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SPARC Privacy notice

Privacy notice – SPARC (SPARC Pathways 50+ and Pathways Training Fund Project), funded by the European Social Fund.

General information

European Social Fund Logo vertical

SPARC is responsible for providing funds for upgrading the knowledge, skills and competences of the workforce, and promoting flexible learning pathways to facilitate the transition from education to work.

SPARC logo
The processing of personal data is governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018), collectively referred to as data protection law. On occasions we may need to collect and use personal data in order to fulfil these duties.<br

The controller for the personal information that is being processed is the Department for Work and Pensions (DWP). Suffolk County Council (SCC) is the processor for the SPARC project. SCC is not the controller for any other / additional data collected by Futures or other Delivery Partner that is not essential for delivering the Pathways 50+ or Pathways Training Fund projects. If you have any queries about how SPARC is collecting or using your personal data, you can contact Kate Watson at

Contact details for the council’s Data Protection Officer and Compliance Manager can be found in SCC’s corporate privacy notice, which is available on the council’s website.

The types of personal data that we process and where it comes from

We will collect the following personal data from these groups of people/entities:

SME Employers (P50+ and PTF)

  • Ownership declaration (autonomy)
  • Contact name email, tel no.
  • Staff headcount
  • Approved accounts of turnover or balance sheet.
  • De minimis State Aid value £ and declaration
  • BACS statement/run
  • Bank statement
  • Payroll/payslip (financial data redacted).

SME Employees and Participants

  • Full Name
  • Age/Date of Birth
  • Full Address
  • Gender
  • Ethnicity*
  • Health – disability*
  • Single parent household
  • Education level achieved.

Delivery Partners

  • BACS statement/run
  • Bank statement
  • Credit Card Payment

SPARC Project Team, including Futures and training provider partner staff

  • Full Name
  • Limited salary information.

*Information about disability and ethnicity is classed as “special category data” under the GDPR. We will only collect these data for the Pathways Training Fund when it is relevant and for the purposes described above.

Why do we process your personal data?

We are collecting your data for the following reasons:

  1. To confirm eligibility for participation in a European Social Fund project;
  2. Report, manage, monitor and evaluate project delivery.

Our reasons for using personal information include:

  • delivery of services and support to you
  • monitoring and protecting public spending.

Our legal basis for processing your information

Personal data

Under data protection law, SPARC can only process your personal data if it is lawful to do so. Please see the details below of the lawful bases that we rely on for processing different types of personal data.

For processing personal data, we rely on the following lawful basis:

  • UK GDPR Article 6(1)(e) – where ‘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’.

Special category data

When we process special category data (e.g. health, ethnicity), we rely on the following additional lawful basis:

  • UK GDPR Article 9(2)(b) – where “processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.”

Sharing your information

The SPARC project does share information during implementation of the project with the following recipients:

Whether we intend to transfer your information to another country

We do not transfer any personal data to any countries or international organisations outside of the UK.

How long we keep your information

We keep personal data for as long as we need it to fulfil the purpose that it was collected for, and in line with any statutory or locally determined retention periods.

We will securely retain personal data for the duration of the project until December 2023. When the information is no longer needed for the above purposes, it will be securely deleted. After this time, we will only keep data which is required by the funder for potential audit of our project, which will be limited to December 2033, after which date, all data will be securely destroyed. For further information, please refer to: ESF Document Retention Guidance for the 2014-2020 ESF Programme.

Automated decision-making and profiling

The SPARC Project does not use automated decision-making processes or profiling in respect of your information.

Your rights under data protection law

Under data protection law, you have the right to request access to the information that we hold about you. If you would like to make a request to access your personal information, please refer to your employer’s privacy notice. Please also refer to the DWP’s privacy notice below. You can ask for a copy of the information DWP holds about you from this link: ‘Right of Access Request’.

You also have other rights regarding your personal data. You can find out more information about these rights by looking at the council’s corporate privacy notice and the DWP’s Personal Information Charter.

Your right to independent advice

If you would like independent advice on this privacy notice or other matters about how Suffolk County Council processes your personal data, including how to make a complaint, you can contact the Information Commissioner's Office at:

Wycliffe House
Water Lane
Telephone: 0303 123 1113


Participant Privacy Notice for the Department for Work and Pensions

Purpose: The information you provide to Suffolk County Council will be shared with the Department for Work & Pensions (DWP) and used to evaluate this project and to report to Suffolk County Council and European Social Fund for monitoring purposes, in line with European Commission regulatory requirements.

Your information will also be shared with research organisations working on behalf of the Department for Work & Pensions who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary and you will be asked to consent before taking part in any research activity you may be contacted about.

The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left. This information may also be shared with research organisations working on behalf of the DWP however individuals will not be identifiable and you will not be contacted about this research. Data will not be used or shared for any commercial or marketing purposes. At all times your information will be kept securely, and nobody will have access to it that should not.

Lawful Basis for the processing: For the purposes of the General Data Protection Regulation (GDPR), the DWP is the data controller in respect to information processed which relates to all participation in the European Social Fund. ESF grant beneficiary organisations are data processors in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund.

DWP is not the controller for any other / additional data collected by Suffolk County Council that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by Suffolk County Council. The ESF Programme Action Note 018/18 sets out the lawful basis for processing personal data under ESF.

Retention periods for personal data: All personal data held by DWP or research contractors for the purposes of evaluation will be permanently deleted no more than six months after the research has been completed (i.e. when the final report is published on GOV.UK). Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK at: ESF Document Retention Guidance for the 2014-2020 ESF Programme (

Your rights in respect of processing: If you do not wish your personal data to be used for ESF evaluation purposes please contact and we will delete your data held for these purposes and you won’t be contacted about participating in research. More information about how and why DWP uses your personal information, including how to ask for a copy of the personal information DWP holds about you can be found in DWP’s Personal Information Charter. Information about how to ask for a copy of the information DWP holds about you (known as a ‘Right of Access Request’) can be found at: Request your personal information from the Department for Work and Pensions - GOV.UK (