Policies

PURPOSE

Progressive Independence Limited is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, store, share and protect personal information when you visit our website, contact us, enquire about our services, make or are the subject of a referral, apply for employment, or otherwise interact with Progressive Independence.

This public Privacy Policy should be read alongside any additional privacy information provided to you when personal information is collected. It sits alongside Progressive Independence’s internal Data Protection, Data Retention, Information Security, GDPR and Data Protection Training, Data Breach Response and Notification, and E-Safety policies.

1. WHO WE ARE

For the purposes of UK data protection law, Progressive Independence Limited is responsible for deciding how and why personal information is processed where we act as the data controller.

• Legal entity: Progressive Independence Limited

• Company number: 15148532

• Registered address: 48-52 Penny Lane, Liverpool, L18 1DG

• Website: https://progressive-independence.co.uk

• General and data protection enquiries: contact@progressivei.co.uk

• Telephone: 0151 374 0874

In some circumstances we may process information jointly with another organisation, or process information on behalf of another organisation such as a local authority or placing authority. Where relevant, the applicable arrangements will be explained to the individual.

2. PERSONAL INFORMATION WE MAY COLLECT

Website visitors

When you use our website, we may collect technical and usage information necessary to operate, secure and understand use of the website, including:

• your IP address;

• browser and device information;

• pages visited and information about how the website is used;

• technical information required to operate and secure the website;

• information collected through cookies and similar technologies.

People who contact us

• your name and contact details;

• organisation and job title, where relevant;

• the content of your enquiry;

• information you choose to provide;

• records of correspondence and communications.

Referrals and enquiries about our services

Where an enquiry or referral is made about our services, we may process information necessary to assess and respond to it. This may include information about a child or young person, including:

• identity and contact information;

• circumstances and support needs;

• care history;

• education;

• health and wellbeing;

• safeguarding concerns;

• risks and behaviours;

• family and social circumstances;

• accommodation and placement requirements;

• information supplied by a local authority, placing authority or other professional.

Some of this information may be special category personal data or information relating to criminal offences. We only process such information where there is an appropriate lawful basis and, where required, an additional condition under data protection law.

Recruitment

If you apply for employment with Progressive Independence, information we may process includes:

• name and contact details;

• CV, application form and supporting information;

• employment history, education, qualifications and training;

• references and referee details;

• identity, proof of address and right-to-work information;

• driving licence information where relevant;

• interview and assessment information;

• reasonable adjustment information;

• equality and diversity monitoring information where collected;

• DBS, overseas criminal record and other safeguarding or suitability information where required;

• recruitment correspondence, decisions and outcomes.

3. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

• directly from you;

• through website forms, email or telephone;

• when you apply for a job;

• from local authorities, placing authorities and other professionals making referrals;

• from recruitment agencies, previous employers and referees;

• from qualification or training providers;

• from DBS and other relevant checking services;

• from publicly available sources where appropriate and lawful;

• through cookies and similar technologies;

• from third-party recruitment, HR, IT and other service providers acting on our behalf.

4. HOW WE USE PERSONAL INFORMATION

Depending on the circumstances, we may use personal information to:

• respond to enquiries and communicate with you;

• provide and manage care and support services;

• assess referrals, needs, risks and placement enquiries;

• safeguard children and young people;

• communicate with local authorities, placing authorities and other professionals;

• manage complaints, concerns and safeguarding matters;

• recruit and assess applicants and complete pre-employment and safeguarding checks;

• manage our workforce and employment processes;

• meet legal, regulatory and record-keeping obligations;

• manage and secure our premises, systems, website and IT;

• monitor and improve our services;

• respond to legal or regulatory requests and establish, exercise or defend legal claims;

• prevent and detect fraud, crime or other unlawful activity.

5. LAWFUL BASES FOR PROCESSING

We only process personal information where we have a lawful basis. Depending on the circumstances, this may include:

• Consent - where consent is appropriate and required. Consent can be withdrawn at any time, although this does not affect processing already carried out or processing supported by another lawful basis.

• Contract or pre-contractual steps - where processing is necessary to enter into or perform a contract, including relevant employment arrangements.

• Legal obligation - where processing is necessary to comply with legal, regulatory, employment, safeguarding, health and safety or record-keeping obligations.

• Legitimate interests - where processing is necessary for our legitimate organisational interests and those interests are not overridden by the rights and interests of the individual.

• Vital interests - in exceptional circumstances where processing is necessary to protect someone’s vital interests.

• Public task - where applicable, where processing is necessary for a task carried out in the public interest or under official authority.

6. SPECIAL CATEGORY AND CRIMINAL OFFENCE INFORMATION

Our work with children and young people means we may need to process particularly sensitive information, including information about health, disability, racial or ethnic origin, religion or beliefs, sexual orientation, biometric information where applicable, and safeguarding matters. We may also process criminal conviction and offence information, including DBS and overseas criminal record information where relevant and necessary.

We will only process this information where permitted by law and where the required safeguards and additional legal conditions are in place. Safeguarding information may be shared with appropriate organisations or professionals where this is necessary and lawful to protect a child, young person or another individual.

7. CHILDREN AND YOUNG PEOPLE

We recognise that children and young people require particular protection when their personal information is processed. We take appropriate steps to ensure their information is collected and used fairly and lawfully, limited to what is necessary, kept accurate where appropriate, stored securely, accessed only by those who need it, and retained only for as long as necessary or required.

Where appropriate, privacy information will be provided directly to children and young people in a clear and accessible way that takes account of age, understanding and individual circumstances.

8. WHO WE MAY SHARE INFORMATION WITH

We may share personal information where this is necessary, lawful and proportionate. Depending on the circumstances, this may include:

• local authorities, placing authorities, social workers and Leaving Care Teams;

• Ofsted and other relevant regulators;

• health professionals and NHS services;

• education providers;

• safeguarding professionals;

• police and emergency services;

• independent advocacy services;

• other professionals involved in a person’s care or support;

• referees, previous employers, DBS and other vetting organisations;

• payroll, HR, recruitment, IT, hosting and data-storage providers;

• professional advisers, insurers, courts, tribunals and other authorities where required or permitted by law.

We do not sell personal information to third parties. Where another organisation processes personal information on our behalf, appropriate contractual, technical and organisational safeguards will be used.

9. RECRUITMENT AND APPLICANT INFORMATION

Recruitment information is used to assess suitability, communicate with applicants, arrange interviews and assessments, verify information, obtain references, confirm the right to work, complete safeguarding and vetting checks, consider reasonable adjustments and make and document recruitment decisions.

If you are unsuccessful, we will normally retain recruitment information for six months after the recruitment process concludes. If you separately agree to be considered for future vacancies or join our talent pool, relevant recruitment information may be retained for up to nine months after the recruitment process concludes. You may withdraw consent for future-vacancy consideration where consent is the lawful basis being used.

If you are appointed, relevant recruitment information will become part of your employee record and will be managed in accordance with our employee records and applicable retention requirements. Detailed DBS certificates and other detailed criminal-record information will not be retained for longer than reasonably necessary, subject to legal, regulatory or safeguarding requirements.

10. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies to operate correctly, remember preferences, understand how the website is used and support embedded or third-party functionality. These may include strictly necessary, analytics, functional and third-party cookies.

Where consent is required for non-essential cookies, we will seek consent before using them. You can manage cookie preferences through the controls provided on our website and, where applicable, through your browser settings. Further information about the cookies actually used by our website will be provided in our Cookie Policy or cookie-management information.

11. SECURITY

We use appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, destruction, misuse, alteration and unauthorised disclosure. Access to personal information is restricted according to role and need. Our internal information-security arrangements include controls for company systems, devices, access, storage, secure communication and the reporting of security incidents.

No website, email service or electronic transmission can be guaranteed to be completely secure. Please avoid sending unnecessary sensitive information through standard website forms or unsecured email unless specifically requested.

12. HOW LONG WE KEEP PERSONAL INFORMATION

We retain personal information only for as long as it is required for the purpose for which it was collected, or for any longer period required by law, regulation, safeguarding responsibilities, contractual obligations or the establishment, exercise or defence of legal claims. Retention periods vary according to the type of record and why it is processed.

• Unsuccessful recruitment candidates: normally six months after the recruitment process concludes.

• Talent pool/future vacancy candidates: up to nine months where the individual has separately agreed to future-vacancy consideration and an appropriate lawful basis applies.

• Successful candidates: relevant information transfers to the employee record.

• Detailed DBS/criminal record information: securely destroyed when no longer reasonably required, subject to applicable legal, regulatory or safeguarding requirements.

Other records are retained in accordance with Progressive Independence’s internal retention requirements. When information is no longer required, it will be securely deleted, destroyed or anonymised where appropriate.

13. INTERNATIONAL TRANSFERS

Some service providers may process or store personal information outside the United Kingdom. Where personal information is transferred outside the UK, we will ensure the transfer complies with applicable UK data protection law and that appropriate safeguards are in place, such as an adequacy decision or appropriate contractual safeguards where required.

14. YOUR DATA PROTECTION RIGHTS

Depending on the circumstances and the lawful basis for processing, you may have the right to:

• request access to personal information we hold about you;

• request correction of inaccurate or incomplete information;

• request erasure where there is no lawful reason for us to continue processing;

• request restriction of processing in certain circumstances;

• object to certain processing;

• request data portability in certain circumstances;

• withdraw consent where consent is relied upon;

• object to direct marketing;

• request information about automated decision-making where applicable.

These rights are subject to legal conditions and exceptions and will not apply in every circumstance. We do not currently make recruitment decisions based solely on automated processing that produces legal or similarly significant effects.

15. DATA PROTECTION REQUESTS

To exercise a data protection right or ask a question about how your information is processed, please contact:

• Email: contact@progressivei.co.uK

• Telephone: 0151 374 0874

• Post: Progressive Independence Limited, 48-52 Penny Lane, Liverpool, L18 1DG

We may need to verify your identity before responding. Requests will normally be dealt with within the applicable statutory timeframe.

16. COMPLAINTS

If you have concerns about how Progressive Independence has handled your personal information, please contact us first so that we can investigate and seek to resolve the matter. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

• Information Commissioner’s Office website: https://ico.org.uK

• Telephone: 0303 123 1113

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our services, website, processing activities, technology, legal requirements or regulatory guidance. The latest version will be published on our website.

18. CONTACT US

• Progressive Independence Limited

• Email: contact@progressivei.co.uK

• Website: https://progressive-independence.co.uK

• Registered address: 48-52 Penny Lane, Liverpool, L18 1DG

• Telephone: 0151 374 0874

Policies

This website uses cookies.