Guidance

Fast Stream and Emerging Talent Programme data privacy notice

Updated 21 May 2020

1. Your data

1.1 Purpose

The purpose(s) for which we are processing your personal data is:

• to record, track and respond to correspondence from pre-registered individuals who apply for Fast Stream registration. A correspondence log will be held on a secure Fast Stream support site relating to any issues, questions or concerns individuals may have with Fast Stream
• operation of the Fast Stream graduate recruitment campaigns including assessing candidates, matching individuals with potential jobs and learning activities. In addition, throughout their time on the Civil Service Fast Stream Programme, we use this information internally to contact individuals at various points to provide them with necessary information about their postings, secondment placements and career options, or for those who have indicated that they want to become ambassadors for and participants in future promotional campaigns
• for the on-boarding and posting operations of candidates, sourcing, recording details, undertaking analysis of candidates skills, experience and qualifications against suitable matching roles. Informing government departments and the wider Civil Service HR community of suitably matched roles for new candidates and providing posting-related data to those stakeholders
• supplying information to other relevant government departments including: for security clearance purposes, Fast Stream ongoing career opportunities/secondments, Fast Stream career progression, wider Civil Service opportunities, including the Direct Appointment Scheme, and performance monitoring and reporting
• informing other government departments, wider Fast Stream Emerging Talent (FSET) team and professions of a candidate’s progression and performance
• analysing Fast Stream operational data to inform our current and future activities
• recording the commencement and exit of career and place of work, destinations of successful scheme applicants and tracking security clearance progress, coaching, recording applicants’ preferences and correspondence
• for analysis in measuring performance marking for consistency and fairness, benchmarking and comparison of diversity and talent against industry standards it is necessary to process diversity related data to comply with our legal obligations as a data controller in order to protect your rights under employment and social security law and social protection
• it is necessary to comply with a legal obligation placed on us as the data controller under s.39 of the Equality Act 2010 relating to disabilities and health
• to monitor the effectiveness of the Fast Stream recruitment process
• in order to assign an email address to those individuals on the Fast Stream and Emerging Talent scheme
• providing HR related data to our services partner in order to set individuals up on the payroll system
• to facilitate the registration and use of the Fast Stream online platform by candidates: enable candidates to create an online account and apply for the Fast Stream scheme, to take online tests, upload and collect score results and input feedback comments, to enable the upload, reading and sift of additional information forms, and to be able to accept Fast Stream Assessment Centre and Final Selection Boards invitations. Data is also used to provide scheme assessor availability and for them to activate an online account and evaluate candidates
• to ask for feedback of fast streamer’s experiences on the programme and about our service, or to invite individuals to be part of a test group for research purposes
• with your consent, we will continue to hold your contact details for the purposes of contacting former members of the Fast Stream about possible alumni events, development activities, assessment and selection of future talent and volunteering opportunities such as helping with our schools and university outreach work

Photographs, audio and videos may also be taken of individuals who have indicated that they want to become ambassadors for and participants in future promotional and talent scheme marketing campaigns. Subject to an individual’s explicit agreement, we may then use their photograph, audio and videos for this purpose although they are not required or obligated to do so.

1.2 The data

Pre-registration

We will initially process the following basic personal data as part of your pre-registration interest in joining the Fast Stream programme:

• personal names (first name(s) / surname)
• email address (telephone / mobile contact number)

If we seek feedback from you on the application process where you discontinue your application, we will also process:

• opinions
• ethnicity data

Pre-employment recruitment data

We will then process the following personal data if you decide to formally apply to join one of these programmes and it will form part of the pre-employment checks that we are required to undertake about you:

• address (place of residence / or address to be used for correspondence)
• telephone numbers
• email addresses
• bank account details
• ID / address verification documentation:
• drivers licence
• birth
• marriage / civil partnerships
• utility / council tax bills
• credit card / bank or mortgage statements
• welfare benefit entitlement letters
• passport information
• carer’s passport (applicable where individuals have this personal responsibility)
• nationality, UK Immigration / residency and any visa restrictions
• age / date of birth
• parents’ employment / occupation
• gender and sexual orientation
• criminal offences and convictions
• religious beliefs
• educational / professional qualifications and membership
• educational institution attendance details (schools, colleges, further education / higher education)
• free school meal eligibility (for diversity monitoring)
• employment history
• National Insurance number
• tax documents (P45 / P60)
• sickness absences, health, disability, impairment and personal medical conditions
• as a ‘Disability Confident’ (Guaranteed Interview Scheme) employer we will also process Support / Reasonable Adjustment requirements including records of conversations about a candidates requests
• work location / work location preference / travel requirement plus supporting reasons

Pre-employment Video Interview assessment data

We will then process the following personal data if you decide to progress to the Video Interview stage of your application:

• video recording of you from the interview, containing your image and voice

For successfully on-boarded Fast Stream candidates

Once a candidate has been successfully recruited we will process the following data throughout your time on your programme:

• any correspondence you may have placed with the Fast Stream support site
• salary and payroll / staff ID number
• job role / title
• line manager contact details and line management performance reports
• security clearance level / status and expiry date
• Fast Stream and Emerging Talent Coaching data [Name, contact details (phone and email)]
• Fast Stream Assessment Centre number
• individual assessment / selection scores
• personal opinions and feedback of Fast Stream individuals about their experiences within a particular posting
• scheme details of Fast Stream prior to their leaving the scheme
• Fast Stream individuals personal contact information prior to their exit from the scheme, used for post scheme communications
• as a ‘Disability Confident’ (Guaranteed Interview Scheme) employer we will process Support / Reasonable Adjustment requirements. This data will include all requests (including records of conversations) and details of the support/ adjustments authorised.
• current and future locations when exiting the scheme
• personal reasons for departure from the Fast Stream schemes
• current and future locations prior to joining the Fast Stream schemes
• Fast Stream travel bookings and expense reimbursements
• destination of leavers from the Fast Stream schemes
• development Trajectory Assessment (DTA) and End of Scheme Assessment (ESA) score results and recommendations (name, staff number, Performance scores, opinions about the data subject)
• secondment host names / contact email / telephone number
• assessors names and contact details for Fast Stream and Internship schemes (both paid and unpaid, Civil Servant assessors including information about re-payment of travel, fees and subsistence to assessors)
• qualifications and results which have been taken as part of the Scheme
• IP address (where online surveys have been completed via survey software tools)
• photographs, audio and video which may be taken subject to explicit consent of the Fast Stream individual

Leaving the Scheme

When you leave the scheme we will ask for the following information (providing this information is entirely voluntary):

• preferred email contact (personal and/or new work email)
• preferred phone number
• what activities would you be interested in getting involved with as a member of the Fast Stream alumni network?
• the grade of your new role
• what geographical region your new role is in
• your profession
• how you found the new role
• is it your aspiration to become a senior civil servant (SCS)
• your age
• your gender
• your ethnicity
• your sexual orientation
• your family’s socio-economic background
• whether you have a physical or mental health condition, illness, impairment or disability

1.3 Legal basis of processing

The legal bases for processing your personal data are:

• it is necessary in order for us to begin and complete the required steps including preliminary pre-employment, social background and diversity monitoring checks, before a decision can be made about the offering of a formal contract of employment. It is also necessary for ongoing employment contract obligations thereafter including the monitoring of a successful candidate’s career progression and application of their salary uplifts
• processing is also necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. These tasks are essentially the operation, management and monitoring of all the Civil Service Fast Stream and Emerging Talent (FSET) programmes.
• processing is also necessary to comply with a legal obligation placed on us as the data controller under s.39 of the Equality Act 2010 relating to disabilities and health.
• with the consent of the individual, their photographs, audio and video may be taken and used for marketing events and promotional material. In addition, with consent we will keep contact details and details of diversity and onward assignments for those leaving the scheme.

Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

The legal bases for processing your sensitive personal data are:

It is necessary for the purposes of performing or exercising our obligations or rights as the controller. Or the data subject’s obligations or rights, under employment law, social security law or the law relating to social protection.This relates to public sector equality duty obligations in the employment context and this data includes details relevant to the operation of the Disability Confidence (Guaranteed Interview Scheme) process, and also to facilitate Fast Stream individuals who require specific workplace adjustments on the grounds of personal health conditions, impairments or disabilities, or also data relating to an individual’s religious beliefs. For example, so that workplace inductions dates can be considered accordingly.

Processing is of data concerning ethnicity, religious or philosophical belief, health including disability or sexual orientation, and it is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with a view to enabling such equality to be promoted or maintained.

It is necessary for the establishment, exercise or defence of legal claims, or in relation to a court acting in its judicial capacity – for example an employment tribunal. Application records are kept for audit and defence of legal claims purposes.

It is necessary for statistical purposes, and it is in the public interest e.g. analysis of applications and recruitment outcomes (including online tests), impact on protected groups, timescales. It is also necessary to monitor the effectiveness of the Fast Stream schemes and measure against the wider objectives of increasing Civil Service diversity in ensuring that our recruitment practices are fair.

For diversity data on those leaving the scheme, we rely on your consent.

The processing by us of personal data relating to criminal convictions and offences or related security measures is authorised because it is necessary for reasons of substantial public interest for the exercise of a function of the Crown, a Minister of the Crown, or a government department. Specifically this includes ensuring the individual’s right to work in the UK if they are not a British national and also eligibility for any appropriate security clearance.

1.4 Recipients

Your personal data will be shared by us:

• IT supplier of the Fast Stream support site
• with grade managers (based in other government departments)
• with departments security branches (based in other government departments)
• government finance, who are a part of HM Treasury (for the purpose of ensuring Finance Fast Streamers become qualified)
• with departments where security information (NI numbers, DOBs, clearance levels) is disseminated to confirm that the Fast Streamer has the appropriate security clearance required for when they transfer to their next new role
• with activity managers (based in other government departments and secondment host organisations)
• with Fast Stream scheme assessors
• with secondment host organisations
• with external third party assessment platforms (for the purposes of carrying out assessments, including video interviews, and the hosting of such assessments)
• as your personal data will be stored on our IT infrastructure it will also be shared with our data processors who provide email, and document management and storage services

Apprenticeship and additional learning providers

Until October 2017, the Fast Stream and Emerging Talent (FSET) team shared personal contact details with Ashridge Business School to facilitate their delivery of an optional two year Masters course for those on the Fast Stream programme. Although this course is now delivered in-house, there are still existing fast streamers on that Masters programme. Data is also shared with an online collaborative project management tool for organising and tracking secondment data and is restricted to the secondment team with only temporary access granted to other key users.

FSET coaching data is also shared with training providers where the contract is managed by Civil Service Learning. As your personal data will be stored on our IT infrastructure it will also be shared with our data processors and an online survey software provider.

1.5 Retention

Your personal data will be kept by us for two years in relation to the initial operation of the recruitment campaigns, and for any correspondence you may have logged with our Fast Stream support site.

Successful candidates will have further personal data processed throughout your time on the programme. This is done in order to manage you throughout your time on the scheme. This data will be retained for a maximum of five years which will normally coincide with the end of the individual’s completion of the Fast Stream programmes.

After five years the data will then be anonymised to enable any aggregated statistical analysis that may be required for research purposes.

If your photograph, audio and video is taken and used for marketing and promotional purposes, it will be kept by us for 3 years.

Data relating to any travel booking arrangements and any associated expenses repayments will be retained for 3 years for internal audit requirements.

We will keep your personal contact details for when you leave the scheme to keep you informed of any events or items that you would be interested in. This data will be held individually, with their consent refreshed no less frequently than once every two years.

All staff are trained to handle personal data, and it is given appropriate controlled access and is stored securely with restricted access.

Where personal data have not been obtained from you

Data is exchanged with and received from other government departments for the purpose of cross-referencing levels of security clearance held by an individual and also to enable authorised individuals to obtain staff building access passes.

As part of the necessary pre-employment security form checks we also exchange data with a third party support service who conduct pre-employment checks that include details of any disclosed criminal convictions and offences. The data held by the third party support service is kept securely as specified in their contract (managed specifically by Civil Service Resourcing), and destroyed securely when no longer needed.

All mentioned third parties are currently under contract with the Civil Service and are legally bound to process the data in line with the data protection regulations.

Data is also collected by online survey software for the purpose of assisting with postings and the contract is managed by the Government Recruitment Service.

Contact names and email addresses may also be passed to us by third party career development, recruitment and employment organisations where they have received details about potentially suitable applicants for one of the civil service talent schemes.

2. Your rights

You have the right:

• to request information about how your personal data are processed, and to request a copy of that personal data
• to request that any inaccuracies in your personal data are rectified without delay
• to request that any incomplete personal data are completed, including by means of a supplementary statement
• to request that your personal data are erased if there is no longer a justification for them to be processed
• in certain circumstances (for example, where accuracy is contested), to request that the processing of your personal data is restricted
• to object to the processing of your personal data where it is processed for direct marketing purposes
• to object to the processing of your personal data
• to request a copy of any personal data you have provided, and for this to be provided in a structured, commonly used and machine-readable format

In relation to the use of any data where we are relying on the lawful basis of consent (details above), you have the right:

• to withdraw consent to the processing of your personal data at any time

3. International transfers

As your personal data is stored on our IT infrastructure, and shared with our data processors, it may be transferred and stored securely outside the European Economic Area (EEA). Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses for certain key data processors. Data may be transferred outside the EEA where use is made by us of the collaborative online processing tool and our photographic image management agency but we would rely upon their adherence to the EU-US Privacy Shield Framework.

4. Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

5. Contact details

The data controller for your personal data is the Cabinet Office. In some cases your employing organisation may also be a data controller. This is only in cases where Cabinet Office has shared individual-level survey responses with an organisation (via a qualified analyst who has signed a data sharing agreement, as outlined above).

The contact details for the lead data-controller are:

Cabinet Office
70 Whitehall
London
SW1A 2AS
csps@cabinetoffice.gov.uk

The contact details for the lead data-controller’s Data Protection Officer (DPO) are:

Stephen Jones (DPO)
Cabinet Office
70 Whitehall
London
SW1A 2AS
dpo@cabinetoffice.gov.uk

The Data Protection Officer provides independent advice and monitoring of Cabinet Office’s use of personal information.