This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data, and keep it safe.
We know that there's a lot of information here but we want you to be fully informed about your rights, and how we at Futures, use your data.
We hope the following information will answer any questions you have but if not, please do get in touch with us. We've broken it up into sections so it's easy for you to access.
It's likely that we'll need to update this Privacy Notice from time to time. We'll notify you of any significant changes when you visit our website.
The Futures Group – which we'll refer to as 'Futures' in this information – is made up of a number of related brands and businesses: Futures for You, Futures for Business and Futures Employment Solutions.
To keep things simple throughout this notice, 'we' and 'us' means the Group and its brands.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent - In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters, when you register with an account on one of our websites. When collecting your personal data, we'll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations - In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you access the National Careers Service that we deliver, we'll collect your contact details so we can get in touch with you to see how you're getting on with the action plan we create with you.
Legal compliance - If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the Group to law enforcement.
Legitimate interest - In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your contact details to send you information related to services you have accessed.
We also combine the satisfaction level of our customers to identify trends and ensure we can keep our services of high quality. We will also use your contact details to send you direct marketing information by post or email telling you about products and services that we think might interest you, unless you ask us not to.
- When you visit any of our websites, and use your account to apply for a job.
- When you create an account with us.
- When you purchase a product or service or by phone but don't have (or don't use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask one of the Group to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event, for example a careers advice session.
- When you choose to complete any surveys we send you.
- When you fill in any forms. For example, if an accident happens in one of our offices.
- When you've given a third party permission to share with us the information they hold about you.
- When you use our offices which have CCTV systems operating for the security of both customers and colleagues. These systems may record your image during your visit.
If you have a web account with us: your name, date of birth, address, application details, email and telephone number. For your security, we'll also keep an encrypted record of your login password.
Details of your interactions with us through our contact centre.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of your satisfaction levels, web pages you visit and how and when you contact us.
Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
For example, when we're checking your eligibility for one of our Apprenticeships.
Details of your visits to our websites, and which site you came from to ours.
Personal details which help us to recommend items of interest.
We'll only ask for and use your personal data collected for recommending items of interest and it's always your choice whether you share your details with us.
Your image may be recorded on CCTV when you visit an office with this in place.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and IP address where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. We use Google analytics so this information is aggregated.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. This is more likely to apply if you're a business we're providing services to.
Of course, if you wish to change how we use your data, you'll find details in the 'What are my rights?' section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you've asked for.
For example, if you've asked us to keep you updated with services we provide, we can't do that if you've withdrawn your general consent to hear from us.
Here's how we'll use your personal data and why:
To delivery any services, products or contracts you are accessing through one of our centres.
To respond to your queries, and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our customers, premises, assets and Group from crime, we operate CCTV systems in some of our premises which record images for security. We do this on the basis of our legitimate business interests.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We'll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, and legally required information relating to the services we provide. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
For example, we'll record your browser's Session ID to help us understand more when you leave us online feedback about any problems you're having.
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account on one of our websites or by contact us to let us know you want withdraw consent.
To process your booking/appointment requests (such as with a careers adviser).
Sometimes, we'll need to share your details with a third party who is providing a service (such as the DWP or one of our sub-contractors). We do so to maintain our appointment with you. Without sharing your personal data, we'd be unable to fulfil your request.
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using 'https' technology. Access to your personal data is password-protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
Whenever we collect or process your personal data, we'll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
- National Careers Service – 6 years
- Adult Education Budget – 12 years
- Community Grants – 12 years
- Young People Service – 7 years
We sometimes share your personal data with trusted third parties.
For example, local authority, department for work and pensions, education and skills funding agency, to handle complaints, to fulfil statutory obligations, to help us personalise our offers to you and so on.
Here's the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Direct marketing companies who help us manage our electronic communications with you.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
For further information please contact our Data Protection Officer.
To help personalise your journey through our services we currently use the following companies who will process your personal data as part of their contracts with us:
An overview of your different rights
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact The Data Protection Officer, The Futures Group, Fifth Floor, Pearl House, Friar Lane, Nottingham NG1 6BT or email email@example.com.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, for example you continue to access our services.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
There are several ways you can stop direct marketing communications from us:
Click the 'unsubscribe' link in any email communication that we send you. We will then stop any further emails from that particular division.
Write to The Futures Group, Fifth Floor, Pearl House, Friar Lane, Nottingham NG1 6BT.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven't been covered, please contact our Data Protection Officer who will be pleased to help you:
Data Protection Officer
The Futures Group
Fifth Floor, Pearl House
Tel: 08000 85 85 20