Click Start by Bath Spa in Creative Digital Skills

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.

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), 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.

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.

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),
• marketing platform (Mailchimp),
• client relationship management platform (Salesforce),
• social media advertising campaigns (Meta Pixel, Twitter Pixel, LinkedIn Insight Tag, TikTok Pixel), 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

Click Start: Privacy notice

Who we are

This privacy notice explains how we receive and use personal information for the Click Start programme, an initiative funded by Nominet. The University of Bath is the lead partner for the Institute of Coding (IoC) and will be responsible for receiving and processing data about applicants, participants and employers connected with the projects which make up the Click Start programme for evaluation purposes.

Click Start is an initiative designed to support people into technology and digital roles through education. It seeks to focus on diversity of talent and equality of opportunity to support learners from disadvantaged backgrounds to take up digital skills. Through the provision of inclusive technical training (courses) alongside tailored personal and professional skills support, this programme will combine best practice in digital skills provision with wraparound support.

The primary beneficiaries of the Click Start Programme will be 26,500 learners who engage with our programme, 25,000 of whom will receive broad outreach support. A further 1,500 learners will receive personalised 1:1 support.

The Institute of Coding is a group of industry, government, higher education and outreach partners who have come together to create more than 150 new courses that have engaged 900,000 diverse learners to date. Our partners have created a variety of courses (many of which are online) so you can keep learning wherever you are in your life or career.

Personal information and Click Start

For the purposes of relevant data protection legislation, the partner collecting data for each project funded through the Click Start programme is the data controller.

We, University of Bath, will process data on applicants, participants and employers, but these data will be anonymised before they reach the Institute of Coding so we will be unable to identify individuals.

Please see each learning provider’s Privacy Notice for detailed information on:

• why they are collecting your personal information
• which information will be collected
• the legal basis for this data collection
• how your information will be used
• how long the information will be stored
• who will be able to see your personal information
• how you can request to access, rectify or erase your information from their records

Personal information and University of Bath, the Institute of Coding

The University of Bath, the lead partner in the Institute of Coding (IoC), will receive, analyse and store the data outlined in this Privacy Notice in connection with the Click Start programme. We will share this data with our externally appointed evaluators for the purpose of analysis.

Data collected by each learning provider will be anonymised and shared with the Institute of Coding to:

• build up a picture of those interested in and/or registered to participate in the programme
• review the status of learners towards completion of their training at various stages
• review pre- and post- course survey data to assess how successful the programme has been
• analyse the outcomes and impact for learners and employers as a result of engagement with the programme

Your personal, individualised data will not be available to the Institute of Coding or any other partner within the Institute of Coding consortium. Aggregated, anonymised and summarised data may be shared with Institute of Coding consortium partners and Nominet (the funder) to support the development of best practice.

Why we collect information

We are collecting information on ‘Click Start’ applicants, participants and employers for the purposes of helping us understand how well the courses are working and whether they are achieving their anticipated outcomes.

Consent for marketing or evaluation purposes

If you have given your consent to either be added to Institute of Coding mailing lists or to be given further information about the Institute of Coding’s Ambassador programme, your contact details will be passed to the Institute of Coding and used for this purpose until you ask us not to send you further information.

If you have consented to be contacted by either the Institute of Coding or our externally appointed evaluators for the Click Start programme for the purposes of evaluation, your contact details will be passed to the Institute of Coding and shared with the external evaluators. We will keep your contact data for a maximum of 5 years, after which time they will be securely destroyed.

If you wish to withdraw consent at any time, please contact both your training provider and ioc@bath.ac.uk.

For further information please contact the University of Bath Data Protection Officer:

David Jolly, Office of Policy & Planning, University of Bath, Claverton Down, Bath, BA2 7AY

dataprotection-queries@lists.bath.ac.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 February 2023