IPS Focus Privacy Notice

This notice tells you about:

  • the information Shaw Trust (the Trust) may hold about you,
  • how we will protect your information,
  • how we may share or use this, and
  • the rights you have.

1. Who we are

Shaw Trust is the provider of the Individual Placement and Support (IPS) Service in Bath.

We support people to gain and retain employment alongside health and wellbeing support.

Shaw Trust is the Data Controller for your personal data once it is received through our Expression of Interest form or referral process.

If you have any questions about this notice or how we use your data, please contact:
data.protectionmailbox@shaw-trust.org.uk

Your personal information

We may collect the following types of personal information:

  • Name
  • Date of birth
  • Address and postcode
  • Email address
  • Telephone number
  • Referrer details (if applicable)
  • Employment history and support needs
  • Health or disability information relevant to employment support

We only collect the minimum information necessary to:

  • assess eligibility
  • contact you
  • provide employment support
  • meet commissioning and audit requirements

Some information may be classified as special category data, such as health or disability information. This is handled with enhanced safeguards.

How we collect your data

We collect your information when:

  • You complete a digital Expression of Interest form on our website
  • A professional refers you to the programme
  • You contact us directly

Initially, forms are submitted securely and reviewed by our Triage Team. In future phases, form data will integrate directly with our secure operational CRM system.

Information Provided About You by a Third Party (Referrals)

In some cases, we may receive further relevant information about you from other trusted sources involved in your care or employment support — such as:

  • your NHS care team,
  • your employment advisor, or
  • a referring support organisation.

We use this information to:

  • continue your support without interruption,
  • assess your needs and eligibility, and
  • deliver appropriate services if you choose to engage

This data is processed in line with our Article 14 UK GDPR obligations.

Legal Basis for Processing

We rely on one or more of the following UK GDPR bases:

  • Public Task – the processing is necessary for delivering a commissioned public health or employment service.
  • Health and Social Care Provision – where special category data is involved, under Article 9(2)(h).
  • Legal Obligation – where required by law (e.g. safeguarding, funding requirements).

We do not rely on consent as our lawful basis to receive your information, but you still have rights over your data (see below).

Protecting Your Information

Your data will be stored in secure systems and only accessed by trained and authorised personnel. We will not transfer your personal data outside the UK/EEA without suitable safeguards in place.

How long we keep your data

We retain your personal data:

  • For up to 6 years after the end of your involvement in the IPS programme, in line with funding and legal obligations.
  • If you do not continue with the service, we may keep your data for no more than 6 months after the referral is received, after which it will be securely deleted.

Sharing Your Information

To provide the IPS service, we may share your data with:

  • NHS commissioners or referrers
  • employment support staff within Shaw Trust
  • IT service providers supporting our secure systems
  • funders or oversight bodies, where legally required

We do not sell your information or use it for automated decision-making.

Your Rights

You have the right to:

  • access and correct your personal data;
  • request erasure, restriction, or objection;
  • be informed of how we got your data (if from a third party);
  • withdraw consent at any time;
  • complain to the Information Commissioner’s Office (ICO).

To exercise your rights, contact:
Data Protection Officer
Email: data.protectionmailbox@shaw-trust.org.uk
Address: Shaw Trust, Black Country House, Rounds Green Road, Oldbury B69 2DG

When we Contact You (Referrals)

If we receive your data via referral, we will contact you to:

  • explain who we are and where we got your information
  • explain why we’re contacting you and what services we offer
  • provide a copy of this privacy notice

This supports your rights under Article 14 of the UK GDPR.