Statement on Privacy implications of combination
Adopted on 3rd May 2022
On 28th January, RFEA – The Forces Employment Charity announced we intend to combine our employment related activities with The Officers’ Association (OA), and begin an exciting new chapter in our history.
We have been working together to create a single charity to provide exceptional career support to all Service leavers, veterans, reservists, and their families throughout the UK, whatever their circumstances, rank, length of service, or reasons for leaving.
From Tuesday 3rd May 2022 RFEA will become the Forces Employment Charity.
To ensure there is no impact on our services and the processing of personal data, RFEA and OA have agreed to continue operating and processing data in agreement with current privacy policies. This will continue until such time that the Forces Employment Charity systems have been developed to accommodate all activities in accordance with all regulations.
What does that mean in real terms?
If you have registered with RFEA, then there will be no change to how your personal data is being processed.
You can contact [email protected] if you wish to exercise any of your rights or have any questions about the handling and use of your personal data.
RFEA Privacy Notice
It is important that you read this notice, together with any other privacy notice that is provided on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
Who We Are
RFEA- The Forces Employment Charity gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
RFEA The Forces Employment Charity’s registered office is First Floor, Mountbarrow House, 12 Elizabeth Street, London SW1W 9RB. We are a ‘Registered Charity’ England and Wales (1061212) and Scotland (SC039262). We are a company registered in England and Wales under company number (03270369). We are registered on the Information Commissioner’s Office Register; registration number (Z7498943), and act as the data controller and data processor when processing your data. We have a dedicated Data Protection Controller who can be contacted at RFEA Head Office, First Floor, Mountbarrow House, 12 Elizabeth Street, London SW1W 9RB; email [email protected].
Data Protection Principles
We will comply with the data protection principles under the data protection legislation. This says that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- relevant to the purposes we have told you about and limited only to those purposes
- accurate and kept up to date
- kept only as long as necessary for the purposes we have told you about
- kept securely
Information That We Collect
RFEA The Forces Employment Charity processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from is: –
- Full Name
- Title and Rank
- Date of Birth
- Service Number
- Enlistment Date
- Discharge Date
- Campaigns Served
- Employment History
- Home Address
- Personal Email
- Business Email
- Financial Problems
- Evidence of your right to work in the UK/immigration status
- Family, lifestyle and social circumstances
- Copies of driving licence, passport, birth and marriage certificates, decree absolute
- Home Telephone Number
- Mobile Telephone Number
- Special Category Data – i.e. health/medical information, information about criminal convictions/allegations and offences (not in all cases; only where applicable to the service programme offered).
We collect information in the below ways:
- Paper and Website Registrations
- Telephone Disclosures
- Employment CVs
- Employee Data
- Review meetings
- Group Events
- Referral Information
- Web chat and Webinars
Equality, Diversity and Inclusion Questionnaire
RFEA wants to meet the aims set out in our Equality, Diversity and Inclusion commitment. This includes not discriminating under the Equality Act 2010. RFEA have introduced an equality and diversity questionnaire that is intended to help us maintain best practice and identify barriers to workforce equality and diversity.
The information on the questionnaire will be used for evaluation purposes only to ensure we are meeting our Equality & Diversity Policy and will play no part in the registration or service delivery.
This information will include Special Category Data and is optional. The information we will collect will be:
- Sexual Orientation
The intention of analysis is to establish if there are different success rates between genders, people of different sexual orientation, ages, different ethnic backgrounds or faiths, and people with disabilities. If there are differences in these areas, it will enable action to be taken to ensure that no group is treated unfairly.
All questions are optional. You are not obliged to answer any of these questions but the more information you supply, the more effective our evaluation will be. All information supplied will be treated in the strictest confidence.
With the help of feedback from our community groups, beneficiaries and staff, we will continue to develop arrangements to review and evaluate the effectiveness of our employment and service delivery policies. If our evaluation reveals any gaps in our policies, we will take necessary action.
How We Use Your Personal Data (Our Legal Basis For Processing)
RFEA The Forces Employment Charity takes your privacy very seriously and will never disclose or share your data outside our Partners listed in this notice without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:
- We collect and process your personal data in the performance of a contract or to provide an employment service to you as a client/beneficiary with your consent.
- We collect and process your personal data in the performance of a government contract to provide an employment service to you as a client/beneficiary under legitimate interest.
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes.
- We will occasionally send you marketing information where we have assessed that it is beneficial to you as a client/beneficiary and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now by requesting you read the information provided at www.knowyourprivacyrights.org.
You have the right to access any personal information that RFEA The Forces Employment Charity processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source/provider
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use (currently RFEA The Forces Employment Charity does not use any automated decision-making processes).
If we receive a request from you to exercise any of the above rights, we will ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing And Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. RFEA The Forces Employment Charity uses third parties (partners) to provide and enhance our services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
We only share your data with recognised partners that are appropriate to your specific support programme. Our partners may include those listed below, but there is a wider support network that we may work with to support individual cases. We will keep you informed of partners linked within your specific programme:
- The MOD. As a sub-contractor, delivering the Career Transition Partnership to the MOD, we process data for all Armed Forces Service Leavers.
- Right Management as part of our contract in delivering the Career Transition Partnership service for the Ministry of Defence (MoD). We jointly process personal information on Service Leaver clients two years prior to leaving the service and two years post discharge; this data is used specifically in the service of employment support and job finding. Details are at https://www.right.com
- Right Management as part of our Ex-Forces Programme, hosts the database system which we use to process data. This allows clients the opportunity to access Rightjob and other benefits as a Veteran.
- GLA as part of our Forces For London Programme. The Greater London Authority will pass your personal contact details and personal data on to an organisation which will be responsible for evaluating the GLAs European Social Fund (ESF) programme and DWP evaluators. The evaluation reports will be presented in an anonymised report and you will not be mentioned by name or other distinguishing characteristic. If contacted by the GLA or DWP evaluation organisation you may refuse to be included in the evaluation. Details are at https://www.london.gov.uk/about-us/governance-and-spending/privacy-policies/gla-privacy-policy
- TechVets Programme. TechVets clients will register with RFEA and their personal data will be stored on RFEA’s Salesforce CRM system.
Charitable and Social Enterprise Partners:
- Greenwich Hospital. Details are at http://www.grenhosp.org.uk/
- The Royal British Legion. Details of their Data Protection, Privacy and Communications Policy are at https://www.britishlegion.org.uk/quick-links/our-privacy-policy-and-promise
- Poppy Scotland. Details are at http://www.poppyscotland.org.uk/about-us/
- Lloyds Patriotic Fund. Details can be found here https://www.lloyds.com/help/privacy
- Call of Duty Endowment. Details can be found here https://www.callofdutyendowment.org/privacy_policy
- Forces For London
- X-Forces – Details are at https://www.x-forces.com/
Employers and Training Provided
- An employer registered on Rightjob – To support your job searching activities, we will only share information you have consented to share and with vetted employers
- Training providers – To support your job searching activities, we will only share information you have consented to share
RFEA The Forces Employment Charity takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
- Restricted Access
- IT Authentication
- Data Encryption
- Virtual Private Networks (VPN)
- Controlled Anti-virus/malware
- Security Cleared Employees
How We Store Personal Data
Your personal data will be stored in a secure Information Technology system. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- In addition, we limit access to your personal information to only RFEA personnel, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions. Details of these measures are available upon request from our Data Protection Controller.
- Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure, in a contractual arrangement.
- We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office (ICO) of a suspected breach where we are legally required to do so.
RFEA contract a small number of suppliers to assist in ensuring your personal data is stored securely. All contractors meet GDPR, Data Protection Act 2018 and IS0 27001 requirements.
- 123formbuilder – Is used for our registration form and to upload proof of service. Once the form has been completed it connects to RFEA via a Data Centre in Frankfurt. This complies with current GDPR requirements – https://www.123formbuilder.com/secure-forms.html
- Spanning – Prioritises the privacy and security of all personal data held by RFEA ensuring that it is backed up via a secure Data Centre in Dublin – https://spanning.com/gdpr/
- F-Secure – With the introduction of direct uploading of Proof of Service RFEA have investing in Virus and Malware protection to add an additional layer of security to protect your Personal Information. F-Secure scans all documents via a Data Centre in Dublin – https://www.f-secure.com/gb-en/about-us/trust
- Dotdigital – Is used as part of RFEA marketing and feedback gathering. When selecting to opt into our newsletter your data is stored on dotdigital. Dotdigital has extensive expertise in protecting data, championing privacy, and complying with complex regulations. https://dotdigital.com/trust-center/gdpr/
Consequences Of Not Providing Your Data
You are not obligated to provide your personal information to RFEA The Forces Employment Charity, however, as this information is required for us to provide you with our services and legitimate interests, we will not be able to offer some/all our services without it.
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
RFEA The Forces Employment Charity only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years plus current year.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Change Of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated or new purpose, we will notify you and we will explain the legal basis which allows us to do so.
Special Categories Data
Owing to the provision requirements of some of our more specialised services, RFEA The Forces Employment Charity sometimes needs to process sensitive personal information (known as special category data) about you; for example, information about your health. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Do We Need Your Consent?
We do not need your consent if we use special categories of your personal information in accordance with our reasons outlined above:
In limited circumstances, if the need arises, we will approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information About Criminal Convictions
We will only use information relating to criminal convictions or alleged criminal behaviour where the law requires us to do so. This can arise when it is necessary for us to comply with the law or for another reason where there is a substantial public interest in us doing so.
Less commonly, we will, if necessary, use information relating to criminal convictions or alleged criminal behaviour where it is necessary in relation to legal claims, where it is necessary to protect your interests, or someone else’s interests and you are not capable of giving your consent, or where you have already made the information public.
We will only collect information about criminal convictions or allegations of criminal behaviour where it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions/allegations as part of the specific programme or if we are notified of such information directly by you while you are on one of our programmes.
We will collect your personal details, including but not limited to your name and contact details (together with your e-mail address) and other relevant information from your Curriculum Vitae (“CV”). On occasion this will also include sensitive personal information such as details of criminal convictions and ethnic origin. When we receive your details and CV electronically, this may be through a direct application on our website or an application that you have made through a third-party job board.
We will likely obtain further personal information about you during our relationship with you. This information will have obtained from you directly.
Our standard terms of business state that we retain applicant data such as CVs, interview notes and special category data (information on criminal convictions, biometric data etc) for the purposes of the specific role you apply for and that, as controllers of your data, you will be inform you if we plan to retain your CV on file to notify you about potential future roles.
The length of time we will hold or store your personal information is for 6 months once the position has been successfully filled.
Service Leavers, Veterans or families members should register for their personal employment support. Veterans who work for organisations that seek to use our employer contacts or services for their business or charitable purposes will be excluded.
Duty To Inform
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time with us.
Lodging A Complaint
RFEA The Forces Employment Charity only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
RFEA The Forces Employment Charity
Data Protection Manager
First Floor, Mountbarrow House
12 Elizabeth Street
London SW1W 9RB
Information Commissioner’s Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 (National Rate)
Fax: 01625 524 510
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Review Of This Privacy Notice
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.