5. Questions to identify privacy issues
5.1 Involvement of multiple organisations
- The delivery of Work Able Scotland will involve the Scottish Government, the Department for Work and Pensions, Skills Development Scotland and WAS contracted providers ; The Wise Group (www.thewisegroup.co.uk), Progress Scotland (can be accessed via www.thelennoxpartnership.org) and Remploy ( www.remploy.co.uk) and
5.2 Anonymity and pseudonymity
- If the project does not require the matching of data sources together to produce new data.
- There will be no new or additional information technologies.
5.4 Identification methods
- The customer's National Insurance number will be used as a unique identifier.
- There will be no new or substantially changed identity authentication requirements.
5.5 Personal data
- Personal data will be transferred from DWP to WAS contracted service providers and from WAS contracted service providers to SDS Contract Management personnel as detailed at Annex A.
- The personal details of individuals will be transferred to WAS contracted service providers at the point of referral.
- These changes will apply to approximately 1,500 individuals.
- There will not be new or significantly changed consolidation, inter-linking, cross-referencing or matching of personal data from multiple sources
- The project will not involve the linkage of personal data with data in other collections, or any significant change to existing data links or holdings
5.6 Changes to data handling procedures
- There will not be new or changed data collection policies or practices that may be unclear or intrusive; the data collection will mirror an existing DWP process which they will subsequently implement on behalf of the SG.
- There will not be changes to data quality assurance or processes and standards that may be unclear or unsatisfactory.
- There will not be new or changed data security access or disclosure arrangements that may be unclear or extensive
- There will not be new or changed data retention arrangements that may be unclear or extensive.
- There will not be changes to the medium of disclosure for publicly available information in such a way that the data becomes more readily accessible than before.
5.7 Statutory exemptions/protection
- The data processing will not be exempt in any way from the Data Protection Act or other legislative privacy protections.
- The project does not involve systematic disclosure of personal data to, or access by, third parties that are not subject to comparable privacy regulation
- The project's justification does not include significant contributions to public security measures.
- During 2015 SG consulted extensively to inform the development of Scotland's employability services. Following careful and independent analysis of the responses received, the key principles and values of the Scottish
Approach to employability which will underpin devolved employability services in Scotland from 1 April 2017 were set out in March 2016 in Creating a Fairer Scotland: A New Future for Employability Support in Scotland ( http://www.gov.scot/Resource/0049/00498123.pdf)
As part of the continued Fairer Scotland discussion, the Scottish Government's Employability Programme Division engaged the Central Government Digital Transformation Service ( CGDTS) and User Research and Engagement ( URE) teams to explore the personal experiences of people engaging with employability services. 21 organisations and over 150 individuals participated and the report completed in December 2016.
- The justification for the new data handling is not unclear or unpublished
5.9 Other risks
- There are no risks to privacy not covered by the above questions