1. Introduction

Serco Limited has been selected to deliver a Digital Careers Upskill Programme commissioned by Greater Manchester Combined Authority (GMCA). Serco is based at Serco House, 16 Bartley Wood Business Park, Bartley Way Hook, Hampshire, RG27 9UY.

This Privacy Policy (“Policy”) is issued by Serco (referred to hereafter as “Serco”, “our”, “we” and/or “us”) for the Digital Careers Upskill Programme, for and on behalf of Serco where we are acting as a data controller (independently of GMCA).  Where GMCA are acting as a data controller and we including our delivery organisations) are acting as their processor, please find below a link to GMCA’s privacy notice for Skills for Growth – Skills Delivery (“GMCA’s Policy”).  The Digital Careers Upskill Programme offers support to Greater Manchester residents for digital reskilling to allow them to undertake training that will assist in obtaining better quality employment in digital roles or in digital upskilling to help those in existing digital roles learn new skillsets to progress at work. We have developed this Policy to ensure you (a participant of the programme) are informed and confident about the security and privacy of your personal information for the personal data we are a data controller of. This is in addition to GMCA’s Policy.

This Policy is to help you understand how Serco collects, uses, discloses, holds and safeguards the personal information about you.  It also explains your rights in relation to your personal information and how to contact us or the Information Commissioner’s Office in the event you have a question, concern, or feedback. Please read this Policy carefully as it contains important information.

2. Who Is Responsible for Your Personal Data

For the purposes of the relevant data protection legislation and this Policy, Serco is an independent controller for personal data, which is necessary for the Digital Careers Upskill Programme, and for our purposes as the training provider. For example, Serco is data controller for some of the personal information that is also collected for GMCA as the data controller such as your name, contract details or for additional personal data such as your aspirations/career goals.

Serco is registered as a data controller with the UK’s Information Commissioner's Office and our registration number is Z5746980. Our programme and/or website may provide links, promote or signpost to other independent third-party websites, plug-ins or applications. Those third party are not always under our control. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the conduct of third-party companies linked to the programme or the website or the contents of their privacy notices. You should refer to the privacy notices of these third parties as to how and why they may handle your personal information. When you leave our website or before you enable any connection, we encourage you to read the privacy notice of every website, plug-ins or applications you visit or wish to use.

GMCA

Where GMCA is an independent data controller of the personal data which is collected, used and/or shared between Serco and GMCA as part of delivery of the Digital Careers Upskill Programme, please refer to GMCA’s Privacy Notice for Skills for Growth – Skills Delivery for details of how they manage your personal information:

View GMCA Privacy Notice for Skills for Growth – Skills Delivery

3. Personal Data Collected

When using the term “personal data” or “personal information” in this Policy, we mean information (including opinions) that relates to you and from which you could be identified, either directly or in combination with other information which we may have in our possession.

We will collect, store, and use the following (not exhaustive) type of personal information about you:

• Personal and Employability Details: title, full name, contact address and postcode, contact number, email address, date of birth, signature, employment, education and training details

• Identification Information: National Insurance Number

• Correspondence: responses, comments, feedback and opinions when you communicate with us for instance when making a complaint
• Assessments: Skills assessment, needs assessment related to joining the programme, Learner Plan and meeting notes, progression details, attendance records
• Preferences: permissions, or preferences that you have specified
• System Identifier s: e.g. IP address, device identifiers, login attempts, date and time for accessing our or our commissioned third-party platforms and/or apps and any personal data collected through cookies

Please note, you do not have to provide your personal information to us. However, if you do not provide your personal information which we ask for and require for the programme, we may not be able to: provide you with the support that you require under the programme, or meet the necessary requirement of the programme; or respond to enquires that you may have (list not exhaustive). 

4. How Your Personal Data Is Collected

We will obtain your personal data in different ways:

• We collect information directly from you in various ways including over the phone, face to face, via email, or online portal or directly from or through GMCA’s other partners delivering their wider Digital Skills Programme
• We collect information during normal course of our relationship with you (e.g. when we have our initial assessment meeting and through managing your delivery through the programme etc.)
• We collect information that was made public by you (e.g. contacting us via a social media platform)
• Personal data may also be created by us, such as records of your communications with Serco

5. How and Why We Use Your Personal Information

We will collect, use and share your personal information where we have a legal justification to do this and the processing is necessary. The legal justification depend on the purpose of the personal information is collected and its processing requirements. The legal justification on which we rely on to process your personal information includes:

• To fulfil our contractual obligations to you, including delivering the programme content
• To exercise our legal rights with respect to our contract with you
• Where we have consent (on occasions we may ask you for consent, we will use the data for the purpose which we explain at the time) or where the information is made public by you
• To exercise our functions and to meet our legal responsibilities, including for the performance or exercise of a public task (including for and/or on behalf of a government department (e.g. GMCA)
• For the purposes of employment, social security and social protection law
• For the purpose of equal opportunity monitoring
• For the purposes of any measures we are required to take from time to time during a national or international emergency (for example during a pandemic) and to comply with national laws for humanitarian purposes including for monitoring epidemics, pandemics and their spreaWhere processing is necessary for reasons of substantial public interest to fulfil a function of a government department (e.g. GMCA) including but not limited to equal opportunities monitoring and/or preventing and/or detecting unlawful acts
• In response to requests from government law enforcement authorities conducting an investigation
• Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business e.g. in the framework of tax control and reporting obligations

Where necessary for Serco’s or third parties legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, such as:

• To effectively manage and deliver our services to you, including sharing your information with relevant partners and service providers in connection with delivering these services
• To comply with our GMCA contractual obligations, including to verify details of Learners who achievement outcomes as part of the Digital Skills for Growth programme, in order for Serco to receive payment from GMCA
• To contact you and manage any enquiries, complaints and feedback
• To enhance, modify, personalise or otherwise improve our services / communications for the benefit of our customers
• For promotional purposes
• To ensure programme procedures are adhered to, e.g. programme induction, completion of Learner Plans
• For business analysis purposes and to develop our business strategies
• In connection with establishing, exercising or defending our legal rights in the event of a claim and compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with the legal process or litigation)

Where we need to use your personal information for any other purpose, we will let you know at the time we collect your personal information or as required or permitted by law.

Serco sometimes handles personal information relying on exemptions under the applicable data protection law.  Any permitted handling of personal information under such exemptions will take priority over this Digital Skills for Growth Privacy Policy to the extent of any inconsistency.

6. When Is Sensitive Data Collected and Used?

We may on occasions process your special category information.

We will primarily collect this information in the following scenarios:

• Where you choose to share special category information in your communications with us

Collection of this information will not affect whether your will be accepted onto the programme.

Where required by applicable laws, we will take steps to have in place an appropriate policy document and safeguards relating to the processing of such personal information.

7. Cookies

We use cookies on our website. Cookies are small text files that are downloaded onto your device when you visit a website. Please refer to our cookies policy for further information about our use of cookies.  Cookies only record the areas of our website that a computer/device has visited. If you do not want a cookie you can set your browser to deny it or visit our cookies policy for further details. 

8. CCTV

Where there are closed circuit television (CCTV) in operation in and around our sites, and offices for (but not limited to): (i) public and worker health and safety; (ii) security; and (iii) crime prevention and detection, then for these reasons, the information processed may include visual images of personal appearance and behaviours.

We display signs to inform visitors and workers that they are under surveillance and there may be video recording in operation. This information is kept in secure environments and access is restricted to Serco’s designated workers.

9. Sharing Your Personal Information with Others

As set out above in section 2, we operate this programme on behalf of GMCA. We will share your personal data with them as part of delivering the services as their processor and in some circumstance where it is necessary as independent data controller. You may also be contacted for evaluation and research purposes by GMCA (or an organisation acting on its behalf) details of which will be contained within the GMCA Skills for Growth – Skills Delivery Privacy Notice.

We will disclose your personal information to other third party in certain circumstances such as where it is a contractual obligation or where we are permitted to do so by law. On some occasions, these third parties may also be a controller of your personal data. The other third parties we may share your personal data with includes:

• Your employer or organisation engaged for the purpose of the Digital Careers Upskill Programme (excluding Serco’s subcontractors)
• Other government department or public body (e.g. local authorities)
• Our third-party providers who help deliver or run our system and business (e.g. system provider)
• Our professional advisors (e.g. legal advisor, insurers, auditors) or third-party providers engaged by us to conduct research and evaluation of the programme and the services we provide to you
• Government, regulatory and law enforcement bodies where we are required, in order to comply with our legal obligations; to exercise our legal rights and/or for the prevention; detection and investigation of crime
• Other organisations within the Serco group of companies, where such disclosure is necessary to provide you with our services or to manage our business
• Our subcontractors who operate under contract to Serco to deliver the Digital Careers Upskill Programme

We may disclose your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale or GMCA changes service providers. Serco’s contracted third-party service providers are required to take appropriate security measures to protect your personal information in line with our contract and the laws.

Less commonly, we may process and share your personal data with third parties where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

Transferring your personal information outside the European Economic Area (EEA)

We (and our subcontractors who operate to deliver the programme to you on our behalf) do not currently transfer, store or otherwise process personal data, outside the United Kingdom (UK). However, if our business needs change, we will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests.

Serco operated on a global basis. Our standard practice when transferring personal data outside the UK/EEA is to:

• put in place binding corporate agreements, which will include the standard contractual clauses approved by the European Commission and/or the Information Commissioner’s Office for transferring personal information outside the EEA, to ensure that your information is safeguarded
• ensure that the country in which your personal information will be handled has been deemed "adequate" by the European Commission and/or the Information Commissioner’s Office; or the company is registered and compliant with recognised code of conduct or certification scheme
• in the limited circumstances that information is transferred within Serco Group, ensure such transfers are covered by an intra-group data sharing agreement entered into be all relevant entities within Serco Group, which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection and
• carefully validate any requests for information from law enforcement or regulators before disclosing the information

We will co-operate with any regulators as required by law to ensure that we remain transparent about the way we handle your personal information. If you would like further information about the global handling of your personal information, please contact us using the details below.

10. Security of Your Personal Information

Serco takes precautions including administrative, technical and physical measures to safeguard your personal information, including password protected access to IT systems, documented employee procedures, internal monitoring and training to help ensure that your information is protected and secure. Our employees, contractors, and any other third-party providers are bound by confidentiality obligations and we will only allow access to employees and contractors and any other third-party providers where there is a genuine business need.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use robust procedures and security features to try to prevent unauthorised access.

11. How Long Do We Keep Your Personal Information

We keep your personal information for as long as is necessary or for as long as we are required to under our contractual obligations and for the purposes set out in this Policy. Any personal information processed by us will be retained as per our records and retention schedule and will only be used for the purposes for which it was collected. Set out below are summaries of criteria we use to determine how long we will keep your personal information for, thereafter we will either delete or anonymise the data:

• We will retain your information for as long as you are engaged for the services, thereafter it will be retained for another 10 years after the closing of the programme in 2023, unless it needs to be retained for longer 

Where not subject to the above, we will generally keep your personal data in accordance with any applicable limitation period (as set out in applicable law) to allow reasonable time for review and deletion or anonymisation of the personal information held.

12. Your Legal Rights

You have legal rights in connection with personal information. Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
• Request erasure of your personal information (commonly known as the "right to be forgotten"). This enables you to ask us to delete or remove personal information in limited circumstances, where: (i) it is no longer needed for the purposes for which it was collected; (ii) you have withdrawn your consent (where the data processing was based on consent); (iii) following a successful right to object (see Object to processing); (iv) it has been processed unlawfully; or (v) to comply with a legal obligation to which Serco is subject

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for a number of reasons, including: (i) for compliance with a legal or contractual obligation; or (ii) for the establishment, exercise or defence of legal claims

• Object to processing of your personal information by us or on our behalf which has our legitimate interests as its legal basis for that processing, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. You can object at any time to your personal information being processed for direct marketing (including profiling)
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, but only where: (i) its accuracy is contested, to allow us to verify its accuracy; (ii) the processing is unlawful, but you do not want it erased; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or (iv) you have exercised the right to object, and verification of overriding grounds is pending

We can continue to use your personal information following a request for restriction, where: (i) we have your consent; (ii) to establish, exercise or defend legal claims; or (iii) to protect the rights of another natural or legal person

• Request the transfer of your personal information. You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where: (i) the processing is based on your consent or on the performance of a contract with you; and (ii) the processing is carried out by automated means
• Obtain a copy, or reference to, the personal data safeguards used for transfers outside the European Union. We may redact data transfer agreements to protect commercial terms
• Withdraw consent to processing where the legal basis for processing is solely justified on the grounds of consent

If you would like to exercise any of these rights for the data Serco processes as an Independent controller, please submit your requests to Serco via the address below. Please note, to ensure security of personal information, we will ask you to verify your identity before proceeding with any such request.

We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

For any personal information processed by GMCA as an independent data controller, please contact the GMCA direct to exercise your rights in accordance with the contact details within their Skills for Growth – Skills Delivery Privacy Notice. 

13. Data Protection Officer

We have a Data Protection Officer (DPO) to oversee compliance with the Digital Careers Upskill Programme Privacy Policy. If you have any questions about this Privacy Policy or how we handle your personal information, please address to:

Data Protection Officer

Serco Ltd

Enterprise House

18 Bartley Wood Business Park

Bartley Way

RG27 9XB

Alternatively, please email dpo@serco.com or call +44 (0)1256 745900.

Supervisory authority

We would be happy to address any concerns you have about your data privacy directly, and we encourage you to contact us in the first instance with your queries. However, you have a right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/ or call 0303 123 1113) who will then investigate your complaint accordingly.

Changes to the Digital Careers Upskill Programme Privacy Policy

This Digital Careers Upskill Programme Privacy Policy (version 1) was reviewed and updated in November 2021.

We may amend the Digital Careers Upskill Programme Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. If we change this Privacy Policy, we will post the details of the changes on our website. Any changes will be effective when posted. Please regularly check these pages for the latest version of this document.