Work Able Scotland: privacy impact assessment

Privacy impact assessment for our Work Able Scotland programme, which will provide employability support for people at risk of long term unemployment as a result of a health condition.


3. Description of the project

3.1 The Scotland Act 2016 provides the opportunity to develop a distinctively Scottish approach to employment support for disabled people and those who are at risk of long-term unemployment due to a health condition. From 1 April 2017, Scottish Government ( SG) will introduce transitional arrangements. These will remain in place until 30 April 2019 2018, in advance of the full SG programme of employment support from 1 April 2018.

3.2 The Work Able Scotland ( WAS) Programme is a voluntary programme for unemployed customers with a health condition who want to enter work, which is owned by the Scottish Government and managed by Skills Development Scotland ( SDS) on behalf of SG. The programme will be delivered by three contracted service providers who will also act on behalf of the SG; The Wise Group, Progress Scotland and Remploy The Department for Work and Pensions ( DWP) work coaches will refer claimants to contracted WAS providers using a clerical process agreed between DWP and SG.

3.3 DWP will provide the following services, and process Personal Data on behalf of SG for the following purposes:

  • Job Centre Plus ( JCP) Work Coaches will identify eligible and suitable customers for WAS contracted providers and make referrals using an agreed clerical process as described at Annex A.
  • Job Centre Plus Work ( JCP) Coaches will agree customer start date with WAS contracted providers.
  • With the customer's consent, Job Centre Plus ( JCP) Work Coaches will action the leavers plan completed by WAS contracted providers when the customer exists the WAS service.

3.4 The scope and type of Personal Data that may be provided to or accessed by DWP as part of the Services and for the purposes as described at section 3.3 consists of:-

  • Customer name
  • Title
  • Date of Birth
  • National Insurance Number
  • Postcode
  • Address
  • Telephone number
  • 2 nd Telephone number
  • Employer details
  • Staff payroll reference
  • Salary & hours of work
  • Participant Circumstances
  • Potentially sensitive customer information.

3.5 Further descriptions of the Personal Data and how it will be treated are provided in Annex A .

3.6 The processing by both SG and DWP in respect of WFS meets the requirements of condition 5(c) of Schedule 2 of the DPA (for non-sensitive personal data) and condition 7(c) of Schedule 3 where sensitive personal data are involved.

3.7 The Scotland Act 1998, as amended by the Scotland Act 2016 (Part 3 (Welfare Benefits and Employment Support) provides SG with the power to provide schemes such as WFS.

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