Who we are

Skills Training Network Ltd manage applications and referrals to employability programmes and support services in several local authority areas in Scotland.

All personal information provided by you through this website is under the control of Skills Training Network Ltd, and we’re responsible for taking care of your personal information in line with the Data Protection Act 2018, and the UK General Data Protection Regulation (GDPR).

This policy may refer to the organisation as ‘Skills Training Network Ltd’, ‘our’, ‘us’, or ‘we’, and our registered office is 5 Striven Gardens, Glasgow G20 6DU.

Terms used in this policy

In all of our policies, we try to use language that is easy to understand, and avoid legal terms. However, we’re required by law to include certain information in our privacy policy – here we explain what these terms mean:

• UK General Data Protection Regulation (GDPR) is a regulation on data protection and privacy, that applies within the United Kingdom (UK). The regulation provides individual control and rights in respect of personal information.
• Data Protection Act 2018 (DPA), along with the GDPR, sets the regime for handling personal data within the UK.   
• Personal data is information about individuals, like name and address, or barriers to employment and training. Our policy may refer to personal data as ‘personal information’.
• ‘Special category’ personal data is personal information the GDPR considers to be sensitive, such as information about ethnicity, sexual orientation, religious beliefs, or mental and physical health. Use of this personal information is subject to stricter conditions under the GDPR.
• Lawful basis for processing — all uses of personal information must be supported by a ‘lawful basis for processing’. This means there must be provisions in the GDPR or DPA allowing the use of personal information for specific purposes.

Making an application through the Skills Training Network website

Collecting and using your personal information

When you apply to an employability programme or support service, we may collect the personal information below. 

• If you register on our website, we collect your username, chosen password, your name, email address, contact number, address, social media links and registered company/charity number
• If you apply through our application form, we may ask you to provide your name, contact details, date of birth, communication preferences, gender, nationality, and permanent residence. We ask for details of your education, qualifications, work experience and barriers to employment. 
• To support your application, we allow you to give us the name and contact details of your support worker (if applicable). You must make sure you have the permission of your support worker to provide us with their details.
• How you want to be contacted — if you opt to receive further information from Skills Training Network Ltd or third parties.
• Undertaking research about the employability sector – we’ll retain a copy of your application and use it for producing statistical analysis and research in respect of Skills Training Network Ltd’s application processes. Any statistical analysis reports published will not allow any individual to be identified.

‘Special category’ personal information

To support your application, we may ask you to provide special category personal information as detailed below, which may be shared with the course providers (training organisations) you apply to.

• Its up to you if you give details about your ethnicity, sexual orientation, gender identity, and religious belief — this will help providers check their compliance with the Equality Act 2010 and confirm your eligibility for the programme you’ve applied for. This information is provided to your chosen provider after you’ve submitted your application.
• You can choose to give information about any disability you have, so the providers you’ve applied to can support you if you’re invited to interview or offered a place.

Sharing your personal information

We may share your personal information with organisations or individuals, for the purposes listed below.

Supporting your application to a programme

• We share the personal information in your application with the training providers you’re applying to, so they can consider your application. We may also liaise with them about your application.

Enabling research about the employability sector

If you apply through the Skills Training Network website, we may share your personal data with your local authority, or other statutory organisations, to support research in the public interest. We do this to help inform research about, and improve, employability support. We do not allow use for commercial purposes, such as marketing, and we take steps to minimise the personal information shared to support this research. Any data shared with researchers will not allow individuals to be identified.

Reporting to organisations with responsibilities for employability

We may also share personal information with government or other bodies with responsibilities for the employability sector, or others which develop and monitor the effectiveness of government policies for employability such as:

• Local Authorities (Local Employability Partnerships) — when necessary to help them meet reporting responsibilities and enhance research of unemployment in relevant areas

We only supply personal information that identifies you for these purposes:

• if the provision of statistical analysis is not suitable
• if we have a contract or agreement in place setting out agreed purposes for which it can be used

Prevention and detection of crime

We may share personal information with relevant statutory organisations, like the police, to support the prevention and detection of crime, and for child protection purposes.

Verification checks

We will make verification checks to ensure your application is accurate, and not fraudulently submitted. This process will include cross-referencing the information submitted on new applications with previously cancelled submissions. If any adverse information is revealed about you, we will let you know so you have an opportunity to respond. We may also share details of these checks with the course providers to whom you’ve applied.

Information provided as part of your application may also be used by course providers to complete their own verification checks regarding the details you have provided. They may contact you directly if there are any concerns or queries regarding your application.

If you apply through the Skills Training Network website and don’t hear from the training provider after 7 days, you can contact us to track the progress of your application. To enquire about the status of your application, please contact hello@skillstrainingnetwork.org.

Collecting and using your personal information

If you apply through the Skills Training Network website, you will receive an email notification to confirm that your application has been sent. This email includes a summary of the details you submitted in your application.

Sharing your personal information

Your application will only be shared with the provider of the programme you applying for, and not with any other providers.

How to opt out of receiving email notifications

We may use a supplier to provide this information to you – such as an application that enables us to deliver information to you, sending you an email or SMS/text. You can opt out of receiving application email confirmations, by clicking the ‘unsubscribe’ link in our communications.

We use a variety of measures to make sure we hold your personal information securely, and only share it with organisations who need to access it. This includes maintaining an Information Security Management System. We use third party suppliers who provide parts of our services for us.

Making a referral through the Skills Training Network website

Collecting and using your personal information

When you make a referral to an employability programme or support service, we may collect the personal information below. 

• If you refer through our referral form, we may ask you to provide your name, contact details, employer and communication preferences.
• How you want to be contacted — if you opt to receive further information from Skills Training Network Ltd or third parties.
• Information about your client – we may ask for information about your client, such as their name, contact details, date of birth, communication preferences, gender, nationality, and permanent residence. We ask for details of their education, qualifications, work experience and barriers to employment. 
• Consent – you must make sure you have the permission of your client to provide us with their details. Skills Training Network Ltd accepts no liability for referrals submitted by individuals without the consent of their client.
• Undertaking research about the employability sector – we’ll retain a copy of your referral and use it for producing statistical analysis and research in respect of Skills Training Network Ltd’s referral processes. Any statistical analysis reports published will not allow you or your client to be identified.

‘Special category’ personal information

To support your referral, we may ask you to provide special category personal information about your client as detailed below, which may be shared with the course providers (training organisations) you refer to.

• It’s up to your client to share details about their ethnicity, sexual orientation, gender identity, and religious belief — this will help providers check their compliance with the Equality Act 2010 and confirm their eligibility for the programme you’ve referred to. This information is provided to your chosen provider after you’ve submitted your referral.
• It’s up to your client to share details about any disability they have, so the providers you’ve referred to can support them if they’re invited to interview or offered a place.

Sharing your personal information

We may share your personal information with organisations or individuals, for the purposes listed below.

Supporting your referral to a programme

• We share the personal information in your referral with the training providers you’re referring to, so they can consider your referral. We may also liaise with them about your referral.

Enabling research about the employability sector

If you make a referral through the Skills Training Network website, we may share your personal data with your local authority, or other statutory organisations, to support research in the public interest. We do this to help inform research about, and improve, employability support. We do not allow use for commercial purposes, such as marketing, and we take steps to minimise the personal information shared to support this research. Any data shared with researchers will not allow individuals to be identified.

Reporting to organisations with responsibilities for employability

We may also share personal information with government or other bodies with responsibilities for the employability sector, or others which develop and monitor the effectiveness of government policies for employability such as:

• Local Authorities (Local Employability Partnerships) — when necessary to help them meet reporting responsibilities and enhance research of unemployment in relevant areas

We only supply personal information that identifies you or your client for these purposes:

• if the provision of statistical analysis is not suitable
• if we have a contract or agreement in place setting out agreed purposes for which it can be used

Prevention and detection of crime

We may share personal information with relevant statutory organisations, like the police, to support the prevention and detection of crime, and for child protection purposes.

Verification checks

We will make verification checks to ensure your referral is accurate, and not fraudulently submitted. This process will include cross-referencing the information submitted on new referrals with previously cancelled submissions. If any adverse information is revealed about you, we will let you know so you have an opportunity to respond. We may also share details of these checks with the course providers to whom you’ve referred.

Information provided as part of your referral may also be used by course providers to complete their own verification checks regarding the details you have provided. They may contact you directly if there are any concerns or queries regarding your referral.

If you make a referral through the Skills Training Network website and don’t hear from the training provider after 7 days, you can contact us to track the progress of your referral. To enquire about the status of your referral, please contact hello@skillstrainingnetwork.org.

Collecting and using your personal information

If you make a referral through the Skills Training Network website, you and your client will receive an email notification to confirm that your referral has been sent. This email includes a summary of the details you submitted in your referral.

Sharing your personal information

Your referral will only be shared with the provider of the programme you are referring to, and not with any other providers.

How to opt out of receiving email notifications

We may use a supplier to provide this information to you – such as an application that enables us to deliver information to you, sending you an email or SMS/text. You can opt out of receiving application email confirmations, by clicking the ‘unsubscribe’ link in our communications

We use a variety of measures to make sure we hold your personal information securely, and only share it with organisations who need to access it. This includes maintaining an Information Security Management System. We use third party suppliers who provide parts of our services for us.

Application and referral security

To keep your applications and referrals secure, we ensure that all applications and referrals passed to course providers are encrypted. We also ask you to answer certain questions before we discuss your applications and referrals with you.

We retain your personal information in accordance with the GDPR, which obliges us to keep it only for as long as is necessary. If we do not have any requirement to retain personal information for business, regulatory, or legal reasons, we will delete it.

Article 89 (1) of the GDPR allows us to retain personal information for statistical and research purposes in the public interest. If you apply through our website, we’ll retain and use this, in combination with other information we hold, to produce statistical analysis and research in respect of the employability sector, for public benefit.

The GDPR provides you with rights in respect of your personal information.

• The right to be informed about the way Skills Training Network Ltd processes your information – we provide these details when you first use a Skills Training Network Ltd service and this includes the information available through this privacy policy.
• The right of access to information Skills Training Network Ltd holds about you. There may be a requirement to provide identification details so we can be sure we are sharing information with the right person. We may also ask you for confirmation of the information you are hoping to obtain or your interactions with Skills Training Network Ltd to support this handling of your request.
• The right of data portability – provides a right to a machine readable copy of your information in certain circumstances.
• The right to object to ‘automated decision-making’ including profiling – you have a right under the GDPR to object to any decision that has legal effects on you made by solely automated means (e.g. no human intervention). Skills Training Network Ltd’ uses of personal information doesn’t include automated decision-making as defined in the GDPR.
• The right to ‘rectification’ of your information – if you believe that the information Skills Training Network Ltd holds about you is inaccurate, you have a right to ask us to amend or update that information.
• The right to request deletion of your personal information – Skills Training Network Ltd retains personal information to support research into the employability sector. However, you can request that we delete the personal information we hold about you and will provide a response.
• The right to object to uses of personal information, in particular where the lawful basis for processing relies on processing in the public interests, or Skills Training Network Ltd’ legitimate interests. See the section ‘Lawful basis for processing’ for more information.
• The right to restrict processing, which is available in certain circumstances.

If you would like to apply these rights, or have questions about Skills Training Network Ltd’ use of personal information, please email hello@skillstrainingnetwork.org, or write to: Data Protection Officer, Skills Training Network Ltd, 5 Striven Gardens, Glasgow G20 6DU. Further details about these rights can be found on the Information Commissioner’s website.

If you’d like to opt out of receiving direct marketing, you can click the ‘Unsubscribe’ in the communications we send. 

Personal information

Purpose 1 – Managing applications and referrals to employability programmes

If you apply or make a referral through Skills Training Network Ltd, you’re accepting our terms and conditions, and entering into a contract with us. We’ll collect the personal information necessary to satisfy the purpose of this contract, such as personal information to allow course providers to make informed decisions on whether to offer a place on a course.

GDPR lawful basis for processing – Article 6 1 (b) ‘processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract’.

Purpose 2 – Sharing personal information with statutory bodies with responsibilities for the employability sector, and to enable research into employability

We share personal information with providers and other public authorities (e.g. government bodies such as Local Authorities) to help them with their statutory functions, including funding, regulation, and policy-making.

We share personal information with course providers to help them meet, or demonstrate they are meeting, government aims or policies such as ‘widening participation’ initiatives, which require them to address discrepancies in the take up of employability opportunities between different social groups.

We always try to share information in a way that does not identify individuals, such as by providing statistical information. Where personal information is provided in a way that allows individuals to be identified, it is done so under contractual terms, and not used to support decisions being made about individuals.

GDPR lawful basis for processing – Article 6 1 (e) where ‘processing is necessary for the performance of a task carried out in the public interest’.

Purpose 3 – Commercial use of personal data through Skills Training Network Ltd’ commercial products and services including providing services to course providers to help their application/referral strategies, and producing commercial research

We give analysis to course providers, to help them understand and measure the success of their application/referral procedures, and improve them. We do not provide personal information that identifies individuals for this purpose. This may involve some individual level data matching activity to support the analysis; but, any information we share will be anonymised to ensure individuals cannot be identified. We also may provide statistical analysis to people or organisations undertaking research into the employability sector.

Your personal data may be used to support the development and provision of commercial products to third parties. Personally identifiable information will not be shared through such products or services without your consent.

GDPR lawful basis for processing – Article 6 1 (f) where ‘processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child’.

These activities do not involve sharing personal information in a manner that identifies you with third parties; personal level information will only be provided with your consent.

We may use personal level data to support the development of new commercial products. Individual data will never be shared through these commercial products or services without your consent.

‘Special category’ personal information

Purpose 1 – Equality monitoring

When applying, applicants can choose to tell us their ethnicity, sexual orientation, and religious beliefs. Providers can use this information to review their performance in meeting their statutory duties in the Equality Act 2010. We may also use this information to produce similar analysis across the employability sector.

GDPR basis for processing – Article 9 2 (g) where the use of personal information ‘is in substantial public interest’, which the Data Protection Act 2018 clarifies can include keeping under review the existence or absence of equality of opportunity or treatment between different groups of people, including differences based on ethnicity, religious beliefs, and sexual orientation. This information is not used to influence decision-making, and will not be shared with a course provider until a decision has been made on your application.

Other websites you can access from this one

• Our website and privacy policy may contain links to other websites, operated by other organisations. Links which leave our website have an image next to them, of an arrow coming out of a box. We’re not responsible for the protection and privacy of any information you provide while visiting other websites. This privacy policy applies to this website only. Make sure you read the privacy policy of the website you’re visiting. o
  

How we collect your personal information

If we engage with each other through social media, we may collect information contained in your posts or blogs, comments, likes, voting, web chat, video uploads, or private messaging functions, from any of the social media links available to you on this website.

How we share your personal information

Any personal information you choose to share could be accessed publicly, if you to share any content on this site, or on any of our social media sites (Facebook, Twitter, YouTube, Instagram, LinkedIn). This includes disclosing personal information if you engage with Skills Training Network Ltd social media, such as posting comments on our Skills Training Network Ltd Facebook page, sending us a private message, uploading a video, or tweeting us.

We cannot be held responsible for any damaging actions or behaviours which may result, following your use of this, or any other related social media activity.

Social media acceptable use

When you engage with Skills Training Network Ltd on social media, such as our Facebook page or Twitter feed, comments you post are live as soon as you publish them. We do not check and approve them beforehand. We will remove inappropriate posts.

Cookies

We want to make sure we give you very clear information about the cookies we collect, how we use them, and how to disable them — read our cookies policy.

We use cookies to provide users with the functionality contained in our website, and produce anonymous information to help analyse website traffic, usage, and behaviour. This helps us improve the visitor experience on our website, and ensure you receive relevant adverts when you use our website, and others.

The data controller responsible in respect of the information collected on this website is The Skills Training Network Limited, which is notified to the Information Commissioner as a data controller.

If you remain dissatisfied with our response following any review related to a request you have made regarding your personal data, you are entitled to appeal to the Information Commissioner. Such an application should be sent to the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Email: Scotland@ico.org.uk

Website: https://www.ico.gov.uk

If you have any questions about this privacy policy or our treatment of your personal information, you can get in touch at hello@skillstrainingnetwork.org.