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Privacy notice – Multiply

What information we collect and why

The data you complete when you join one of our learning opportunities is being gathered for the purpose of adult learning enrolment. Step2Skills will use this information to fulfil our contract with the Education and Skills Funding Agency (ESFA), on behalf of the Secretary of State for the Department of Education (DfE).

Your personal information is used by the DfE to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009

Where you are participating in any activity with us that is 2 hours or more, the DfE will create and maintain a unique learner number (ULN) and a personal learning record (PLR) using the data in your enrolment form. This is then securely uploaded to the government’s Individual Learning Record (ILR) system by Step2Skills. Where you are participating in an activity below 2 hours, we will only need to collect your name, date of birth and post code. This is to check eligibility; prove engagement activities have taken place, so Step2Skills and their delivery partners can be funded; and to support the evaluation of the Multiply project. The DfE will be using the data to see if people have moved into other learning above 2 hours that is then registered on the government’s Individual Learning Record (ILR) system – see above.

Either Step2Skills, their partners who are delivering Multiply or the DfE will contact you after you have completed your learning with us, to find out what you did next. This helps us show the impact of your learning and is part of our funding requirements.

How we collect the information

Your enrolment information will be processed directly by the Step2Skills delivery team, or via our delivery partners at the time of enrolment, depending on who you do your learning with. Our delivery partners are subject to our strict data management controls and enter your data onto our management information system. They then send your enrolment form and any signed learner agreement to us, after the course and we file this securely. For online courses where enrolment cannot take place in person we may require submission of identification evidence, to be sent via email or upload. Such documents will be stored securely and will be destroyed as soon as the receiver logs what they have seen and on what date. For documents uploaded to our online enrolment system the destroying of documents is an automated process, however if you send any documents over email, you will be notified that the evidence has been destroyed by return of email.

All other information we collect will be done via consent with you at the time we ask for it e.g. publicity information, permission to have photos taken.

What we will do with your information

The information you give us will be held by Step2Skills. We are legally obliged to collect this information to satisfy our contract with the Department for Education, for Ofsted and for our equality duty as set out in the Equality Act. We will only share your information with third parties who support us to deliver these contracts:

• The Department for Education who funds us and the European Social Fund (ESF) where applicable (where they match funding)
• A delivery partner who we fund to deliver your learning – this is your learning provider for the course you do. You will know who that is because you will enrol with them directly.
• The organisation who may contact you to find out what you did after your learning with us (a requirement of our funding). This could be J2 Research who Step2Skills have a contract with to do this work, or it could be another agency contracted by the Department for Education directly.
• The management information system provider – Monterpoint. We upload data for our funding body through this system
• The exam board – if you are taking exams with us
• The online assessment, enrolment system and/or learning platform you use with Step2Skills or our delivery partners (where strict data protection rules apply)

We will share information with other third parties only if it is in the interests of health and safety or safeguarding. We may also share information with the police or other agencies if it is necessary for the following purposes:

• the prevention or detection of crime
• the apprehension or prosecution of offenders
• the assessment or collection of any tax or duty or any imposition of a similar nature

How we keep your data safe

Delivery partners and the Step2Skills team input your data to our Management Information System once you have enrolled. Enrolment paperwork is sent to Step2Skills to be securely stored in a locked facility and then securely archived. Your course paperwork is held locally by your learning provider, who also keeps this secure.

How long we will keep your information

All supporting documentation evidencing the delivery of the ESF project must be kept for a period of three years from 31 December following the submission of the accounts in which the expenditure of the programme is included. The retention of Documents date is currently 31 December 2034, but you will be notified of any change to this date.

The ESF (European Social Fund) guidance on retention is here

What are your rights?

Hertfordshire County Council will be the Data Controller for this information.

You have the following rights in relation to this data:

• You have the right to be informed about what information we hold about you and how we use it.
• You have the right to request copies of any information the Council holds about you by making a subject access request.
• If information we hold about you is factually inaccurate you have the right to have it corrected.
• You have the right to object to the way we are using your data.
• You have the right to request that your data is deleted. However, we may be unable to delete your data if there is a need for us to keep it. In this case you will receive an explanation of why we need to keep the data.
• You can also request that we stop using your data while we consider a request to have it corrected or deleted. There may be some circumstances in which we are unable to do this however we will provide an explanation if this is the case.
• In certain circumstances you may also request data we hold about you in a format that allows it to be transferred to another organisation.
• In the event that decisions are taken using automated processes you have the right to request that these decisions are reviewed by a member of staff and to challenge these decisions.

If you would like to request copies of your data, request that your data is deleted or have any other queries in relation to data which the Council holds about you please contact the Data Protection Team.

Data Protection Team
Hertfordshire County Council
County Hall
Pegs Lane
SG13 8DQ
Tel: 01992 588099

You can also contact our Data Protection Officer at or in writing to the address above.

If you are unhappy with the way that Hertfordshire County Council has used your data or with the way we have responded to a request you also have the right to contact the Information Commissioner’s Office

Step2Skills have data protection guidance which is available on request.

October 2022

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