How we protect and manage your personal data
Who we are
The Jersey Employment Trust (JET) includes Employment Services, Acorn Training and Development Services. JET also has some business units, which may be used as part of a client’s (service user) Training and Development – Acorn Nursery, Acorn Woodshack, Acorn Reuse. JET has nominated Data Protection Officers. These Data Protection Officers are Sarah Boydens and David Rose who can be contacted on 01534 788900, at dataprotection@jet.co.je or in writing at The Oakfield Building, La Rue du Froid Vent, St Saviour, Jersey, JE2 7LJ.
The information we collect about you:
In order to process your referral into the service JET requires personal and sensitive information, which may include:
- Name
- Gender
- Contact details – address, telephone numbers, emails
- GP name and address
- Residential status
- First language
- Social Security registration number
- Driving licence details
- Benefit details (Contributory and Non-Contributory Benefits)
- Health condition and disability details
- Employment history
- Other support persons or agencies involved
- Conviction information
- Any other information which will or may have a direct bearing on your access to services or your future employment
When we collect your information
We collect the above information at the point of referral (as listed on the referral form) and update it annually, or when it changes, throughout the time you use the service. Information is provided by the individual themselves and may also be provided from Customer and Local Services Departments: Back to Work, Health Zone or Income Support. Other third parties who may provide information include services such as: GP, Mental Health, Psychology, Probation, Social Services (child/adult), Drug and Alcohol, Occupational Therapy, or any other specific service relevant to you and your access to JET services.
How information about you will be used and the legal basis
JET uses the data on your medical condition or disability to assess whether you are eligible for the service and if so, to use it in consideration for job matching.
JET uses data on benefits to assess if there are any implications on your job seeking activity (e.g., if you are in receipt of Short Term Incapacity Allowance (STIA) you will be unable to attend weekly job club/training). It is also used to see whether you are a mandatory jobseeker (under income support legislation) and need to be added to contractual reporting requirements contained within a contract between the Customer and Local Services Department and JET.
JET uses data on your name, contact details, date of birth and Social Security number to keep up-to-date records on client files, database systems, digital CRM database, and hard copies in client files. This information can be used day-to-day (e.g., to contact an individual to arrange an appointment and access services). This will also be used as part of your employment and training service and details will be used to put on a CV and application forms in order to apply for jobs.
Referrals to other support services outside of JET may take place to best support you and would include the above data as part of the referral process. However, any referrals to other agencies will only take place with your explicit consent or in cases of vital interests where there is a safeguarding requirement.
Data on criminal convictions and investigations would need to be known if it impacts on the opportunities to gain work in your sector of choice (e.g., enhanced DBS may be required to work with children). It also may be required under ‘vital interests’ legal basis as the majority of JET clients are classed as “adults at risk”, as per the Jersey safeguarding guidelines, and therefore JET has a duty of care to ensure that they are not put at risk within their training and development activities with JET.
By signing the referral form, JET holds your personal information on the following basis under the General Data Protection Regulations (GDPR), with your explicit ‘consent’ i.e. you have agreed to, or as part of ‘legitimate interests’ your contract of accessing services with JET, or in cases of ‘vital interest’ where there may be risks we need to be aware of and manage for client safety.
JET may also hold personal information provided by other agencies which is lawfully disclosed to JET in cases of ‘Vital interests’, or ‘legitimate interests’ as part of your accessing services, or is obtained with your explicit consent (you may withdraw your consent at any time, further information on this listed below).
Under legitimate interests JET is required to produce statistics on employment and training that takes place via the services.
Who we share your information with
- Customer and Local Services. If you are in receipt of Income Support and are classed as a mandatory job seeker then we are required to share information on your attendance with Back to Work at Customer and Local Services. This is a statutory requirement from Back to Work and you will have consented to this when a referral in respect of you is made to JET.
- Other agencies. We may share data with other services when we make a referral to external support services. We do this with your explicit consent or in cases of your vital interest where there is risk and safeguarding requirement.
- Employers. In order to successfully job match your CV information will be shared and any medical/disability information is shared on a need to know basis as part of your risk assessment for a placement or job.
- Armed forces support services. For clients who have previously served, we will ask your consent to share date so that you may benefit from additional support services that are available to you under the Armed Forces Covenant for veterans.
How long we hold your data
Relevant information regarding you will be kept whilst you continue to be a JET client and for 12 months after you have ceased receiving JET services. For clients who are with the service for 2 years plus -annually, we will archive non-essential data that is 24 months or more old, this will be permanently deleted after it has been in the archive for 5 years. If you are employed by JET at any time, contractual information will be retained for 10 years after employment ceases. A separate privacy notice is provided to anyone who is employed by JET, see HR for more information. After these times information will be destroyed.
Implications of not providing your data or consent
If you do not provide the information required on the referral form we may not be able to process your referral nor offer you a service. If there is some information withheld, we may not be able to offer you a satisfactory level of service.
If you wish to withdraw your consent we may no longer be able to provide a service to you.
Closed Circuit Television (CCTV) Monitoring & Recording
The Jersey Employment Trust is committed to providing a secure, safe and well managed retail and storage environment at Acorn Enterprises. The use of Closed Circuit Television (CCTV) enables monitoring of people and can act as a deterrent of inappropriate behaviours and illegal activity (e.g. theft).
The use of CCTV is permitted under the Data Protection (Jersey) Law 2018. CCTV usage will be conducted in a professional, ethical and legal manner.
The purpose of CCTV at Acorn Enterprises is:
- For security purposes as a deterrent to crime and for the investigation of crime.
- To improve customer service, to monitor queues and systems of working to enhance JET’s retail operations.
- To review accidents or near misses to improve health and safety arrangements at Acorn.
JET's CCTV Policy is available on request.
Your rights
Any person who provides JET with personal information will have the following rights under Data Protection (Jersey) Law 2018:
- The right to access their personal data (through a Subject Access Request).
- The right to stop or restrict the use of their personal data from being processed.
- The right to request to have all personal information JET holds on them to be deleted (this is known as the right to erasure).
- The right to ask and have their personal information transferred to another service provider (this is known as data portability).
- Right to have their personal information kept up-to-date and accurate and to direct JET to correct information they believe is incorrect.
- The right to complain to the Jersey Office of the Information Commissioner at 2nd floor, 5 Castle Street, St Helier, Jersey , JE2 3BT or 01534 716530 or enquiries@jerseyoic.org
If you wish to exercise any of these rights you can contact us via Data Protection Officers Sarah Boydens and David Rose on 01534 788900, at dataprotection@jet.co.je or in writing at The Oakfield Building, La Rue du Froid Vent, St Saviour, Jersey, JE2 7LJ.
Updates
We will update our Data Privacy Notice from time to time and you can find a copy of the most up to date notice on our website www.jet.co.je.
JET is a Data Controller for the purposes of the Data Protection (Jersey) Law 2018.