Guidance

Help to Grow: Management Essentials - privacy notice

Published 23 February 2024

This notice relates to personal data collected under the Help to Grow: Management Essentials scheme run by the UK government Department for Business and Trade (DBT). It sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the UK General Data Protection Regulation (UK GDPR).

The Help to Grow: Management scheme is funded by DBT and administered by The Chartered Association of Business Schools (CABS), the scheme administrator. DBT is the data controller and CABS is the data processor. See the CABS privacy notice.

References to ‘we’ and ‘our’ in this privacy policy mean DBT and the CABS. Any references in this privacy policy to ‘you’ or ‘your’ means the scheme participant.

Your data

If you apply for the Help to Grow: Management Essentials programme, we may use, store and transfer different kinds of personal data about you as follows:

  • identity data - includes first name, last name, job title, employer, the unique identifier assigned to you on registration, title, age and gender
  • contact data - includes employer address, email address and telephone numbers
  • technical data - includes, but is not limited to, traffic data, browser data, internet protocol (IP) address, weblogs, platform used and other communication data
  • profile data - includes feedback and survey responses, information you provide regarding your role at your business, information regarding your interactions with our email communications and attendance at our events
  • usage data - includes information about how you use our website

We may use special category data revealing racial or ethnic origin and disability with your consent.

Purpose

The purpose(s) for which we are processing your personal data is that it is necessary for the performance of a task carried out in the public interest.

Your data may also be used for statistical research to inform adjustments in scheme delivery and the evaluation of the programme and where it’s necessary for the purposes of the prevention, investigation, detection or prosecution of criminal offences including fraud.

The legal basis for which we are processing your personal data is:

Public task

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 data controller, in this case the function is to ensure that we can monitor and evaluate the effectiveness of the programme, thereby ensuring value for money and the proper use of public funds.

The legal basis for processing your special category data (also known as sensitive personal data) is because we have a basis in law to understand the equality impacts of this programme to help us comply with our Public Sector Equality Duty Section 149 of the Equality Act 2010.

Special category 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.

Recipients

Your personal data will be shared by us with:

  • Indigo Tree Digital, our virtual learning environment providers, to create your participant profile on the online platform and deliver the programme content to you
  • our evaluation partners for the purpose of evaluating the Help to Grow: Management programme only
  • the Cabinet Office and to guide their communications campaign for the Help to Grow: Management programme
  • HM Revenue and Customs (HMRC) in connection with the promotion and evaluation of the Help to Grow: Management programme
  • third parties for the purposes of completing tasks and delivering services to you on our behalf
  • third party providers to send our newsletter: Salesforce (Saleforce’s privacy information), WordPress (WordPress’ privacy information) and Campaign Monitor (Campaign Monitor’s privacy information)
  • Change++ to produce automated reports on the personal data that we collect about you and other users/participants through our website and our virtual learning environment platform (Change++ privacy information)

As your personal data will be stored on our IT infrastructure, it will also be shared with our data processors Microsoft and Amazon Web Services.

Retention

In accordance with the UK GDPR and the Data Protection Act 2018, we will retain personal data, and any special category personal data that is collected by CABS with your consent, will be kept for no longer than is necessary for the purposes for which it is being processed. That is, it will be retained for evaluation and monitoring of the Help to Grow: Management Essentials programme and shall be deleted by us and our appointed evaluators of the programme once the evaluation is complete. You can withdraw consent, see the Your rights section below for further information.

The business school where you enrol or the mentor you work with may retain your personal data for as long as is necessary for the purposes for which they process it. For more details, please contact your business school.

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
  • request that any inaccuracies in your personal data are rectified without delay
  • request that any incomplete personal data are completed, including by means of a supplementary statement
  • 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
  • object to the processing of your personal data where it is processed for direct marketing purposes
  • object to the processing of your personal data
  • 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

A full list of your rights under the General Data Protection Regulation (GDPR) is available on the ICO website.

Complaints

Data controller

The data controller for your personal data is the Department for Business and Trade (DBT). You can contact the DBT Data Protection Officer at:

Contact the DPO:

DBT Data Protection Officer
Department for Business and Trade
Old Admiralty Building
London
SW1A 2HQ

Email dataprotection@businessandtrade.gov.uk

Data processor

The data processor for your personal data is the Chartered Association of Business Schools (CABS). You can contact the CABS Data Privacy Manager at:

Ramin Bokaian
Chartered Association of Business Schools
3rd Floor
40 Queen Street
London
EC4R 1DD

Email: ramin.bokaian@chartereabs.org

Telephone 020 7236 7678

Information Commissioner

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

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Email casework@ico.org.uk

Telephone 0303 123 1113

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