Starting Off are committed to transparency, protection and respect in relation to your data. With this in mind we have put together this policy to give you an overview of:
- What information we gather
- When and how we collect it
- Why we need it and what we use it for
- Where we keep it and how long for
- Your rights in relation to your personal information
- How you go about exercising your rights
Each time we collect data from you, we should be making you aware of what we will be doing with that information. Our data collection forms will typically state the information given here in more detail, but any questions can be sent to our Data Protection Officer (details at the end of this policy).
By using our services you are agreeing to the terms of collecting and processing your data. This policy may change from time to time, you can check our website for the latest version, but Starting Off will ensure your rights and freedoms will always be respected in terms of your personal data.
How we collect information
We obtain information about you if:
- You use our contact form on our website
- You apply for a job on the National Apprenticeship Service website
- You contact or visit us directly
We also use a specialised search engine (Broadbean) to find potential candidates from CV databases and social/professional networks to get in contact with you. We do not store any data about you unless you are interested in using our services or consent to our marketing.
Do we share your data?
Starting Off do not sell any data to any 3rd parties.
We do share some personal information with 3rd parties for the sole purpose of providing you with services in relation to your apprenticeship such as:
- Registering your details with government or examining bodies
- Setting you up with an e-Portfolio
- Creating user accounts on Virtual Learning Environments
Security is a primacy concern of Starting Off and every system we use that contains your personal information is checked and monitored to ensure compliance to data protection regulations.
What we collect and what we use it for
Recruitment - Clients
If you are a company asking us to recruit for you, the type of personal information we require will be your contact details (as well as the contact details of anyone else relevant in the organisation) and your signature confirming acceptance to the terms of business.
Recruitment – Individuals
If you are an individual asking us to find you a job, the type of personal information we require will include your name, address, contact details, date of birth, qualifications and school history, skills and work history, work interests, hobbies, referees, National Insurance number, your CV, copies of certificates and any special requirements you have for work placement or interview.
Our recruiters may also note additional information about you during the registration interview regarding gaps in CV or store a photo or physical description of you as a reminder of who you are.
As part of our equal opportunities policy, Starting Off reformat all our candidate’s CVs to include only: your first name, your skills, your education, your work experience, your personal statement and our feedback on your interview. Only these reformatted CVs are shared with our clients.
We may also send your first name, age, and a brief description about you as part of our monthly newsletter to a group of clients interested in recruiting new talent.
In very rare circumstances, our enhanced-security clients may ask for additional ID such as a copy of your passport, drivers licence, proof of address or birth certificate. Starting Off authenticate this document and send to the client without storing it on our own systems.
For every interview you attend, we try to obtain feedback from the employer. This is shared with you and stored on our recruitment system.
For 16-18 year old’s, we encourage parents or guardians to get involved in the process. We ask for your consent to contact the next-of-kin to keep them informed of your progress.
Employers who register an interest in or have used our services, will be asked for consent to be part of our mailing list. If you accept you will receive one email per month highlighting talented young job-seekers and infrequent emails about events that we may be running.
Starting Off may also source contact details for the purpose of marketing through reputable 3rd party data collectors. We will use these contacts to promote our apprenticeship programmes and the Apprenticeship Levy scheme.
Candidates who register an interest in or have used our services, will be asked for consent to be part of our mailing list. If you accept you will receive infrequent emails detailing events or promotions we are running.
You can opt out of all our mailing lists at any time by:
- clicking the unsubscribe link on an email you receive
- changing your preferences here: https://portal.tracker-rms.com/START/gdpr.asp
- contacting our Data Protection Officer (details at the end of this document)
Apprenticeships / Training
We have further data requirements for those on an apprenticeship training programme which can include:
Health Details & Ethnicity
Details on your health (i.e. mental or physical disabilities) and your next-of-kin, or anything that could be considered important to know to maintain your wellbeing or support your learning is shared with those at Starting Off who interact with you.
We record your ethnicity as we have Government set targets for equal opportunities. We use these figures to determine if we need to take positive action.
Your ethnicity and health data are shared with the Department for Education for their statistical reporting.
Your portfolio will contain most of the information captured at recruitment, plus details on your apprenticeship, learning style and achievements. As you progress in your qualification, you may potentially add additional private information as evidence of your learning.
If you are using our online e-portfolio system, it will be accessible to you, your assessor(s), your manager at work, our Internal and External Quality Assurers and to the administration team at Starting Off.
If you are using a paper-based portfolio, it will be in your possession for the majority of your apprenticeship. Starting Off may take responsibility for it at certain stages, in which case it will be afforded the same level of access as an online portfolio.
Additional Proof of Identity
Learners who sit exams for the IT qualification under the BCS awarding body may need to provide photographic forms of identification which will be copied and stored securely by Starting Off to comply with the contractual obligations of the awarding body.
Feedback / Surveys
Both apprentices and employers will be invited to provide feedback on how Starting Off have managed the apprenticeship upon completion. We use this information to improve the services we provide.
The Education Skills Funding Agency and the Department for Education may also contact you to obtain feedback on our performance.
How long we keep your data
Starting Off have legal obligations to retain learner data and evidence of employment/training for apprenticeships for the Educational Skills Funding Agency and Department for Education. Therefore your personal data in terms of who you are, what job you did, what qualification you chose, your health & ethnicity, and most of the paperwork you complete must be kept by us for the period specified by those government agencies (typically at least 8 years).
We also have contractual obligations to retain evidence of your training and assessment for our awarding bodies (typically at least 3 years after you complete your programme).
Any data that is kept for contractual, legal or audit purposes is protected with limited access.
Data not required for legal or contractual obligations (i.e. recruitment data where we did not successfully place a candidate) is kept for 2 years from the date of last contact as part of internal KPI monitoring and business intelligence. The exception to this would be recording data for the purpose of blacklisting candidates or employers for legitimate business purposes where data is kept for 7 years.
Your rights under data protection legislation are detailed below. If you have any queries about your personal data, or wish to exercise any of these rights, please get in contact with our Data Protection Officer (details below).
Right to be informed
You have the right to know whether or not we process your personal data as well as details on what we do with that data. This is laid out in general in this document, but you can request details specifically relating to your data also.
Right of access
We will provide you with a copy of all your data upon request, free of charge, providing this does not impact on the rights and freedoms of others. If there are any instances where we cannot provide you with data you will be informed of the reasons.
Right to rectification
You have the right to have any inaccurate or incomplete personal data about you to be rectified or completed.
Right to erasure
In some circumstances you have the right to the erasure of your personal data. Those circumstances include when the personal data is no longer necessary in relation to the purposes for which it was collected; or the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
Instead of deletion, we may elect to anonymise your data where any personal details are changed in a way that they can no longer link back to you in any way. We may do this if the data relating to actions on your account are valid for our KPI reporting or business intelligence.
Right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it, with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another person, or for reasons of important public interest.
Right to data portability
You have the right to receive personal data you have provided in a structured, commonly used and machine-readable format, or to have that data transmitted directly to another controller. Starting Off may need to retain some information for our own legal or contractual obligations.
Right to object to processing
For where we process data for legitimate business interests (i.e. KPI reporting or business intelligence), you have the right to object to this processing. If you make an objection, we will stop processing your personal information unless we can demonstrate legitimate grounds for doing so which override your interests, rights and freedoms.
Rights related to automatic decision making and profiling
Starting Off have no fully automatic decision making / profiling systems. We use the data you provide us at registration as part of a search engine when looking for potential candidates, but all decisions are made by humans. You do have the right to object to us using your personal information in this way.
Our two offices are located at:
Starting Off, 3-5 Wood Hill, Northampton, Northamptonshire, NN1 2DA
Starting Off, 4 Victoria Street, Northamptonshire, NN16 OBT
Our UK registration number is: 03755326 under the Northampton address above.
If you have a query or request in relation to your data or your rights, you can contact our Data Protection Officer, Jordan Banks:
By phone on 01604 622855
By post to the Northampton address above
By email to: firstname.lastname@example.org