Under the UK General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

(a) legitimate interest – we need to process your personal data to administer and report on the performance of the project or programme which has supported you into training and employment and to evaluate the social impact to gain support for future projects.

(b) consent  – we seek explicit consent to process data related to your health, ethnicity, and any criminal offence data.  We will seek your separate consent if you feature in  our promotional materials e.g.  case studies.   You can withdraw your consent at any time by contacting:  csradmin@procure-plus.com.

(c) compliance with a legal obligation  – some circumstances we may be required to act under a legal or statutory obligation, for example to respond to a subject access request

You give us information when you:

• register on our candidate portal
• complete a form
• correspond by phone, email or other means.
• engage with us on social media

We may also get information from other sources, including:

• Third parties, such as our delivery partners, employers and external training organisations
• Software services that we use to administer our work

• Name and contact details (phone, email address, postal address)
• Date of birth
• Education, training, and employment details – employment and education history, qualifications, CVs, attendance at training courses and interviews, evidence of employment
• Email correspondence and notes relating to the training and employment support provided
• Photographs and videos and case studies for promotional materials

We work proactively to support people from diverse backgrounds move into training and employment. This means we ask you about your status in relation to groups we target support at, this may include:

• Age
• Gender
• Social housing landlord and geographical location
• If you are in care or a care leaver
• If you have served in the military

This means we also collect some sensitive information such as your

• ethnic background
• whether you class yourself as having a disability or learning difficulty
• whether you have ever spent time in prison, a Young Offenders’ Institute, served a community order and/or been convicted of any offense through British courts

We do not hold any information disclosed to our delivery partners about unspent criminal convictions.

A unique identifier will be generated by our system against your records.

Occasionally, we may record notes of conversations between ourselves, the delivery partner and your employer.

We may collect additional information depending on the requirements of the funders / stakeholders involved in the programme you have engaged with.  Please check the programme specific information at the end of this page.

We use your information for many purposes, which may include:

• to provide employment and training support services to you
• to assess your eligibility for funding or employment and training opportunities
• to help us to improve and expand employment and training support services
• to monitor the effectiveness of our delivery partners
• for audit and compliance purposes
• to comply with our contractual obligations and grant funding agreements
• to evaluate and report on our activities to our board, funders and other stakeholders
• to promote our work

Wherever possible your data will only be shared on an anonymised and/or aggregated basis.

However, we may need to share your information with third parties for our operational or administrative needs, to provide you with support into employment or training, evaluate the impact of our service and comply with obligations to funders and to comply with the law:

• Our service providers – for example where your data is held in a software system
• Our delivery partners – community groups, employment organisations and training providers we are working with to support you into employment and training
• Our funders – where we are required to evidence compliance with a contract
• Your employer or prospective employers for the purpose of supporting you into employment

Where we share data with other organisations there are contractual agreements in place that outline how your data can be used.

All the personal data we process is processed by our staff in the UK who received training in data protection.

We have security arrangements in place to guard against unauthorised access, improper use, alteration, destruction or accidental loss of your personal information. We take appropriate organisational and technical security measure and have rules and procedures in place to ensure that any personal information we hold is not accessed by anyone it shouldn’t be.

Our IT hosting and maintenance is located on servers within the European Economic Area (EEA).  Your data receives the same level of protection in the EEA as it does in the UK through the safeguard of Adequacy Decisions.

We do not intend to transfer data outside of the EEA but in the event that we do so we will comply will all appropriate transfer mechanisms as stipulated by Data Protection Legislation.

Under data protection law, your rights in relation to data we hold about you include:

• Right of access – you can ask us for a copy of the data we hold about you
• Right to rectification – if the data we hold is inaccurate or incomplete you can ask us to update this information

You also have the right to:

• Erasure – you can ask us to erase your personal information.
• Restriction of processing – you can ask us to limit the way we use your data for a period
• Object to processing – you can stop us from processing your data for a particular purpose.
• Data portability – you can ask to receive the information you have provided to us in a format that will allow you to easily transfer it to another organisation.

However, these rights and our ability to meet these requests will depend on the circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

We do not use automated decision making.  If in the future, if we intend to process your personal data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information.

Procure Plus is a registered data controller (number Z1072740).

Re:vision is a registered data controller (number ZA070946). Procure Plus acts as a processor for Re:vision.

If you wish to exercise any of your rights or raise a complaint on how we have handled your personal data, you can contact:

Group Company Secretary, Katie Taylor by email to katie.taylor@procure-plus.com

or in writing at Procure Plus, Duckworth House, Lancastrian Office Centre, Talbot Road, Manchester, M32 0FP).

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Procure Plus has links with employers who can refer employees to benefit from funded training.  This is delivered by training partners contracted by Intertrain UK Ltd (a City and Guilds business) who deliver Skills Bootcamp for the Department for Education (DfE).

• Intertrain UK Limited
• the delivery partner that delivered your training
• third parties who provide us with support services and who we have contracts in place with
• our auditors where the scope of and nature of the audit requires it

Intertrain UK Limited (a City and Guilds business) and training organisations contracted by them.  This project is funded by the Department for Education (DfE).

The Onsite Experience programme (OSE) is a CITB funded programme, designed to provide people with no current or recent experience of the construction industry with job specific training and work placements in order to secure employment (or self-employment) within the construction industry. Procure Plus has been commissioned to deliver this programme on behalf of CITB.  In order to deliver this programme, Procure Plus  works with delivery partners to identify suitable candidates, training providers to provide training required and employers to provide work placements and employment opportunities.

In addition to our standard for data for this project we also collect:

• CSCS card number
• National Insurance number
• UK Citizenship
• Drivers Licence
• History of working in the construction sector
• Occupations you are interested in working in
• Consent to be contacted as part of an evaluation of the programme
• Clothing size for Personal Protective Equipment

If you engage with the programme:

• Records of training attended
• Records of onsite experience

If you are successful in securing employment:

• Occupation
• Date employment commenced or reason for not starting
• Employer
• Job Level
• Weekly gross salary
• Type of construction project you are employed on

Procure Plus uses your information to:

• Assess eligibility and suitability
• Arrange and deliver appropriate training
• Facilitate and evaluate work placements
• Secure employment opportunities
• Monitor progress once in employment

We will contact you to confirm you have completed 12 weeks’ employment in construction, which is a condition of your funded training.

We also use your data to:

• Report activity to meet our contractual obligations to funders (CITB)
• Report activity to other stakeholders (e.g. our Board, local authorities and social housing providers)
• Evaluate the impact and quality of services provided

Where we use your data as part of promotional activity (case studies, news items, award submissions etc) additional consent will always be gained where you are personally identifiable.

Our partners for this project are:

• CITB

The CITB is a Joint Data Controller with Procure Plus.

 Construction Industry Training Board (CITB) to enable CITB to fulfil its functions as set out in the Industrial Training Act 1982. CITB’s statutory functions include but are not limited to the maintenance of a record of candidates’ construction-specific training achievements on the CITB Construction Training Register (‘CTR’) (or such other recording system as CITB operate from time to time).  CITB may also share your information with a third party who may contact you to carry out an evaluation of the fund.  For information explaining your legal rights and how we use your information, please view our Privacy Notice online at citb.co.uk/privacy.

• Delivery Partners and Training Organisations

If our delivery partner has provided you with support to get ready for, or to move into work, they are a data processor on behalf of Procure Plus in respect of the data held on the consent form and evidence of employment required by Procure Plus.

The delivery partner may hold additional data they may have collected from you, training organisations or employers in order to provide you with support into employment for example CVs, training records, unspent criminal convictions for which they are the Data Controller.

• Other organisations

 We may share data with local authorities or social housing providers for the purpose of evaluating and reporting on the impact of our service in their community. Identifiers such as your name would not be shared but you may be indirectly identifiable if there are a small number of people with the same characteristics as you.  For example, one female bricklayer living within a certain postcode.

Your data will be held securely and be treated confidentially. It will not be disclosed to external parties other than as required for the purposes described.

If you register using our portal but do not progress your data will be deleted after three months.

If you start training (even if you do not complete or progress) your data will be deleted after 7 years.

Email communication is deleted after 7 years.

Procure Plus has a contract with Cambridgeshire and Peterborough Combined Authority (CPCA)  to deliver social value to local communities within the Greater Southeast Region. CPAC has asked Procure Plus  to  provide a service to support you into training or employment, Procure Plus does this by engaging with local delivery partners.   Your data is processed to evidence that the delivery partner has supported you into employment and to report outcomes to CPCA, the procure Plus Board and other stakeholders. It is also processed for auditing and compliance purposes.

The consent form you completed which included your name, geographic location, contact details, landlord, date of birth and information that relate to the priority groups that this support is targeted at will be provided to us by the delivery partner. We also collect evidence of sustained employment or other evidence of employment provided by you e.g a payslip.

The local delivery partner who supported you will also hold the above details.

Photographs and / or video clips or case studies may be used in marketing materials for Procure Plus and/or CPCA (this would only be with separate explicit request made via your delivery partner).

Your data will be held securely and treated confidentially and will not be disclosed to third parties outside of Procure Plus and other than as described below:

• the delivery partner that supported you into training or employment
• third parties who provide us with support services and who we have contracts in place with
• our auditors and auditors appointed by CPCA where the scope of and nature of the audit requires it

• Cambridgeshire and Peterborough Combined Authority (CPCA)

We will use anonymised data for the performance monitoring of our contract with CPCA and to report on our social value activities to our Board and other stakeholders.

• Delivery Partners and Training Organisations

Our delivery partner has provided you with support to get ready for, or to move into work. The delivery partner may hold additional data they may have collected from you, training organisations or employers in order to provide you with support into employment for example CVs, training records, unspent criminal convictions. This information relating to the support you receive before employment and/or whilst in employment is not shared with us and the delivery partner is the Data Controller.

Procure Plus is only the Data Controller in respect of the information on the consent form you completed, and evidence of employment will be shared between the delivery partner and Procure Plus.

We will not share your information with any third parties for the purposes of direct marketing.

Your data will be deleted after 6 years.

Re:vision is a regeneration charity that is part of the Procure Plus Group. Re:vision works with delivery partners in the local community.  Your data is processed by us to evidence that our delivery partner has supported you to find employment, undertake training or work experience placement and so that we can report on the delivery of our charitable objectives to our stakeholders such as our board and the Charity Commission. It is also processed for auditing and compliance purposes.

Information provided by you via our delivery partner:   Name, geographic location, contact details, landlord, date of birth and information that relates to the priority groups that this support is targeted at.

We also collect evidence of employment and sustained employment, or other evidence of employment provided by you e.g. a payslip.

The local delivery partner who supported you will also hold the above details.

Information generated by us: A unique identifier will be generated by our system. Occasionally, we may record notes of conversations between ourselves, the delivery partner, and your employer.

Photographs and / or video clips which may be used in marketing materials for PPH  (this would only be with separate explicit request made via your employer or delivery partner).

Your data will be held securely and treated confidentially and will not be disclosed to third parties outside of Re:vision  and other than as described below:

• the delivery partner that supported you into training or employment
• third parties who provide us with support services and who we have contracts in place with
• our auditors where the scope of and nature of the audit requires it

We will not share your information with any third parties for the purposes of direct marketing.

Procure Plus Holdings Limited 

Procure Plus provides staffing and other resources to Re:vision and is a Data Processor.

Re:vision also sometimes works collaboratively with Procure Plus to assist individuals into employment within the construction sector.

Delivery Partners and Training Organisations

Our delivery partner has provided you with support to get ready for, or to move into work. The delivery partner may hold additional data they may have collected from you, training organisations or employers in order to provide you with support into employment for example CVs, training records, unspent criminal convictions This information relating to the support you receive before employment and/or whilst in employment  is not shared with us and the delivery partner is the Data Controller.

Your data will be deleted after 7 years.

Procure Plus has a contract with your employer or prospective employer to create job opportunities for people living within your local area.   Your data is processed to evidence the contractual criteria has been met , and reporting on performance to the PPH Board and other stakeholders. It is also processed for auditing and compliance purposes.

Information provided by you via your employer / or our delivery partner:   Name,  geographic location, contact details, landlord, date of birth and information that relate to the priority groups that this support is targeted at.

Information provided by your employer – Confirmation of sustained employment.

If you have been supported by a local delivery partner, they may also hold the above details.

Information generated by us: A unique identifier will be generated by our system. Occasionally, we may record notes of conversations between ourselves, the delivery partner and your employer.

Photographs and / or video clips which may be used in marketing materials for PPH  (this would only be with separate explicit request made via your employer or delivery partner).

Your data will be held securely and treated confidentially and will not be disclosed to third parties outside of Procure Plus and other than as described below:

• your employer or prospective employer
• the delivery partner that supported you into training or employment
• third parties who provide us with support services and who we have contracts in place with
• our auditors where the scope of and nature of the audit requires it

We will not share your information with any third parties for the purposes of direct marketing.

Delivery Partners and Training Organisations

Our delivery partner has provided you with support to get ready for, or to move into work. The delivery partner may hold additional data they may have collected from you, training organisations or employers in order to provide you with support into employment for example CVs, training records, unspent criminal convictions This information relating to the support you receive before employment and/or whilst in employment  is not shared with us and the delivery partner is the Data Controller.

Your data will be deleted after 7 years.