New Anglia LEP Privacy Policy 1
Last Updated: September 2023
Privacy Policy
Last Updated: 25th September 2023
This privacy policy sets out how New Anglia Local Enterprise Partnership (LEP) uses
and protects any information that you provide to New Anglia LEP and its delivery
partners.
A separate privacy policy is available for director’s, employees and prospective
employees. Please contact the HR department for further information.
Data Controller and Data Processor
As Data Controller and Data Processor, New Anglia LEP is responsible for ensuring
that all data, including any Personal Data, that it holds is accurate and, where
necessary, kept up to date.
New Anglia LEP will ensure that individuals have access rights to their data as
required by the General Data Protection Regulation (2016/679), Data Protection Act
2018 and UK GDPR 2020.
As the Data Controller, New Anglia LEP’s Data Protection Officer oversees the use of
data within the LEP and has the right to enforce any legal requirements contained
within the General Data Protection Regulation (2016/679), Data Protection Act 2018
and UK GDPR 2020.
Use and Storage of Data
In accordance with Article 5(2) of the General Data Protection Regulations, New
Anglia LEP adheres to the following principles when storing and processing data:
Data is collected for specified, explicit and legitimate purposes and will not be
processed in a manner that is incompatible with the original purpose(s) for
which the data was collected.
Data is stored and processed lawfully, fairly, and in a transparent manner, in
relation to individuals.
We use appropriate technical or organisational measures to ensure that there
is appropriate security in place for any personal data; this includes protection
against unauthorised or unlawful processing and against accidental loss,
destruction or damage.
The data we collect is as accurate as possible and, where necessary, kept up
to date.
Data is kept in a form which permits identification of data subjects for no
longer than is necessary for the purposes for which the personal data is
processed.
All reasonable steps are taken to ensure that inaccurate personal data is
erased or rectified without delay.
Data may be used for further processing and archiving purposes in the public
interest, or for scientific, historical research or statistical purposes.
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Personal data may be stored for longer periods insofar as the personal data
will be processed solely for archiving purposes in the public interest, scientific
or historical research and/or statistical purposes, subject to implementation of
the appropriate technical and organisational measures, required by the
GDPR, in order to safeguard the rights and freedoms of individuals.
Personal Data Collected
New Anglia LEP has contracts with Government Departments to deliver a range of
business support programmes and grant schemes, several of which are delivered in
partnership with other organisations and Local Authorities.
As part of the operation of these programmes/schemes, New Anglia LEP processes
personal data according to the following lawful basis:
Article 6(1)(e) of the General Data Protection Regulation “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”.
The lawful basis for controlling or processing ‘special category’ data is:
Article 9(2)(g) of the General Data Protection Regulation “Processing is necessary for
reasons of substantial public interest, on the basis of Union or Member State law
which shall be proportionate to the aim pursued, respect the essence of the right to
data protection and provide suitable and specific measures to safeguard the
fundamental rights and the interests of the data subject”.
Depending on the nature of activities or support provided by New Anglia LEP and its
delivery partners, the following types of information may be collected and may be
shared with delivery partners and Government Departments for the purposes of
reporting and monitoring. This is not an exhaustive list but provides examples:
1. name of contact.
2. job role.
3. company name (legal and trading).
4. business sector/activity/SIC code.
5. location/address/relevant local authority.
6. email address.
7. public IP address.
8. phone number (including mobile.
9. date and time of enquiry.
10. business status.
11. business ownership.
12. business size.
13. business turnover.
14. staffing numbers (including apprentices).
15. business Companies House registration number, VAT, PAYE.
16. date of incorporation.
17. start date of trading.
18. financial information (historic, current and forecasts) required for assessment
of business support.
19. enquiry source.
20. reason for contacting the partner.
21. outcome of any advice given.
22. details relating to the support given and/or provided.
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Last Updated: September 2023
23. correspondence with businesses/individuals related to business support
services and employment related to learning/training programmes.
24. ethnicity.
25. disability.
26. Physical or mental health condition or illness.
27. gender.
28. age.
29. labour market status.
30. pay details.
31. National Insurance Number.
32. Learner Reference Number.
33. Unique Learner Number.
34. prior attainment.
35. Date of birth.
36. Benefits information.
37. Caring responsibilities.
38. Course evidence such as attendance records and certificates, qualifications.
Information Being Shared
As part of the operation of New Anglia LEP’s business support programmes and
grant schemes, a shared CRM System has been developed by New Anglia LEP to
enable business support and delivery partners across Norfolk and Suffolk to:
facilitate the delivery, coordination and management of business support
services to customers (Individuals, Small and Medium-sized Enterprises
(SMEs) as well as Large Companies) across the counties of Norfolk and
Suffolk;
provide support to inward investment opportunities in line with the objectives
outlined in the Norfolk and Suffolk Economic Strategy;
contact customers about business support services that can be accessed
through the New Anglia Growth Hub (delivered by Suffolk Chamber of
Commerce on behalf of New Anglia LEP).
Your details will be used to support research and evaluation activities, with New
Anglia LEP sharing all, or some of, your personal data with organisations to
undertake independent external audits and evaluations of activities, to assess the
effectiveness of the support provided, as well as ensuring that U.K. and E.U. law,
rules and regulations have been fully complied with. Such organisations may be
appointed by New Anglia LEP and/or the Department for Education, the Department
for Levelling Up, Housing and Communities; the Department for Businesses, Energy
and Industrial Strategy; other Government Departments and/or the European
Commission.
New Anglia LEP will not give any personal data to any other organisation(s) unless
required for the purpose of audit and/or evaluation. In such circumstances, where
possible, New Anglia LEP will remove the details that might identify individuals
personally and will instruct the organisations undertaking the audit and/or evaluation
not to use the data to contact individuals for any reasons unconnected with the audit
and/or evaluation process.
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Last Updated: September 2023
Freedom of Information Act 2000
As a Company Limited by Guarantee we are not formally subject to the Freedom of
Information Act 2000. However, we recognise the importance of accountability and
transparency and voluntarily adhere to this legislation. We respond to Freedom of
Information requests in the same way as organisations which are formally bound by
the legislation and always seek to make information available wherever possible.
Withdrawal of Individual’s rights
Under Article 6(1)(e) and Article 9(2)(g) of the General Data Protection Regulation,
participants in New Anglia LEP’s business support programmes and grant schemes
are unable to claim the following rights in terms of personal data:
the right to erasure (“right to be forgotten”)
the right to portability of their data.
However, the data collected is your personal data, and you have the right, subject to
lawful data requirements:
to see what data we have about you
to ask us to stop using your data
to ask us to delete your data, or to correct your data if there is no longer a
justification to process it
to lodge a complaint with the independent Information Commissioner (ICO) if
you think we are not handling your data fairly or in accordance with the law.
Data Retention
Contracts with several Government Departments, including contracts with the
Department for Levelling Up, Housing and Communities, the Department for
Education, and the Department for Businesses and Trade, stipulate that data and
evidence must be kept for a specified period after support has been provided by New
Anglia LEP and its partners. In the case of the Department for Levelling Up, Housing
and Communities, and the Department for Businesses and Trade, data and evidence
must be kept until 31st December 2033.. In the case of the Department for
Education, data and evidence must be kept until 31st December 2031.
Destruction of Information
In accordance with legislation, any data no longer required for the purposes that it
was held for will be destroyed. This means that New Anglia LEP will destroy all hard
copy and electronically stored information using secure methods that comply with all
data protection regulations in force at the time of destruction.
Data Breaches
In the case of a data security breach, New Anglia LEP will immediately take steps to
contain the breach. Where a serious breach is encountered, New Anglia LEP, as
Data Controller, will notify the Information Commissioner’s Office and launch an
investigation to establish the reasons behind the breach. New Anglia LEP is
permitted to take all reasonable corrective steps as resulting from a security breach,
including suspending use of any systems and/or withholding joint working with
delivery partners.
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Automated decision making
New Anglia LEP does not use personal data to undertake automated decision
making.
New Anglia LEP Contact Details
If you would like further information, please contact:
Data Protection Officer
New Anglia Local Enterprise Partnership
Centrum
Norwich Research Park
Colney Lane
Norwich
Norfolk
NR4 7UG
Tel: 01603 510070
Email: dpo@newanglia.co.uk
Information Commissioner’s Office Contact Details
The Information Commissioner’s Office is the UK’s independent authority set up to
uphold information rights in the public interest, promoting openness by public bodies
and data privacy for individuals:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Website: www.ico.org.uk
