STEP Ukraine: privacy notice
This privacy notice explains how and why we use your personal data within the STEP Ukraine programme.
The Department for Levelling Up, Housing and Communities (DLUHC) is offering an English language and employment support programme (also known as STEP Ukraine) for up to 10,000 Ukrainians across the UK. The aim of STEP Ukraine is to help you improve your English language skills and gain employment or employment more commensurate with your skill level through the provision of English language training and employment support. The STEP Ukraine programme is delivered by World Jewish Relief in partnership with the British Council.
This privacy notice explains how and why we use your personal data within the STEP Ukraine programme.
1. The identity and contact details of the Department for Levelling Up, Housing and Communities (DLUHC) and our Data Protection Officer
DLUHC is the “data controller” for your personal data where you take up the offer of English language training, and/or employment support within STEP Ukraine, and we need to collect and use your data to deliver this to you. “Data controller” means that we are responsible for your personal information under UK data protection law (UK GDPR).
EnglishScore is another data controller whose role is to deliver English language tests and exams for STEP Ukraine participants, after you complete English language training. This means that they will be separately responsible for your data at the stage that you seek to take these exams. See the EnglishScore privacy notice.
DLUHC ‘s Data Protection Officer can be contacted at dataprotection@levellingup.gov.uk.
2. Why we are collecting and using your personal data
We require your personal data to be able to provide you with English language training and / or to help facilitate employment support. If you choose to participate in the STEP Ukraine programme. EnglishScore also needs to use your personal data in its role of providing and invigilating your language exams.
3. What data we are collecting
To administer and deliver English language training we will collect and use the following information about you:
- Your name
- Your unique student identification number
- Course stage you’re at – for example if you’ve enrolled and how many lessons you’ve taken
- Your attendance levels (days and hours attended)
- English proficiency, including assessment scores
- Technical data from use of our websites – for example your Internet Protocol address and cookie session data
EnglishScore – who are entirely separate from DLUHC – will provide testing and certification of your English language proficiency. They will need to use:
- Your name, including to provide you with exam certificates if you pass.
- Your student unique identification number
- Your English language scores
- Information relating to photos of you and/or facial recognition – to verify that the student taking a test online or remotely, is really you
- Recordings of your voice (to test your speaking skills)
- English proficiency including assessment scores
Further details of data collected by EnglishScore can be found in the EnglishScore privacy notice.
To administer and deliver employment support, and evaluate the STEP Ukraine programme we will collect and use the following information about you:
- Name
- Address
- Email address
- Telephone number
- Date of birth and age
- National insurance numbers
- Region you live in
- Sex
- Languages
- Family information
- Disability and accessibility needs
- Childcare needs
- Recent Photograph of you
- Visa details, including nationality and BRP status (Biometric Residence Permit)
- Duration spent in UK
- Employment status, employment history and qualifictions (including Resumé)
- If you have used a work coach from the Department for Work and Pensions (DWP)
- Student unique identification numbers, application numbers and enrolment numbers
- Dropout levels and reasons as to why learners left the programme
- Employment outcomes (employment levels pre and post intervention)
- The changes in the attitudes of learners to employment prospects/English language ability
- Attitudes of attendees to employment prospects/language acquisition (through pre and post intervention surveys)
- Technical data from use of our online services – for example your Internet Protocol address, cookie session data
4. Lawful basis for processing the data
We must have a lawful basis under UK data protection law to use your personal data lawfully. The relevant lawful basis for processing personal data is:
- UK GDPR Article 6(1) (e) - processing is necessary for the performance of a task carried out in the public interest
- Data Protection Action 2018 (DPA) – Part 2, Chapter 2, Section 8 - processing of personal data that is necessary for the exercise of a function of the Crown, a Minister of the Crown or a government department
We may process personal data that is more sensitive about you, which is called “special category data”. This can include biometric information (such as biometric residence permits). We require an additional lawful basis to do this which is the following:
- UK GDPR Article 9(2)(g) processing is necessary for reasons of substantial public interest
- DPA 2018 – Schedule 2, Part 1, section 6 – processing necessary for the exercise of a function of the Crown, a Minister of the Crown or a government department
We also treat any nationality data about you as special category data
Please note that EnglishScore explain their own lawful basis in the EnglishScore privacy notice.
5. With whom we will be sharing the data
World Jewish Relief – are our main “data processor” delivering the STEP Ukraine programme. They will only process personal data under strict terms we have put in place with them. World Jewish Relief are using the following providers to help them deliver STEP Ukraine:
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The British Council – who are facilitating the English language support offer to you, training for which will be provided by trainers provided by the British Council.
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CaseWorthy – for data recording and storage of your personal data.
HM Revenue and Customs (HMRC) – World Jewish Relief will also share your National Insurance number with HMRC. This is for the purpose of monitoring the effectiveness of the STEP Ukraine programme – from National Insurance number sharing, HMRC will be able to tell DLUHC how many STEP Ukraine participants in total have been successful in gaining employment or had changes in employment. Data returned from HMRC to DLUHC will be anonymised, so we cannot identify you or other participants when monitoring outcomes from the scheme.
EnglishScore – who are the provider of English language tests and exams relating to your training.
Microsoft Corporation – DLUHC uses this company for its own IT services.
DLUHC will share anonymised data with all UK devolved administrations (the Scottish Government, Welsh Government and Northern Ireland Executive) for STEP Ukraine programme monitoring and evaluation purposes. “Anonymised” means that you cannot be identified from this information.
DLUHC may also publish anonymised data from this programme on gov.uk as part of reporting on the outcomes and impact of the STEP Ukraine Ukraine.
6. For how long we will keep the personal data, or criteria used to determine the retention period
Your personal information will be destroyed under the instruction of DLUHC at the point the data is no longer needed, in July 2025.
7. Your rights, e.g. access and rectification
The data we are collecting is your personal data, and you have rights that affect what happens to it. Generally, you have the right to:
- know that we are using your personal data
- see what data we have about you
- ask to have your data corrected, and to ask how we check the information we hold is accurate
- complain to the Information Commissioner’s Office (see below)
If you wish to use any of these rights you should first contact dataprotection@levellingup.gov.uk.
8. Sending data overseas
World Jewish Relief, our main delivery provider, are using a data systems provider – CaseWorthy – who are based in the United States of America (USA), and your personal data will be transferred and processed there as part of administering STEP Ukraine.
DLUHC has ensured that appropriate UK GDPR safeguards have been put in place by World Jewish Relief to ensure that your data is processed securely and safely while in the USA.
Please note that EnglishScore are separately responsible for any personal data they may send overseas when administering your English language test exams; please refer to the EnglishScore privacy notice.
As a temporary data storage solution, all of the personal data listed above will be stored in the UK between August 2023 and October 2023 apart from survey results which will be stored in the UK between August 2023 and December 2023. From October 2023 to August 2025, the supplier will store and manage all of the personal data listed above in CaseWorthy servers located in the United States (state of Utah).
Any personal data you provide during the signup process will be temporarily stored in the UK and transferred to CaseWorthy servers in the USA. Any surveys you complete up until December 2023 will be temporarily stored in the UK and transferred to CaseWorthy servers in the USA. Once data has been transferred to the USA, all copies of the data held in the UK will be destroyed.
9. Automated decision making
We will not use your data for any automated decision making.
10. Storage, security and data management
Your personal data will be stored securely. Where data is shared with third parties, as set out in section 5 above, we require third parties to respect the security of your data and to treat it in accordance with the law. All third parties are required to take appropriate security measures to protect your personal information in line with our policies.
11. Complaints and more information
When we or our supplier ask you for information, we will keep to the law, including the Data Protection Act 2018 and UK General Data Protection Regulation.
If you are unhappy with the way the Department has acted, you can make a complaint.
If you are not happy with how we are using your personal data, you should first contact dataprotection@levellingup.gov.uk.
If you are still not happy, or for independent advice about data protection, privacy and data sharing, you can contact:
The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745