Who we are
We are Superfast Business Cornwall an ERDF funded service delivered by Serco Employment, Skills and Enterprise. We deliver this Service under the legal entity of Serco Regional Services Limited (“SRS”), a company registered in England and Wales (Registered No. 01653016). Our registered office is: Serco House, 16 Bartley Wood Business Park, Bartley Way, Hook, Hampshire RG27 9UY. SRS is a wholly owned subsidiary of Serco Group plc. References to “we” or “us” mean Serco Employment, Skills and Enterprise, SRS or Serco Group plc.
What does this policy cover?
We have legal obligations, under the Data Protection Act 1998, to collect any personal information that you provide to us fairly and lawfully. Each time you provide us with personal information we will let you know how we intend to use it. If we are going to use your personal information for any purpose other than identified within this policy, you will be informed via the relevant client terms of business. We will hold your personal information securely and will only keep it for as long as you use the service that you have requested or for as long as our legal obligations specify.
What information do we collect about you?
We will only collect information as is necessary in order for us to effectively communicate with you, to deliver services to you, and to provide contractual monitoring and performance information to our funders. The main types of information we may collect about you include:
- Your name and contact information such as phone and mobile phone numbers, and your email address,
- For the purposes of equal opportunities monitoring, we may ask you questions in relation to equality and diversity but will only collect sensitive personal information with your express permission,
- Your business or home address and postcode,
- Information about your business financial accounts, such as sales figures, turnover, and number of employees
For many businesses your address will be your business address and business contact information, however in the case of sole traders and home-based businesses, and individuals accessing services independently, this may be your home address and personal contact information.
We may also collect the following:
- Information that is publicly available such as filed financial accounts information from Companies House
- If you contact us by email, fax, telephone or post or if you come to see us and leave your details, we may keep a record of that correspondence.
Who will collect your information?
Your information may be collected by people directly employed by us and/or by people employed by organisations engaged by us under a formal, legally binding contract either to deliver specific services to you on our behalf or to seek your opinion about the services you have received. You will be notified of the name of which organisation(s) will contact you, and why they will contact you, at the time you register for our services or at appropriate stages in your relationship with us.
How do we collect your information?
We, or our sub-contractors/suppliers may collect your information either during a telephone conversation with you, when you access any of our or their websites, or via other electronic communication channels, such as in an email, a text message, an internet message, or via social media. We, or sub-contractors and suppliers acting on our behalf, may ask you to complete and sign paper application forms or paper funding or grant claim forms for you to post back to us.
Examples of when your information is collected include when you fill in forms on our websites or web based tools; information provided at the time of registering to use our websites or tools; subscribing to our services; booking onto events; submitting questions; applying for grants/funding; posting material on our social media sites; or requesting further services. We may ask you for information if you report a problem with our websites.
How do we use your information?
We use the information we collect about you to:
- Ensure that content from our sites is presented in the most effective manner for you and for your computer,
- Identify you and to enable us to communicate effectively with you,
- Provide you with information about the services that you request from us or, where you have consented to be contacted for such purposes, about similar services which we feel may be of interest you,
- Verify your identity, when we hold existing information about you,
- Assess your eligibility for the funded services we deliver,
- Carry out our obligations arising from any contracts entered into between you and us,
- Carry out obligations imposed on us by the funders of our services,
- Book you onto events, workshops or face-to-face adviser sessions that you register for, and to send you information about those activities,
- Process your claims for any funded services you receive,
- Notify you about changes to our services or procedures,
- Compile service monitoring and performance information and statistics
Security of your information
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect in face-to-face transactions between us, over the phone, online or through other electronic means.
We may transfer and store the data collected from you in other countries within the European Economic Area (EEA). Your data may also be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your registration for services, the processing of any funding or grant claims, and the provision of support services.
By providing your personal data, you agree to this transfer, storing or processing.
We ensure, as far as we are able, that the organisations who process your information on our behalf are aware of their obligations with regard to the security of your data and have in place suitable physical, electronic and managerial procedures to safeguard and secure the information that they collect.
Sharing your information
We may share your personal information with any member of our Group, which means our ultimate holding company, or any wholly owned subsidiary (direct or indirect), and where the terms holding company and subsidiary are as defined in section 1159 of the Companies Act 2006.
We may also share your personal information with other organisations. We will only do this:
To provide you with information or services that you request from us but which are delivered by organisations operating on our behalf,
- To carry out our obligations arising from any contracts entered into between you and us,
- To comply with any statutory reporting and audit requirements. This may include forwarding your personal information on to any organisation which has provided funding for the services delivered to you, for information and reporting purposes,
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets,
- If Serco Regional Services Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its site users will be one of the transferred assets,
We may also share your information with 3rd party organisations under the following circumstances:
- In order to comply with the directions of the funders of our services to carry out market research or evaluations of your satisfaction with the services you have received and the effectiveness of the services provided to you. Such research or evaluations are carried out by carefully selected partners either on our behalf, or on behalf of the funders of the services provided to you.
- In the event that we believe the third party’s goods and services may be of interest to you.
We will never sell your personal information.
When you first register with us as a result of newly accessing any of our services or first acceptance for funding under a specific support project, we will ask you for your consent to receiving marketing messages either from us or from carefully selected third party providers of similar services that we think might be of interest to you.
If you are already registered with us as the result of previously accessing any of our services or having previously been accepted for funding under a support project, we will continue to market similar services to you.
You may change your consent to receiving marketing messages at any time by clicking on the unsubscribe link in any messages you receive either from us or our partners or suppliers, or by emailing us.
Accessing your information
You have the right to request a copy of the personal information that we hold about you. If you would like a copy, please email us or write to The Quality & Audit Manager, Serco Employment, Skills and Enterprise, Envoy House, 61 Longbridge Road, Plymouth, Devon, PL6 8LU. We may charge a statutory maximum fee of £10 for providing this information. Please note that we may ask you for further evidence to confirm your identify before supplying the information.
How to contact us
Who is the data controller for ERDF personal data?
Privacy Notice for the Purpose of Data Collection for ERDF
The UK is updating its data protection legislation and it will come into force on 25 May 2018. The new laws aim to update current data protection legislation including the Data Protection Act 1998, increase the privacy protection of all UK and EU citizens and reduce the risk of data breaches. It will apply to all public and private organisations processing personal data.
The EU Common Provisions Regulations (CPR), and Article 6 of the European Regional Development Fund (ERDF) Regulation require the Ministry for Housing Communities and Local Government (MHCLG), as the managing authority for the programme, to monitor and evaluate ERDF-funded activities. In order to conduct monitoring and evaluation (including the summative assessment) and to ensure compliance, the collection of personal data is required.
The MHCLG ERDF Managing Authority is the controller for all personal data required to help deliver the ERDF programme under the terms of its ERDF Funding Agreement.
The MHCLG ERDF Managing Authority will be processing personal data in the ERDF programme according to the following lawful basis:
Article 6(1)(e) of the EU General Data Protection Regulation (GDPR)
‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’.
The lawful basis for controlling or processing `special category’ data under ERDF is:
Article 9(2)(g) GDPR
“processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;”
What personal data will be collected?
Depending on the nature of activities of the ERDF-funded project and the indicators listed under each activity, the following information for each direct or indirect beneficiary where these are individuals may be collected:
Name of contact point within a business (in some cases property owner) engaged with or individual engaged with;
Labour market status prior to receiving support and 6 months after receiving support
Duration of support
Intensity of support
MHCLG may collect special category data on ethnicity and disability.
Who will my personal data be shared with and how will it be used?
Your details will be stored securely and retained in compliance with GDPR and the new Data Protection Act. This information will be used to evaluate this project and to report to the European Regional Development Fund for monitoring and evaluation purposes.
Your details will be used to support the ERDF programme research and evaluation activities. MHCLG will need to share all or some of your personal data with the national evaluator of the ERDF programme. In some cases, the national evaluator, i.e. independent external contractors commissioned by DCLG, may use the contact details to contact a sample of direct or indirect beneficiaries for the purpose of the National Evaluation of the programme. It is likely that the survey methodology will need to incorporate a variety of approaches in order to maximise the survey response rate (for example, telephone survey, written survey, and e-mail survey) – hence the need for a variety of contact details required for each participant. MHCLG may also need to share with other government departments and the European Commission where this is necessary to test the robustness of the data gathered or to inform the National Evaluation.
MHCLG will not give any personal data to any other organisation unless needed for the purpose of the evaluation and will instruct them not to use it to contact individuals for any reasons not connected with the purpose of the National Evaluation of the ERDF programme 2014-2020 or other matters directly relating to the evaluation. If MHCLG has to pass on the data, it will only provide what is needed, and if possible will remove the details that might identify individuals personally. MCHLG will not transfer personal data outside the European Union, to third countries or international organisations.
MHCLG will not keep your personal data for longer than it needs but as a minimum, will retain data for two years after the closure of the 2014-2020 ERDF programme in line with the European Regional Development Fund document retention guidance to ensure MHCLG meets reporting obligations and to demonstrate compliance with EU Requirements.
ERDF participants cannot claim the following rights in terms of ERDF personal data:
- right to erasure (“right to be forgotten”)
- right to portability of their data
The data collected is your personal data, and you have the right, subject to lawful data requirements:
to see what data we have about you;
to ask us to stop using your data;
to ask us to delete your data, or to correct your data if there is no longer a justification to process it;
to lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law.
Automated decision making
Your personal data will not be subjected to automated decision making
You can contact the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Tel: 0303 123 1113
If you would like further information about the programme and your personal information please contact the ERDF Programme at: firstname.lastname@example.org