Childcare Offer for Wales: local authorities privacy notice

The Childcare Offer for Wales online service comprises a digital platform and telephone helpline, replacing the various local authority systems previously used to manage the service. The digital component is a secure, cloud-based case management platform. The Welsh Government is the Data Controller for the information held within the digital service.

Our privacy notice sets out:

•    the personal information we collect about you
•    what we do with it
•    who we may need to share it with
•    how long we will hold it for
•    your rights are in relation to it
 

Personal data is defined under the UK General Data Protection Regulation (UK GDPR) as ‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier.’

The roles of local authorities, as either a Delivery Authority (DA) or an Engagement Authority (EA), are outlined in the Welsh Government’s administration grant award letters. The guidance for local authorities provides further information on the tasks local authorities carry out.

Outlined below are key processes and the personal information we collect about you:

Registering as a Local Authority Administrator

Administrators access the Childcare Offer for Wales platform through a single sign on feature. Administrators will be asked to provide the following personal information:

• your name
• your work email address

Tasks you complete on the Childcare Offer for Wales digital platform

The digital platform tracks administrator actions using an audit feature which is in place to minimise risk of fraud or misuse of the system. This audit feature collects the following personal information: 

• your name
• your work email address

Staffing the national telephone helpline

If you request access to become a user of the helpline, we will allocate you a telephone number and extension number which is linked to your name. We collect the following personal information which is accessible to the Welsh Government and your own local authority: 

• your name
• your work email address
• the telephone and extension number we have allocated to you

Submission of forms via Smart Survey

We use Smart Survey - an online survey tool - to enable you to request actions of us that support you in the delivery of the policy. These actions range from advice and guidance through to decisions on payments to childcare settings. Depending upon the type of request you make we may record the following personal information:

• your name
• your work e-mail address
• your work telephone number
• Your IP address

Contacting us by email

We have a dedicated email inbox where incoming correspondence and requests are received and logged. If you contact us at childcareoffer@gov.wales we may record:

• Your name
• Your work email address
• Your telephone number

Evaluation of the Childcare Offer for Wales

Our service is periodically evaluated to assess its performance and help Welsh Ministers make decisions relating to the development of the supporting policy. If you are invited to take part in research activities related to the Childcare Offer for Wales you will be issued a separate privacy notice outlining how information generated by the research will be collected, held and used. Taking part in research is voluntary and you will not be identified in any reports.

Fraud investigation

The information you provide, or we collect from publicly available sources, may be shared with fraud prevention agencies if we suspect or detect fraud. The Privacy notice for Welsh Government grants provides further information.

The lawful basis under Article 6(1)(e) UK GDPR (public task) applies to all processing described in this notice, as it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Welsh Government.

The lawful basis for processing information in this data collection exercise is our public task; that is, exercising our official authority to undertake the core role and functions of the Welsh Government. 

This enables the operation of the Childcare Offer for Wales programme and provides information which will help Welsh Ministers make decisions relating to the development of the policy, which is being delivered to improve economic and social well-being in Wales in accordance with section 60 of the Government of Wales Act 2006.

Your data will be used by the Welsh Government and local authorities to:

• enable authenticated staff within the Welsh Government and all local authorities in Wales to register on the digital service for administration of the service to parents and childcare providers
• provide easy access to the digital service for administrators using corporate devices through a single sign on feature, so they do not have to create user accounts and sign in each day via Government Gateway
• to audit users’ actions within the digital service
• to enable staff to manage incoming and outgoing calls to and from parents and childcare providers through a secure cloud communications platform

Under UK GDPR, we have a legal duty to protect any personal information we collect from you. We use leading technologies and encryption software to safeguard your data and keep strict security standards to prevent any unauthorised access to it.

Only you and authorised persons working in local authorities, Welsh Government officials (or our suppliers and appointed contractors) will have access to your data.

Callers to the national helpline will be able to see your telephone number but this will not be linked to your name.

In relation to the personal data we collect about you received by email or by online forms, it will be kept in accordance with part 17 of the Welsh Government’s retention and disposal schedule.

In relation to the digital platform, the maximum amount of time we will keep your personal data is 7 years and 3 months from the last transaction date of any setting or parent your name is associated with.

In relation to the helpline, we will keep your personal information for as long as you are an administrator on the helpline. It is the responsibility of local authorities to inform us via the childcareoffer@gov.wales mailbox when a member of staff leaves the Childcare Offer for Wales team, or you can contact the Welsh Government directly.

For forms submitted through Smart Survey or information emailed to the dedicated mailbox, the retention periods will be:

• 7 years for documents relating to finance, for example provider or parent overpayments and backdated payments
• 10 years for information relating to Childcare Offer for Wales policy, such as general queries

We will retain your information in the Smart Survey online portal for a maximum of 3 months.

The Welsh Government will make a determination on who we share your personal information with depending on the nature of the requirement for which the information is needed. The Welsh Government will ensure that information is shared if it is necessary to undertake any function.

Parties we may share your information with include:

• Welsh Government staff
• local authority teams who administer the Childcare Offer for Wales
• third party suppliers or contractors specifically appointed to assist in the delivery of the Childcare Offer for Wales

All suppliers and contractors act under written contracts which require them to process personal data only on our instructions and to maintain appropriate security measures.

Under UK GDPR, you have the following rights in relation to the personal information you provide while involved with the Childcare Offer for Wales. Some rights may be limited where processing is necessary to comply with a legal obligation or for the exercise of official authority.

You have the right:

• to access a copy of your own data
• to ask us to rectify inaccuracies in that data
• to object to or restrict processing (in certain circumstances)
• for your data to be ‘erased’ (in certain circumstances)
• to lodge a complaint with the Information Commissioner’s Office (ICO) who is our independent regulator for data protection.

If you have any further questions about how your data will be used by the Welsh Government or wish to exercise your rights using the General Data Protection Regulation, please contact:

Childcare Offer for Wales team
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

Email: childcareoffer@gov.wales

The Welsh Government’s Data Protection Officer can be contacted at:

Welsh Government
Cathays Park
Cardiff
CF10 3NQ

Email: DataProtectionOfficer@gov.wales
 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Website: ico.org.uk