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Privacy notice for Education Business Partnership Pathways Programme


This privacy notice explains what types of personal data we may hold about you, how we collect it, how we use it and who we may share information with. We are required to give you this information under data protection law.  Achieving for Children is registered as a controller with the Information Commissioner’s Office (registration number ZA045069). The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. 

Located within Achieving for Children’s Education Services, the Pathways team coordinates and delivers AfC’s Pathways programme to targeted young people with SEND aged 16-24 and to young people with Education Health and Care Plans residing in Kingston and Richmond local authority areas.

The Pathways team works closely with other AfC teams including the 14-25 team, Preparing for Adulthood team, social care and health teams in managing the funding process to support learners with needs into training, employment and further education. The Pathways team also tracks and identifies young people who are not in employment, education or training and signposts them to additional support and guidance as well as delivering individual information and guidance sessions.

Personal data we collect 

To fulfil its statutory duties, the Pathways team collects the following personal data about young people:

  • personal identifiers such as such as name, date of birth, address and contact details, national insurance number, ethnicity, health information, education details and emergency contact details 
  • SEND information  and behavioural information 
  • safeguarding information such as professional involvement and other details to ensure that students are suitably supported in the workplace
  • Information regarding prior attainment
  • employment history

How we use your personal data 

The personal data we collect is used to support children and young to  seek education, training, career guidance and employment opportunities including: 

  • identifying and arranging suitable work experience or volunteering placements for children and young people 
  • ensuring that placements identified are suitable for the young person and that employer risk assessments have been based on the young person’s capability and personal needs.
  • ensuring placements identified are within a reasonable travel distance from the young person’s home address 
  • identifying suitable opportunities for education, training and employment and supporting young people to complete relevant applications 
  • providing appropriate support and pastoral care to the young people we are working with 
  • enabling us to contact parents and young people to advise of any changes to their placement or learning programme 
  • informing employers of the young people due to take up placement offers and to ensure that they are prepared for the young person's arrival. 
  • tracking and monitoring your journey through our programmes and analysing the impact of the service provided including case studies

How we collect your personal information 

  • We may collect personal information directly from you through face to face interviews, telephone conversations, letters, emails, text message and forms submitted. 
  • We may also collect information from third parties schools, employers, training providers, other departments within Achieving for Children. 

Lawful basis for processing your personal data 

The lawful basis for processing personal data is the performance of a public task and for special category data we rely upon reasons of substantial public interest (equality of opportunity or treatment). These legal basis are underpinned by the following legislation and statutory guidance:

  • Children and Families’ Act 2014
  • Education and Skills Act 2008, section 68
  • Department for Education Statutory Guidance on the Participation of Young People in Education, Employment or Training , September 2014

Who we share your personal information with

We will only share information where it is appropriate and legal to do so. Where this is necessary, we are required to comply with all aspects of the Data Protection Act 2018. 

Depending on the individual circumstances of each situation, we may have to share this information with other teams within Achieving for Children to fulfil other duties and powers to support our work:

  • Preparing for Adulthood team (as part of SEN team)
  • RBK South London CCIS Service
  • Virtual School and Careleavers’ team
  • Social Care team
  • work placement providers
  • potential employers and education and training organisations
  • other agencies that can support you 

How long will we keep your information

Applications for the Pathways Programme which may include work placements: data placement ends + 1 year.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Achieving for Children’s email service has been configured to Government Digital Service and we encrypt and authenticate email in transit using Transport Layer Security (TLS) and Domain-based Message Authentication, Reporting and Conformance (DMARC). We will ensure that when we send emails containing your personal information they are sent using appropriate security measures to encrypt the data in transit. This may involve the use of a third party encryption tool where appropriate.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Your rights and access to information 

Under data protection legislation you have the right to request access to the information that we hold about you. To request a copy of your data, please read the Individual Rights Request page on this website and then submit your request using your preferred method of contact. 

You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress
  • have inaccurate personal data rectified, blocked, erased or destroyed
  • prevent processing for the purpose of direct marketing
  • object to decisions being taken by automated means
  • In certain circumstances have inaccurate personal data rectified, blocked, erased or destroyed; and 
  • A right to seek redress, either through the ICO, or through the courts

If you have any questions or concerns about the way we process personal data, or would like to discuss anything in this privacy notice, please contact our Data Protection Officer: [email protected]

If you want to make a complaint about how we handle your personal data, we ask that you give our Data Protection Officer the opportunity to respond in the first instance but you are not obliged to do this. You can make a complaint directly to the Information Commissioner’s Office.