As we wrote to you last year, your child’s school, along with 29 other schools, took part in an exciting programme called the “Community Apprentice”. This programme, delivered by a charity called Envision, is designed to help young people develop the skills they need to succeed, particularly in the workplace. We’re writing to you to provide updates on the evaluation of this programme and how your child’s data will be used.
The Behavioural Insights Team (BIT), a social purpose research company specialising in the application of behavioural science, was commissioned by the Education Endowment Foundation (EEF) to conduct a research project to determine the impact of this programme. By taking part in the programme, your child’s school agreed to take part in this research. You received information about this in the Autumn of 2017.
You will be able to find out about the insights from this project in Autumn 2020.
Updates on the evaluation
We are interested in learning the long-term effects of the programme on educational and career results and choices. In order to do so, BIT will be accessing the following data on your child, held in central databases (such as the National Pupil Database, Individual Learner Record, the Higher Education Statistics Authority data, and Longitudinal Education Outcomes database):
- Course information and attainment data from any studies your child may complete between the ages of 16 and 18,
- Whether or not your child enters Higher Education once they are 18,
- Your child’s employment status post-18, including occupation and income.
BIT will also be accessing data from the National Citizen Service Trust regarding your child’s engagement with other social action programmes. NCS Trust is sharing this data with BIT under the legal basis of 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 controller”. NCS Trust data will allow us to investigate whether participating in the Community Apprentice encourages young people to participate in NCS. Answering this question is deemed to be in the public interest.
If you have any questions around NCS Trust sharing data with BIT, please contact NCS Trust’s Data Protection Officer by email at: firstname.lastname@example.org.
The above data will be linked into one combined data set for analysis, and it will also be shared with the EEF to retain in their data archive.
What will happen to the data?
- Please read the attached BIT Privacy Notice for full details.
- BIT and the Education Endowment Foundation takes your child’s data security very seriously and will ensure that data is handled appropriately and securely.
- Data will be shared and processed in accordance with the Data Protection Act 2018.
- If you have any questions about BIT accessing your child’s data, please contact the Data Protection Officer at email@example.com or by writing to: Data Protection Officer, Behavioural Insights Ltd, 4 Matthew Parker Street, London, SW1H 9NP.
- A report is expected to be published in Winter 2024. No individual student or parent will be identifiable in this report – all details will be fully anonymised.
Would you like your child to participate?
BIT is using ‘legitimate interest’ as a legal basis to process the personal data identified necessary for this research. This does not mean it is mandatory for BIT to access or process your child’s longitudinal data however. If you would like to withdraw from this part of the research project so that no further longitudinal data processing takes place using your data, please complete the form below and return to your child’s school. Withdrawal relates solely to the processing and further accessing of the longitudinal data described above by BIT.
If you DO NOT want your child’s longitudinal data to be accessed or processed by BIT, please email the research team at BIT to withdraw your data from this study – firstname.lastname@example.org. Please provide the student’s full name and school name in your email.
If you are happy for your child to participate, you do not need to do anything.
Privacy Notice — Research on Community Apprentice longitudinal outcomes
This notice is effective from 29th March 2019
Your child’s school is participating in a research project relating to the Community Apprentice programme that has been commissioned by the Education Endowment Foundation (EEF) and will involve personal data being shared with and accessed by the Behavioural Insights Team (BIT) for these purposes. This privacy notice sets out how BIT will collect and use your personal data.
Once data has been obtained by BIT, either through your school sharing it, a survey being completed, or it being accessed from a central database, Behavioural Insights Ltd (the legal name of Behavioural Insights Team) will become a data controller of this personal data.
BIT’s contact details
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice for BIT. If you have any questions about this privacy notice, including any requests to exercise your legal rights in relation to your personal data, please contact the DPO:
Post: Data Protection Officer, Behavioural Insights Ltd, 4 Matthew Parker Street, London, SW1H 9NP
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact BIT in the first instance.
We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it and let you know of any material changes to this notice.
What kind of information do we collect?
Your school has shared the following information with BIT about your child: Unique Pupil Number (UPN), name, date of birth, gender, and whether or not they have ever been eligible for free school meals
BIT will also be accessing the following data on your child, held in central databases (such as the National Pupil Database, Individual Learner Record, the Higher Education Statistics Authority data, and Longitudinal Education Outcomes database):
- Course information and attainment data from any studies they may complete between the ages of 16 and 18.
- Whether or not your child enters Higher Education once they are 18.
- Your child’s employment status post-18, including occupation and income.
BIT will also be accessing data from the National Citizen Service Trust regarding your child’s progression to social action.
What do we do with the information we collect?
The purpose for which BIT is processing your personal data is to deliver a randomised controlled trial (RCT) to test the impact and effectiveness of the Community Apprentice programme.
We will only use your personal data where we have a lawful basis for doing so.
Our lawful basis for processing your personal data is legitimate interest (as per Article 6 (1) (f) of the GDPR). It is in BIT’s legitimate interests to process the personal data identified above in order to deliver a meaningful RCT that has been commissioned by the EEF. The research project fulfils BIT’s core business aims including undertaking research, evaluation and information activities in sectors that will deliver social impact.
BIT has considered and balanced any potential impact on the data subjects’ rights by ensuring participating schools have offered all data subjects the opportunity to withdraw from taking part in the research project and permitting data subjects to be able to withdraw at any time.
Who else has access to your information?
BIT may disclose your information to third parties in connection with the purposes of processing your personal data set out in this notice. These third parties may include other companies in BIT’s group that are based within the United Kingdom and suppliers, research assistants and sub-contractors who may process information on behalf of BIT
BIT will also share your data with the Education Endowment Foundation (EEF) for the purpose of archiving the data, which may also be shared, in anonymised form with other research teams. For information on how the EEF will use and protect your data, please see their Data protection statement regarding EEF evaluations: https://educationendowmentfoundation.org.uk/public/files/Evaluation/Data_protection/Data_protection_statement_EEF_evaluations.pdf
We may also disclose your personal information if required by law, or to protect or defend ourselves or others against illegal or harmful activities, or as part of a reorganisation or restructuring of our organisations.
Your personal information will not be transferred outside of the EEA.
We take all reasonable steps to protect your personal information and follow procedures designed to minimise unauthorised access, alteration, loss or disclosure of your information.
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing these include:
- using encrypted servers for the storage and transfer of electronic data;
- storing all hard copy data in a locked facility; and
- using anonymised identifiers where possible.
We ensure that those who have permanent or regular access to personal data, or that are involved in the processing of personal data, are trained and informed of their rights and responsibilities when processing personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When it is no longer necessary to retain your personal data, it will be securely deleted.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. BIT anticipates that personal data it holds will be securely deleted in 2024.
Please note that, under Data Protection legislation, and in compliance with the relevant data processing conditions, personal data can be kept for longer periods of time when processed purely for archiving purposes in the public interest, scientific or historical research, and statistical purposes.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including rights to:
- Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it.
- Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- Object to processing of your personal data: you can object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data.
- Request transfer of your personal data.
- To object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics.
- Not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you
If you wish to exercise any of the rights set out above in connection with this research project, please contact BIT’s Data Protection Officer with your specific request by email to: email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this Notice
We may change this Privacy Notice from time to time. If we make any significant changes in the way we treat your personal information we will make this clear by contacting schools and ensuring they provide you with an updated version of this Privacy Notice.
Behavioural Insights Ltd is a limited company registered in England and Wales. Registration number: 08567792
Registered office: 4 Matthew Parker Street, London SW1H 9NP