Privacy Policy/Notice – Humber Internship Programme

The Humber Internships Programme (HIP) supports SMEs based in the Humber region to provide quality work-based placements and internships to students and graduates, and enables students and graduates resident in the Humber region to access work experience through placements and internships within qualifying SMEs.

This privacy notice is for businesses and individuals engaging with the programme. It sets out the ways in which HIP gathers, uses, stores and shares your data.  The notice also sets out how long we keep your data and what rights you have in relation to your data under the General Data Protection Regulation (GDPR).

The project has received £900,000.00 of funding from the European Social Fund as part of the 2014-2020 European Structural and Investment Funds Growth Programme in England. The Department for Work and Pensions is the Managing Authority for the England European Social Fund programme. Established by the European Union, the European Social Fund helps local areas stimulate their economic development by investing in projects which will support skills development, employment and job creation, social inclusion and local community regenerations. For more information visit https://www.gov.uk/european-growth-funding

The purposes of the data processing

The information you provide to the HIP Programme will be shared with the Department for Work & Pensions (DWP) and used to evaluate this project and to report to the European Social Fund for monitoring purposes, in line with European Commission regulatory requirements.

Your information will also be shared with research organisations working on behalf of the Department for Work & Pensions who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary and you will be asked to consent before taking part in any research activity you may be contacted about.

The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left. This information may also be shared with research organisations working on behalf of the DWP however Version 5 published 4 June 2018 individuals will not be identifiable and you will not be contacted about this research.

Data will not be used or shared for any commercial or marketing purposes.

At all times your information will be kept securely, and nobody will have access to it that shouldn’t.

Where do we get your data from?

We collect data about you when you register an interest in the programme.  Much of the data we hold on you comes from the information you provide in your registration form, including documentation that we are required to scan/copy to demonstrate your eligibility for support under the programme.  Information relating to individuals and businesses may have been provided to us by third parties e.g. other funded support programmes for the purpose of providing you with additional and appropriate support.  Where third parties have provided this, we will seek express permission from you that HIP may store this information.

In addition to the information provided, HIP will undertake checks to ensure eligibility.  In the case of SME beneficiaries HIP may obtain documents that are publicly available and through internal systems e.g. FAME.

What data do we hold?

For individuals (students/graduates) – we will hold: personal data including name, address, date of birth, email address and telephone number; special category data including information about disability, ethnicity and racial origin (if you consent to provide this for the purpose of equal opportunities monitoring).

For SME beneficiary owners and/or staff – we will hold personal data including name, job title, company/business details, email address and telephone number; special category data including information about disability, ethnicity and racial origin (if you consent to provide this for the purpose of equal opportunities monitoring).

 What is our legal basis for processing your data?

HIP needs to collect and retain certain types of data, in various formats to fulfil its functions as an enabler of placements and internships and in line with the conditions of our funding.

Typically, data will be processed:

  • Because you have given us consent
  • To monitor equal opportunities
  • On the grounds of contractual requirement or to take steps to enter into a contract with you e.g. to provide you with a funding agreement for support

How do we use your data?

HIP may process your data for the following purposes:

  • To progress your enquiry and/or application for support to provide a placement or internship
    if you are an SME, or secure a placement/internship if you are a student/graduate
  • To enable the programme to effectively communicate with you
  • To administer and progress financial aspects with you including processing claims and payments
  • To provide information on engaged businesses via progress reports to our external funding body – The Department for Work & Pensions (DWP)
  • To monitor equal opportunities

For the purposes of the General Data Protection Regulation (GDPR), the DWP is the data controller in respect to information processed which relates to all participation in the European Social Fund. ESF grant beneficiary organisations are data processors in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund.

DWP is not the controller for any other / additional data collected by the HIP Programme that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by The HIP Programme.

The ESF Programme Action Note 018/18 sets out the lawful basis for processing personal data under ESF.

Who do we share your data with?

HIP may share your data with:

  • Staff directly involved in HIP for the purpose of providing you with appropriate support
  • Employees of the University of Hull for the purpose of providing you with appropriate support
  • Our funding body, the Department for Work and Pensions (DWP) for contractual reasons
  • Other support programmes who may be able to provide you with appropriate support (your details will only be provided to third parties if you give us express permission to do so)

HIP will not share your information externally for any other purpose without your consent.

How do we keep your data secure?

HIP takes information security extremely seriously and has robust systems in place to protect your data.  Access to information is restricted and will only be shared with the parties listed above.  HIP is required to keep printed copies of all paperwork.  This data is held within locked offices and can only be accessed by HIP project staff.

All electronic documents are stored on a secure server at the University of Hull.  Access to documents is restricted to staff directly involved in HIP.  If your information is shared with any of the parties listed above, we will send these securely with password protection via email.

How long will we keep your data?

HIP will retain your data in line with legal requirements or where there is a business need.

If you enquire about HIP or receive support from HIP, this data will be maintained in line with the contractual requirements of the project.  Currently HIP is required to keep this data for 10 years beyond the date of the project’s last financial claim to DWP (currently estimated to be July 2033 but this may change if the project’s end date changes).

All personal data held by DWP or research contractors for the purposes of evaluation will be permanently deleted no more than six months after the research has been completed (i.e. when the final report is published on GOV.UK).

Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK at: https://assets.publishing.service.gov.uk/government/uploads/sy stem/uploads/attachment_data/file/591617/ESF_Guidance_on_ document_retention.pdf

What rights do you have in relation to your data?

Under the General Data Protection Regulation, you have a right of access to your data, a right to rectification, erasure (in certain circumstances), restriction, objection or portability (in certain circumstances). You also have a right to withdraw consent.

If you would like a copy of some or all of your data held by HIP, please email us or write to us at the contact addresses below.

There may be circumstances in which we are unable to erase data held about you, in which case we will notify you.  For example, if you have entered into a funding contract with us, we will be contractually required to keep records for a specified time period for reporting and audit purposes.

If you do not wish your personal data to be used for ESF evaluation purposes please contact ESF.EVALUATIONS@DWP.GSI.GOV.UK  and DWP will delete your data held for these purposes and you won’t be contacted about participating in research.

More information about how and why DWP uses your personal information, including how to ask for a copy of the personal information DWP holds about you can be found in DWP’s Personal Information Charter at: Version 5 published 4 June 2018 https://www.gov.uk/government/organisations/department-forwork-pensions/about/personal-information-charter

Information about how to ask for a copy of the information DWP holds about you (known as a ‘Right of Access Request’) can be found at: https://www.gov.uk/guidance/request-your-personal-informationfrom-the-department-for-work-and-pensions

Questions or concerns

If you have any questions about this privacy notice or concerns about how your data is being processed, please contact us:

By post:

Pauline Mitchell, HIP Programme Manager
Derwent Building
University of Hull
Cottingham Road
Hull
HU6 7RX

By email:

p.a.mitchell@hull.ac.uk

By telephone:

01482 466106

Right to complain

If you wish to make a complaint, please contact the University’s Data Protection Officer in the first instance at dataprotection@hull.ac.uk

If you are unhappy with the way in which HIP has handled your personal data, you have a right to complain to the Information Commissioner’s Office. For information on reporting a concern to the Information Commissioner’s Office, see www.ico.org.uk/concerns

Changes to our privacy notice

We keep our privacy notice under regular review and we will send any updates via email providing you have given us permission to contact you this way. This privacy notice was last updated on 06 January 2021.