This notice explains what personal data we hold about you, how we collect it, how we use it, and how we may share it. We are required to give you this information under data protection law.

Full information on West Northants Councils full data protection policy can be found here.

Who we are:

The South Midlands Connect to Work Programme is a DWP funded programme that provides supported employment services to help individuals with barriers to work access and sustain meaningful employment across Bedfordshire, Milton Keynes, and Northamptonshire to find and sustain meaningful work.

West Northamptonshire Council is the Accountable Body for the South Midlands Connect to Work Programme and is responsible for processing your personal information. We are regulated under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are the ‘data controller’ for this information alongside the Department of Work and Pensions (DWP), and our Local Authority delivery partners are ‘joint controllers’ of the information for their geography.

What information do we hold:

For the delivery of the Connect to Work Programme, the information we hold may include:

• Name, date of birth, and contact details
• National Insurance number
• Employment and education history
• Residency and benefit status
• Details of any support services you are receiving
• Health information, disabilities, or learning difficulties
• Ethnicity and other equalities monitoring data
• Referral and case management information

The personal and special category data we collect varies according to the purpose of the contact. 

How we collect your data:

Most of the personal information we process is provided to us directly by you in the following ways:

• Face to Face
• Reports
• Expression of Interest form / Application form
• Telephone, email or in writing

We may also receive information from the following with your agreement:

• Programme delivery partners (Bedford Borough Council, Central Bedfordshire Council, Luton Borough Council, Milton Keynes City Council, North Northants Council, and West Northants Council)
• Commissioned delivery partners
• Referral partners (for example Jobcentre Plus, social care teams, health professionals including the NHS)
• Other services you are engaged with.

Why we collect your information:

There are a number of reasons why we need to collect and use your personal information in relation to this programme:

• Assess your eligibility and suitability for the programme
• Provide tailored employment support
• Monitor your progress and outcomes
• Report to the Department for Work and Pensions (DWP) and other government departments
• Evaluate and improve the programme
• Ensure compliance with funding and legal requirements

Whenever we collect information, we always limit this to only the details that are needed. We ensure that data is used and stored safely and securely. We require anyone we share information with, or who uses it on our behalf, to do so too. All programme staff have received training on data protection and information security.

Legal basis for processing your data:

We collect and use your personal for the Connect to Work programme for the following reasons:

• Public task: Processing is necessary for the performance of a task carried out in the public interest
• Substantial public interest: For processing special category data
• Consent: Where you have given permission as part of being referred onto the programme.
• Schedule 1, Part 2 of the Data Protection Act 2018 – Equality of opportunity or treatment

Who we share your information with:

We may share your information with the following groups:

• Programme delivery partners who are joint controllers in the programme (Bedford Borough Council, Central Bedfordshire Council, Luton Borough Council, Milton Keynes City Council, North Northants Council., West Northants Council)
• Government departments including DWP (the funder) and others such as HMRC
• Commissioned delivery partners
• Employers and training providers (with your agreement)
• Other organisations who may be able to support you (with your agreement)
• Health services
• Other organisations where required by law or for safeguarding purposes

All partners are required to comply with data protection legislation and are subject to data sharing agreements.

Please look at the privacy notices of the joint data controllers (Local Authority delivery partners) for this programme to see if they may share your information with other relevant partners and for what reasons.  

How long we keep your data:

We only keep information for as long as it is needed but will retain your personal information for up to 6 years after the end of the programme, in line with government guidance and funding requirements. After this period, your data will be securely deleted or anonymised. Our delivery partners are joint controllers of your data and may have different retention periods, we suggest looking at the other privacy notices in relation to this programme. 

How we store your information:

Physical files may be collected from various sources throughout this programme. They will be processed by sorting and filing, securely retained as per retention policies for this programme, and will be transferred onto our electronic data systems.

Digital data is securely stored on the council’s computer network or securely saved on our information management system, Alcium Evolutive.

We limit access to your personal information to those who have a genuine business need to know it on the programme. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

What rights do you have:

Under the UK GDPR you have a number of rights which you can access free of charge which allow you to:

• Right know what data is collected and why
• Right to receive a copy of your personal data
• Right to ask us to correct any information we hold about you
• Right to request that data is deleted
• Right to request we don’t use your data in a certain way
• Right to request your data to be shared with another organisation
• Right to make a complaint about any aspect of our use of your data
• Right to request that important decisions about you aren’t made automatically by computers or algorithms

Please be aware that your rights may differ depending on the lawful basis for processing your personal data.

If you are unhappy with any aspect of how your information has been collected or used in relation to the South Midlands Connect to Work Programme, you can speak to or make a complaint to the council Data Protection Officer at dataprotection@westnorthants.gov.uk. You can also report concerns to the Information Commissioner’s Office through the ICO website.

Changes to this privacy notice: Privacy notices are live documents and will be updated or revised periodically in line with any programme changes and/or new legislation requirements. This privacy notice was last updated on: August 2025.

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