Supporting 16 to 25 year olds not in education, employment or training (NEET) - privacy notice

PN0511
CYPS – Early Intervention and Safeguarding

Calderdale Metropolitan Borough Council of Town Hall, Crossley Street, Halifax, HX1 1UJ is registered with the Information Commissioners Office (ICO) under the provision of the Data Protection Act 2018. The Council takes its responsibilities as Data Controller under the Data Protection Act and UK GDPR very seriously.

This privacy notice explains how your personal information will be processed if you receive support from Calderdale Council's NEET Panel.

Calderdale Council has a responsibility to encourage, enable and assist young people that are residents in the borough aged 16 and 17 years at the start of each academic year (and up to 25 years in respect of young people with learning difficulties, disabilities and care experienced), to participate in education, employment or training and to mitigate against the risk of becoming Not In Education, Employment or Training (NEET).

Calderdale's NEET Panel aims to increase the number of 16–25-year-olds in Education, Employment and Training. The Panel is made up of representatives from across departments and external partners and thus is to improve the multi-agency response to young people who are NEET who are referred to the Panel. The Panel should also seek to improve the offer from the 'Family Business', for example, Calderdale Council. The information we collect will be shared at this panel so that solutions can be made with key partners to help young people to access employment, education and training.

The type of information we will collect

The information we gather will be collected from data in your Personal Education Plan (PEP), your Educational Health and Care Plan (EHCP), your Pathway Plan or via a NEET Referral Form. Relevant information about your NEET status may also come from the relevant delegate that represents you, such as your Pathway Advisor.

We will collect information directly from young people and/or their parent/carer in several ways. For example, by letter, email, face-to-face, phone, webforms and surveys.

• Personal and family details: name; age, gender; language, parent/carer name and living circumstances.
• Personal sensitive information: ethnicity and religion.
• Contact details: phone number, email address and home address.
• Education and/or employment details: education setting and academic year.
• Social Care records; Personal, Family and Social factors information.
• Assessments and self-assessments.

If you are not in education, employment or training, further information may be collected so we can offer appropriate support:

• Qualifications and achievements.
• Personal strengths and barriers.
• Interests and ambitions.
• Special Educational Needs or Disabilities (SEND).
• First language and any interpreter needs.
• Physical or mental health or condition.
• Substance misuse.
• Offending behaviour.
• Refugee or asylum seeker.
• LGBTQIA+.
• Looked after child or care leaver.
• Young parent/single parent.
• Young carer.

Why we collect and hold this information

• To make sure arrangements are in place to accurately track whether young people are participating in education, employment or training and submit statutory returns to the Department for Education (DfE) on the number of young people who are NEET or whose current activity is not known.
• To offer support and encouragement to you if you are identified as NEET to re-engage with education, employment or training opportunities, either directly or through commissioned or partner organisations.
• To share relevant information with the NEET panel so that solutions can be made with key partners to help you to access employment, education and training.
• When you have given consent for us to send you information on opportunities for jobs, training or other information and newsletters that may be relevant to you.
• To obtain feedback to help us to understand the effectiveness of the service and to develop and improve future services.

Sharing your personal data

We have a statutory duty to report to the DfE the total number of young people who take part in education, employment or training. Also, the number of those who are NEET or whose current activity is not known.

Where a young person is identified as NEET, we will gain their verbal consent to make a referral to the NEET Panel. The Panel consists of Council departments and external partners. The essential members include:

• Youth Justice Service Representative
• Pathways Representative
• Children Looked After Representative
• Virtual School Representative
• Special Educational Needs and Disability Representative
• Disabled Children's Team Representative
• Department for Work and Pensions Representative
• C+K Careers Representative
• Organisational Development Representative
• Calderdale College Representative
• Employment Hub Representative

Guest members to the panel are those who are deemed relevant to a young person's aspirations and needs. This can include, but is not limited to, a mental health representative, business engagement representative, housing representative, etc. The Panel can formally co-opt members as appropriate. Your information will be shared as appropriate with both essential and guest members.

We will only share information with these organisations where it is appropriate and legal to do so.

The lawful basis for the processing your data

The legislation, policies and guidance that relate to this service includes, but is not limited to:

• Education and Skills Act 2008.
• The Care Leavers (England) Regulations 2010.
• Working together to support Young People (NEET) Guidance published by DfE and DWP 2013.

We process personal information and special category data under the following GDPR lawful bases:

• Article 6(1)(a) – your consent (in relation to receiving newsletters and information).
• Article 6(1)(c) – for compliance with a legal obligation to which the controller is subject as above.
• Article 6(1)(e) – for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • Initial contact that does not lead to referral to Children's Social Care – 7 years.
• Article 9(2)(g) - processing is necessary for reasons of substantial public interest.
• DPA 2018 Schedule 1 Part 2 (8) Equality of opportunity or treatment and (18) Safeguarding of children and individuals at risk.

Retaining your personal information

Personal information will be kept for a maximum of 7 years from the case closure and then will be securely destroyed. For young people who also have records with other areas of Children's social care, information will be kept for the following length of time:

• Early Intervention and referrals/assessments including Child in Need cases:
  • Date of birth (DOB) of the child plus 25 years.
• Child Protection cases:
  • DOB plus 40 years.
• Looked After Children:
  • DOB plus 75 years.

Consent

If we rely on consent to use your personal data, you have the right to remove it at any time.

If you want to remove your consent to receive emails about job and training opportunities, please contact by email: pathwaysservice@calderdale.gov.uk.

Your rights

Note: Not all rights are absolute and will only apply in certain circumstances. The GDPR gives people the right to:

1. Be informed.
2. Have access.
3. Rectification.
4. Erasure.
5. Restrict processing.
6. Data portability.
7. Object.
8. Also, rights in relation to automated decision making and profiling.

You also have the right to complain if you feel that your data has not been handled in accordance with the law. To contact our Data Protection Officer, email: information.management@calderdale.gov.uk.

You also have the right to lodge a complaint with the Information Commissioner's Office.