Pathways 50+ Privacy Notice


Pathways 50+ Privacy Notice

Your Personal Information

Your personal data is information that relates to you as individual. If you can be identified directly or indirectly from information, it is your personal information.

For this project, the Secretary for Work and Pensions is the Data Controller. The Futures Group and Suffolk County Council are Data Processors, which means we process your data on the instructions of the Data Controller. We have committed to processing personal data no more than is necessary to deliver the Project.

The DWP personal informational charter explains how and why it uses your personal information and, importantly, ways to exercise your rights online or by post. Below, we have attached the

Because this form is hosted on Futures’ website, we are attaching our cookie notice.

Why We’re Processing Your Data

The SPARC project provides support to both SMEs and participants aged 50 or over, through a combination of expert information, advice, guidance, business support services and grant funding. 

We need to collect and use personal data in order to fulfil these duties. 

This privacy notice explains how the SPARC project uses information about you when you contact us or use our services, and how we protect your privacy.


We collect your data for the following reasons:

  1. To confirm eligibility for participation in a European Social Fund project;
  2. To verify, with a payslip, that funding delivered to an employer has been used to support an individual’s placement
  3. To report, manage,


Our reasons for using personal information include:

  • delivery of services and support to you
  • monitoring and protecting public spending


The types of personal data we process and where it comes from

We are collecting personal data either from you directly, through job boards like Indeed, or from third-party referrals, such as the National Careers Service, JETS and DWP. If you gain a placement, we will receive data, such as your payslip, from the employer to prove that you have been paid.


Personal Data Collected

Directly from you

Name, Address, Contact Phone Number, Email Address, CV, Right to Live and Work Evidence, Date of Birth Evidence and Gender

From a Job Board

Name, Address, Contact Phone Number, Email Address and CV

From a 3rd party referral

Name, Address, Contact Phone Number, Email Address, CV, Date of Birth and Gender


We will not receive more information than is necessary for these purposes.

Where Futures was the data controller for any special category data collected – data such as information about your race or health/disability - we collected that data on the basis of your explicit consent. We erase special category data where it is no longer necessary for the intended purposes.


Data Sharing and Retention.

To deliver this project, we need to share information with our project partner, Suffolk County Council, and the Data Controller, the Department for Works and Pensions (DWP). For detailed information on how the information you provide to us will be shared with the DWP, please see the DWP Participant Privacy Notice, available at the end of this document.

Where possible, we send anonymous data to Suffolk County Council, i.e. statistical data that does not reveal your identity.

Data collected by the DWP and SCC on behalf of the ESF will be retained for the duration of the project (i.e. December 2023). It will be destroyed by the DWP either at the project’s end, 10 years from the end of the project,

The SPARC project shares information during implementation of the project with the following recipients:

  • The Managing Authority and Data Controller, the Department for Work and Pensions, for the project’s Funder, the European Social Fund. Please see the DWP Personal Information Charter and the DWP’s Participant Privacy Notice below.
  • Our partner organisation, Suffolk County Council - A copy of the Council’s Data Protection Policy and Privacy Notice is available to download from 
  • Our external evaluator or auditors.

We do not transfer any personal data to any countries or international organisations outside of the UK.


Your Legal Rights, Our Legal Basis for Processing

Because the Department for Works and Pensions justifies using your personal data for this project because it is necessary for a function of a government department, and your sensitive personal information because it is necessary for employment, social security and social protection processes, your rights are affected. Specifically, you have no right to have your data deleted (no right to erasure) nor do you have the right to transfer your personal data to another organisation (no right to portability). However, your other rights apply. You have:

  • the right to object to the use of your data, if you have a compelling reason to do so (right to object)

You also have:

  • The right to have request that your information be corrected or completed, if it’s inaccurate or incomplete (the right to rectification)
  • The right to limit the use of your personal data, for example because you issues with the content of the information held or how it has been used (the right to restrict processing)
  • The right to receive a copy of your personal data (the right of access)
  • The right to be informed, such as through these privacy notices.
  • The right to complain to us, the DWP, or the Information Commissioner if you are have concerns about the use of your personal data.

Normally, you cannot and will not be charged for exercising your rights.


How to complain

If you have concerns about our use of your personal information, you can complain directly to the DWP, to us, or to the Information Commissioner’s Office (the ICO). (The ICO is the authority that oversees privacy and data protection in the United Kingdom.)

The Department for Works and Pensions

Department of Works and Pension Personal Information Charter, How to exercise your rights

Futures’ Data Protection Officer:

Krystl Robinson-Assan

ICO Data Protection Complaints

Make a complaint online

By phone: 0303 123 1113

By Post:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow, Cheshire



Department for Work and Pensions

Participant Privacy Notice - European Social Fund Projects

Purpose:   The information you provide to Suffolk County Council will be shared with the Department for Work & Pensions (DWP) and used to evaluate this project and to report to the Suffolk County Council and European Social Fund for monitoring purposes, in line with European Commission regulatory requirements.

Your information will also be shared with research organisations working on behalf of the Department for Work & Pensions who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary and you will be asked to consent before taking part in any research activity you may be contacted about.


The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left. This information may also be shared with research organisations working on behalf of the DWP however individuals will not be identifiable and you will not be contacted about this research. Data will not be used or shared for any commercial or marketing purposes.   At all times your information will be kept securely, and nobody will have access to it that shouldn’t.

Lawful Basis for the processing:  For the purposes of the General Data Protection Regulation (GDPR), the DWP is the data controller in respect to information processed which relates to all participation in the European Social Fund. ESF grant beneficiary organisations are data processors in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund.

DWP is not the controller for any other / additional data collected by Suffolk County Council that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by Suffolk County Council. The ESF Programme Action Note 018/18 sets out the lawful basis for processing personal data under ESF: the processing is necessary for a task in the public interest or in the exercise of the DWP’s official authority.

Retention periods for personal data: All personal data held by DWP or research contractors for the purposes of evaluation will be permanently deleted no more than six months after the research has been completed (i.e. when the final report is published on GOV.UK). Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK at: ESF Document Retention Guidance for the 2014-2020 ESF Programme (