third country and safeguards

We will not transfer your data outside the European Economic Area. The servers which store our data are located within the UK.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Some personal data will need to be retained for longer than others.

The type of data determines the retention period. For example, we will delete your contact details one year from the date your support ceases. Other data, for example invoices for your support, will need to be kept for six years from the end of the last company financial year it relates to.

At the end of the retention period the data will be reviewed and deleted.

The deleted data will remain on our data backups for three months from the date of deletion. After that time the data will not be held by Clear Links in any format.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioners Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

The personal data we hold about you was provided by you or by your employer. It did not come from publicly accessible sources.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to provide our services to you. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.

We do not make use of any automated decision-making processes.