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Fair Processing Notice – ESF Liverpool City Region Positive Inclusion Programme

The Department for Work and Pensions (DWP) European Social Fund (ESF) Managing Authority is the ‘data controller’ for all personal data required to help deliver the ESF Liverpool City Region Positive Inclusion Programme. This means that they decide the purpose and means of how your data is used as part of our Positive inclusion Programme activities.

Liverpool City Region Combined Authority (LCRCA) is the data processor for the data.

If you have any questions about how your information is being used you can contact

LCRCA’s Data Protection Officer at:

[email protected]

0151 330 1679

1 Mann Island, Liverpool, L69 3HN

Purpose of the processing and the legal basis for the processing

Your information is being used to confirm that you are eligible for the ESF Positive Inclusion Programme and to assist in identifying ways to help you move nearer to the labour market.  We are able to do this with your consent that you provided when you registered onto the ESF Positive Inclusion Programme.

LCRCA will be processing personal data in the ESF programme according to the following lawful basis:

Article 6 (1) (e) 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.’

Article 9 (2) (b) GDPR provides DWP with the lawful basis for processing ‘special category (sensitive) data i.e. regarding ethnicity and disability:

‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to the Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.’

Description of the categories of personal data

The categories of information being processed include:

  • Your title, first and last names, address and contact details, including email address and telephone number, date of birth, ethnicity, gender;
  • National insurance number;
  • information about your entitlement to work in the UK;
  • information about your household situation (i.e. if you live with other working adults and/or dependents,
  • details about your current employment status, length of unemployment,
  • if you are engaging in training/education,
  • details of your qualifications,
  • Number of people in household
  • Number of people employed in household,
  • Number of 0-17 year olds in household
  • Number of economically inactive18-24 year olds in household
  • Eligibility to work in the UK
  • Physical Disability – Yes or No
  • Health condition – Yes or No
  • Lone parent – Yes or No
  • NEET (Not in Employment, Education or Training) – Yes or No
  • Ex-offender – Yes or No (1.4 only)
  • Start date on project
  • End date on project
  • Status on leaving
  • If commencing/completing training or education on or after leaving the programme, the name and address of the training/education establishment, course/qualification title, awarding body, training state and end date and if the qualification was achieved?
  • If finding employment whilst on or after leaving programme, the job title, start date, location of job, type of contract, number of hours per week and name and contact details of employer.

Why does the Combined Authority process personal data?

LCRCA is contractually committed by DWP to provide data of all participants of the Positive Inclusion Programme to confirm eligibility for the programme and for monitoring and evaluation purposes.  Collection of your national insurance number enables the LCRCA to identify duplicate registrations so that we provide the correct number of participants on the project to the ESF Managing Authority.

LCRCA is required to process your information in accordance with the contractual requirement of the ESF Positive Inclusion Programme. Failure to provide your personal data would lead to the funding for the project being withdrawn.

Who is your data shared with?

Your information will be shared with ESIF team in the Combined Authority, the Secretary of State, Representatives of the Secretary of State, the ESF DWP Managing Authority, Evaluators appointed by the ESF DWP Managing Authority, Representatives of the European Commission, European Court of Auditors and Evaluators appointed for subsequent evaluations by the Positive Inclusion Programme. The information provided will enable the Data Controller to meet its reporting obligations and to demonstrate compliance with EU requirements.

Where is your data stored?

Data is stored in a range of different places, including in the Combined Authority’s IT systems (including email system). Participant paperwork is stored in locked cabinets.

How does the Combined Authority process data?

The Combined Authority takes the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed except by its employees in the performance of their duties.

How long does the Combined Authority keep data?

Your data will be kept as a minimum, for two years after the Audit Authority submits the Annual Control Report in which the final expenditure for the completed project is included. This is to ensure documents may be made available to the European Commission and European Court of Auditors upon request in accordance with Article 140(1) of Regulation (EU) No 1303/2013.

This retention period has been determined by The European Commission as detailed in the data/retention policy in the link below:

Your rights

The GDPR provides you with the following rights when it comes to your personal data:

  • The right to be informed how your personal data is being processed
  • The right of access to the personal data we hold about you, which include providing copies of the information to you within one month of a request.
  • The right to rectification of any incorrect or incomplete data we hold about you
  • The right to restrict processing, which limits what the Combined Authority can do with your information
  • The right to object to direct marketing or any processing based on the performance of a task in the public interest/exercise of official authority or for the purposes of scientific/historical research and statistics.
  • Rights in relation to automated decision making and profiling, where a decision made by a computer has a legal or significant effect on you.

Please note that your right to erasure and right to data portability do not apply to ESF participants because of the particular lawful basis under with ESF personal data is being processed.

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint regarding the processing of your personal data to the UK’s supervisory authority, the Information Commissioner, who can be reached using the details below:

The Information Commissioner’s Office,

Wycliffe House,

Water Lane,


Cheshire SK9 5AF

0303 123 1113

The source the personal data originates from and whether it came from publicly accessible sources

We receive your personal data from the 5 Local Authorities in the Liverpool City Region delivering jobs, education and training information, advice and guidance funded via ESF Positive Inclusion Programme, as part of a data sharing agreement in relation to the Positive Inclusion Programme.

Rights of Access Requests

You can make a request for your information to ESF DWP Managing Agent via the link below:

DWP’s Privacy Policy

DWPS’s personal information charter (or privacy policy) can be accessed via the following link:

The privacy policy contains the standards you can expect from them, how and why they use your personal information, and your rights and responsibilities.

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