Westminster CLIC

Care Leavers into Careers: Privacy notice

What does Catch22 do?

Catch22 is a social business. We design and deliver services that build resilience and aspiration in people and communities across the UK.

We’ve been a charity for 200 years. Today our teams work across children’s social care, deliver alternative education, get people into work through apprenticeships and employability programmes, build stronger communities through social action, and deliver social justice and rehabilitation services (in prisons and in the community). You can find out more about what we do here.

But we don’t just stop at changing lives on the frontline. We take any surplus and the learning from our delivery, and funnel that into public service reform – investing in new structures and programmes that do things differently and change the system for good.

Catch22 Charity Ltd are the data controller for the personal information we hold about you and we are mainly responsible for deciding how we hold and use data about you.  These decisions are based on what is required by law or specified business need and as such we must be able to explain and justify what information we are gathering, how it is going to be used and how long we are going to keep it for. We will only use your data when the law allows us to.  The law says that we must identify a lawful basis for each use of your data and we are required to make you aware of what that is and what rights you have.  For this purpose, we have set out the following privacy notice outlining how we use your data and how that complies with the law.

What is the CLIC (Care Leavers into Careers)?

CLIC (Care Leavers Into Careers) is delivered by Catch22 for Unemployed CEYP (care experienced young people). The programme aims to support CEYP into positive destinations, whether that is employment, education, or further training.

We will help break down the barriers that CEYP face when looking for opportunities. This includes connecting CEYP with employers following up-skilling, which would include Barclays LifeSkills workshops delivered by the team – covering money management, CV building, interview skills, and more.

In order for us to run our programme we need to know information about you.  You will see on the following pages information that tells you what we will need, why we are doing it and what happens to it.  We don’t need your consent to do most of this because by signing up to the programme we are required to collect this information.

All information that is share with the programmes funder is fully anonymised and does not identify any of the programmes participants.

Details collected

For information on all of the information collected, the reason it is collected, who it is shared with, and how long it will be held for, please see the full privacy notice attached at the bottom of this page.

Frequently asked questions

Where did we get your data from?

All of the information we hold about you comes from you. Additionally, though we may/will hold information that has been gathered from third parties where relevant including: –

• Employers
• Apprenticeship providers
• Education providers
• Training providers

Who will we share your information with?

We will ask your consent to share information with any third parties and your adviser will explain this to you and ask you to sign a consent form for what you are prepared to share and with whom.

We will only disclose information about you to third parties without your consent if we are legally obliged to do so.

How long will we hold on to your information for?

We hold data securely for the set amount of time shown in the table above.  Where we hold information required by law or on the basis of legitimate interest then we will default to 6 years unless otherwise required.

Where your information is only held on the basis of consent then if you withdraw that consent we will no longer use your information and we will delete it from your record.

What happens in the information in the records is wrong?

You will need to be specific about why you think the information is wrong and what you think we should do to correct it. If you can prove the information is incorrect, we will change it. If we cannot amend your record in the way you would like, we will explain the reason for this. You will be able to see a copy of your amended record.

What rights do you have over the information that we hold on your behalf?

You have several rights over your data that we are required by law to uphold. You have the following rights:

• The right to access your data: You have the right to request a copy of your data provided that your request is not unfounded or excessive. We are required to provide you with this within one month of your request. In order to request your data, please contact dpo@catch-22.org.uk
• The right to withdraw your data: Where we require your consent to process information then you have the right to withdraw that consent at any time.  If you are unclear where or when this right applies please contact dpo@catch-22.org.uk for advice.
• The right to lodge a complaint with the Information Commissioners Office (ICO): You have the right to make a complaint to the Information Commissioners Office (body that regulates Data Protection) if you feel that we have not processed your data correctly and in accordance with relevant law. Please feel free to make us aware of any concerns that you have, we will look to fix any issues quickly and efficiently. Please visit https://ico.org.uk/ or call 0303 123 1113 in order to lodge a complaint with the regulator.

Talk to us

If you have any concerns about the way in which your information is used when working with us, please feel free to contact Catch22’s Data Protection Officers on the following email address DPO@catch-22.org.uk

Last updated:

We may need to update this privacy notice periodically, so we recommend that you revisit this information from time to time. This version was last updated August 2023

Privacy notice

How we manage your data

Catch22 Charity Ltd. manages the data you provide in accordance with the EU General Data Protection Regulation (GDPR).

• The Data Controller (the organisation that determines how your data is managed) is Catch22. Contact us if you have a query about how your data is managed.
• The Data Processor (the organisation that does data processing on behalf of Catch22) is Totally.Tech.
• We are committed to giving you (the Data Subject in legal terms) an easy way to exercise your eight rights under the GDPR.
• We retain your data for as long as you allow us to do so. You can exercise your right to erasure at any time however, there may be some instances where we need to retain your information for a longer duration for legal reasons, such as when applying for a job with Catch22.
• Catch22 uses Click4Asistance as an online chat tool. By providing information, you consent to Click4Assistance collecting and processing this information according to their privacy policy. 

What information do we collect?

Catch22 may collect, store and use the following kinds of personal data:

• information about your computer and your visits to and use of this website, including your IP address, geographical location, browser type, referral source, length of visit and number of page views (cookies),
• information that you provide to us for the purpose of applying for a job or receiving job alerts (job applications / job alerts),
• subscribing to email newsletters including your name and email address (email newsletter),
• If using our online chat service Click4Assistance, information such as IP addresses, and chat transcripts will be collected. If you choose to provide them, personal data such as names, email addresses will be collected, or
• information that you submit that relates to a complaint, service feedback or enquiry (complaints / feedback and enquiries).

Specific detail of each processing activity is provided below.

Cookies

Cookies are text files that are stored on your web browser by a website’s server. Each cookie is unique to your browser, and will contain some anonymous information such as a unique identifier and the website domain name. This information is sent back to the server each time your browser requests a page from it. This enables the website server to identify and track your web browser via your unique, anonymous, identifier.

Catch22 only uses cookies on its website where they will support the functioning of its website and to improve the experience of its website visitors. These cookies may be created by Catch22’s website, or by third-party services that Catch22 uses, to enable its website to be run effectively.

Some, ‘necessary’ cookies are essential to the running of our website and are exempt from the requirement of consent as per the GDPR and PECR. Functional, analytical and advertising cookies are all optional, and we will only store these cookies on your browser where we have received your freely-given, specific, informed, and unambiguous consent.

Any information that is collected by Catch22 via cookies is processed in a way which does not, and cannot, identify an individual person. We do not make any attempt to find out the identities of those visiting the Catch22 website.

You can find out more about Catch22’s use of cookies, and how to opt-out of or delete cookies from your browser via our Cookies Statement.

Job applications

If you apply for a job with Catch22 using our hosted online job application system, this service will be provided by a data processor on our behalf (SmartRecruiters).

To process your application, we ask for your personal details including name and contact details. We will ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. The hiring managers for the role, along with our Recruitment and HR teams will have access to all of this information.

Catch22 processes your job application data for the purpose of its legitimate interest to process your HR information.

• If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus six years following the end of your employment.
• If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for six months from the closure of the campaign.
• Equal opportunities information is retained for six months following the closure of the campaign whether you are successful or not.

For more information, please see the SmartRecruiters privacy notice.

Job alerts

Through the SmartRecruiters job application system, it is also possible to sign up for job alerts, which will let you know when new jobs that meet your criteria have been posted.

These alerts are managed by the data processor (SmartRecruiters) on our behalf, and will only be processed using your freely-given, specific, informed and unambiguous consent.

If at any point you wish to unsubscribe from SmartRecruiters job alerts, this can be done by clicking the unsubscribe link on the latest email. You can also log into your SmartRecruiters candidate profile to modify or withdraw your details.

For more information, please see the SmartRecruiters privacy notice.

Email newsletter

If you subscribe to Catch22’s newsletter and/or event mailing lists, you will receive regular communications relating to our work. These mailings will be facilitated by a third-party provider, such as Mailchimp or Salesforce (marketing platforms), and your data will be processed by a third-party client relationship management platform, Salesforce.

Catch22 will only process your contact details and send you newsletters following your freely-given, specific, informed and unambiguous consent.

You have the right to unsubscribe from any of our email mailing lists at any time. If you wish to unsubscribe from a Catch22 mailing list please click the unsubscribe link on the latest email or contact dpo@catch-22.org.uk to ensure that you do not continue to receive email newsletters from us. We will need to continue to hold your details after you have unsubscribed to ensure that we do not send you further communications.

For more information, please see the Mailchimp or Salesforce privacy notices as appropriate.

Feedback and enquiries

Catch22 processes the data submitted through any of our website contact forms for the purpose of receiving your message and responding to it under the lawful basis of consent, which you give when submitting the form.

We will only use the information supplied to us to deal with the enquiry and any subsequent issues, and to check on the level of service we provide.

These contact forms are processed using the WordPress plugin, Gravity Forms. When these forms are submitted to us, notification emails are automatically generated to send your enquiry to the appropriate team within Catch22 who will store your email for as long as is required to deal with your enquiry and any subsequent issues.

Form submissions are also stored within the Catch22 WordPress database for a period of 90 days. This allows us to identify if there are any issues with forms being received by our teams. After this time, forms and all accompanying personal data are automatically deleted from the system. Gravity Forms does not receive copies of any of forms, or any accompanying personal data, that are submitted via the Catch22 website.

If using our online chat service, Click4Assitance, data collected through the chat service may be shared internally within Catch22  to provide support and improve services. 

You have the right to withdraw consent for us to contact you at any time by contacting dpo@catch-22.org.uk. You also have the right to lodge a complaint with a supervisory authority, which in the United Kingdom is the Information Commissioner’s Office.

For more information, please see the Gravity Forms privacy notice.

Complaints

Complaints can be submitted using our online feedback form, by emailing feedback@catch-22.org.uk, or by post. Catch22 undertakes the processing of your complaints data as part of its legitimate interests.

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for six years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘data minimisation’ principle.

For more information, please see the Complaints, Compliments and Feedback policy.

Donations

Donations made through our website are processed securely via PayPal. By making a donation, you confirm that you are 18 or over and that the payment details you provide are your own. All donations are final and non-refundable, unless required by law. Please check your information carefully before completing your donation. Once your donation has been processed, you’ll receive confirmation via email from PayPal.

Your donation will help Catch22 continue its work across our programmes and services. Unless stated otherwise, donations will be used where they are needed most to support our charitable objectives. If a specific project or appeal becomes fully funded or cannot proceed, we may use your donation for a similar purpose to achieve the same charitable outcomes.

When you make a donation, we collect and process your personal information in line with our Privacy Policy. This includes your name, contact details, and payment information, which is processed securely by PayPal on our behalf.

Use of data processors

The Data Processor (the organisation that does data processing on behalf of Catch22) is Totally.Tech.

Catch22 also works with third-party data processors to provide our:

• content management system (WordPress),
• website analytics (Google Analytics and Microsoft Clarity),
• marketing platform (Mailchimp),
• client relationship management platform (Salesforce),
• social media advertising campaigns (Meta Pixel, Twitter Pixel, LinkedIn Insight Tag, TikTok Pixel),
• online chat service (Click4Assitance), and
• recruitment service (SmartRecruiters).

We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it and retain it for the period we instruct.

Individual Catch22 services may work with additional third-party data processors in line with their contractual requirements. For more information, please see the relevant Service Privacy Notice, which can be downloaded from their service page on this website, or found by searching for the service by name in our Policy Library.

Disclosures

Catch22 may disclose information about you to any of our employees, officers, agents, suppliers or data processors insofar as reasonably necessary for the purposes as set out in this privacy notice.

In addition, we may disclose information about you:

• to the extent that we are required to do so by law,
• in connection with any legal proceedings or prospective legal proceedings, or
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Except as provided in this privacy notice, Catch22 will not provide your information to third parties without your consent.

Security of your personal data

Catch22 will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure, encrypted password and firewall protected servers. As data transmission over the internet is inherently insecure, we cannot guarantee the security of data sent over the internet.

Where information is held on our behalf by data processors, we will ensure, to the best of our ability, that they hold your information securely and in line with data protection legislation. We hold contracts with all data processors to make sure that they cannot do anything with your data unless we have instructed them to do so.

Notice amendments

We may update this privacy notice from time-to-time. Check this page occasionally to ensure you are happy with any changes.

Your rights

Please contact the Data Protection Officer if you have any queries regarding this Privacy Notice or if you would like to exercise or query any of the following rights afforded to you under the General Data Protection Regulation (GDPR):

• right to access
• right to erasure
• right to object
• right to rectification
• right to be informed
• right to restrict processing
• right to data portability
• rights in relation to automated decision making and profiling
• right to lodge a complaint with the Information Commissioners Office (ICO) – via the Complaints page on the ICO website or by calling 0303 123 1113

For further information on your rights, please visit the Individual Rights page on the ICO website.

Contact

If you have any questions about this privacy notice or of our treatment of your personal data, please email dpo@catch-22.org.uk or write to:

Data Protection Officer

Catch22
27 Pear Tree Street
London
EC1V 3AG

Data controller

Catch22’s data protection registration number is Z1473239