Guidance on the requirement for all ESF and YEI providers to record and share individual participant contact details to support the monitoring and evaluation
1. Purpose of the guidance
This guidance explains the requirement for, and the process by which contact details for all participants on European Social Fund (ESF) and Youth Employment Initiative (YEI) provision must be submitted to the Managing Authority (MA). This document covers:
The regulatory and legal basis behind the requirement to collect and share participant data, including contact details;
The requirement for the participant privacy notice to be used with all ESF and YEI participants;
What contact details need to be collected and how they will be reported to the MA;
The handling of contact details for certain ‘sensitive’ groups.
This guidance applies to both ESF and ‘match’ funded participants.
1.1 Who should use this guidance
This guidance should be used by all grant beneficiary organisations, including ‘direct bid’ organisations, Co-Financing Organisations (CFOs) and partners and Intermediate Bodies (IBs).
Grant beneficiary organisations will be expected to provide contact details data for all delivery partners or projects within their operation. The grant beneficiary organisation will be responsible for the quality of the data submitted.
2. Background and context: ESF monitoring and evaluation requirements
The Common Provisions Regulations (CPR) and ESF regulations require the Managing Authority to monitor and evaluate ESF-funded activities.
The ESF Operational Programme 2014-2020 states that robust governance and accountability require programme related analysis, monitoring and evaluation to form an integral part of programme delivery.
In order to conduct monitoring and evaluation individual participant data is required. There is a legal basis for collecting and processing personal data and sharing it with the Managing Authority for the purposes of monitoring and evaluation (Article 56 of the CPR and Articles 5 and 19 and Annexes I and II of the ESF Regulations). Therefore, participant consent to collect participant data and to be re-contacted for monitoring and evaluation purposes is not required. As such, participant data, including contact details should be collected and stored for all participants in order to meet monitoring and evaluation requirements. This includes all ESF and ‘match’ funded participants, and participants on YEI provision.
3. Participant privacy notice
The following guidance on participant privacy notices has been updated to reflect the introduction of the General Data Protection Regulation (GDPR) in respect of the collection and processing of data required to support monitoring and evaluation of the ESF programme. It should be read in conjunction with the DWP’s Personal Information Charter on GOV.UK which has been updated to be GDPR compliant. It is important that any privacy notice relating to ESF includes a link to this.
Grant recipients should ensure that for all ESF operations / projects, the privacy notice used (by themselves and any delivery partners) includes the following information below. It is based on information set out in the ESF Programme Action Note 018/18 issued 02 May 2018 which provides briefing on the implications of the GDPR for the ESF Programme. This Action Note sets out the data controller and data processor roles in respect of ESF personal data and establishes the lawful basis for processing personal data in ESF. You should also refer to Action Note 020/18 which provides additional advice on data Right of Access Requests.
3.1 Wording for participant privacy notice
The purposes of the data processing
The information you provide to [operation / project provider name] will be shared with the Department for Work & Pensions (DWP) and used to evaluate this project and to report to the [operation / project provider name] and European Social Fund for monitoring purposes, in line with European Commission regulatory requirements.
Your information will also be shared with research organisations working on behalf of the Department for Work & Pensions who may contact you to discuss your involvement in the project for research purposes. Participation in research is voluntary and you will be asked to consent before taking part in any research activity you may be contacted about.The DWP may also link your personal details to official administrative records in order to monitor your employment status before your ESF support began and 6 to 12 months after you left.
This information may also be shared with research organisations working on behalf of the DWP however individuals will not be identifiable and you will not be contacted about this research.
Data will not be used or shared for any commercial or marketing purposes.
At all times your information will be kept securely, and nobody will have access to it that shouldn’t.
Regulatory and legal basis behind the requirement to collect data
For the purposes of the General Data Protection Regulation (GDPR), the DWP is the data controller in respect to information processed which relates to all participation in the European Social Fund. ESF grant beneficiary organisations are data processors in respect to information processed which relates to participants in the operations and projects funded by the European Social Fund. DWP is not the controller for any other / additional data collected by [operation / project provider name] that is not essential for delivering the ESF programme, or for any personal data that would normally be collected anyway by [operation / project provider name].
The ESF Programme Action Note 018/18 sets out the lawful basis for processing personal data under ESF.
The retention periods for the personal data
All personal data held by DWP or research contractors for the purposes of evaluation will be permanently deleted no more than six months after the research has been completed (i.e. when the final report is published on GOV.UK).
Personal data held by DWP for all other ESF purposes as required by European Commission regulations will be retained in line with the current guidance on GOV.UK.
The rights available to individuals in respect of the processing
If you do not wish your personal data to be used for ESF evaluation purposes please contact ESF.EVALUATIONS@DWP.GOV.UK and we will delete your data held for these purposes and you won’t be contacted about participating in research.
More information about how and why DWP uses your personal information, including how to ask for a copy of the personal information DWP holds about you can be found in DWP’s Personal Information Charter
Information about how to ask for a copy of the information DWP holds about you (known as a ‘Right of Access Request’)can be found on GOV.UK.
Grant Recipients should supply the following information for each participant:
Participant unique identifier
Home phone number
Project delivery location
Project deliver partner name
Date participant leaves provision
A full data schema listing the variables and format can be found in Annex I included within the original funding agreement letter (Details required for Data Transfer Approval Form). Data definitions can be found in Annex II.
4.1 Data Validation
It is expected that Grant Recipients / providers will quality assure and validate all data prior to upload. Grant Recipients / providers are expected to supply all the details required in the schema. However, if the data is not available for a particular field, the field should be left blank (i.e. do not inset ‘null’ or ‘n/a’ or delete the field or column). Data quality is the responsibility of Grant Recipients, and where issues in data quality are identified this will be followed up.
The participant contact details will primarily be used for contacting a sample of people who have attended ESF or YEI funded provision, 6 months after leaving provision, to ask them to complete a short Leavers’ survey. This will enable the MA to report on the Longer Term Results Indicators (LTRIs) for ESF and YEI participants as required by the European Commission. The contact details will also be used to support other ESF Programme research and evaluation activities as necessary.
The high level process for reporting the contact details is outlined below:
Grant Recipients will routinely supply participant contact details to the Managing Authority, on a similar schedule to the participant level MI (Management Information) data they upload to the ESF E-claims system or send to their contract manager as part of the claim on the Participant Data Schema (PDS)
A representative sample of participant records will be drawn from the ESF E-claims Management Information database and matched to the participant contact detail records submitted to DWP by all Grant Recipients
The ESF Evaluation Team at DWP will be matching the PDS MI data to the contact details data that you submit separately using the participant unique ID – it is therefore imperative that the unique IDs, including all formatting are the same on both data files
Independent external contractors commissioned by the ESF Evaluation Team at DWP will use the participant contact details from the sample to arrange data collection via longer- term follow up surveys
Grant Recipients will need to submit the participant contact details to DWP quarterly, including contact details data for all participants who have left provision in the preceding quarter.
6.1 Submission of data.
As the data contained in the contact details data upload is personal data, it must be stored and transferred securely. DWP have developed a secure ‘ESF Contact Details Uploader’which providers must use to submit their participant data.
To gain access to the uploader, please email a completed version of the ‘Annex 1’ form attached to the original funding agreement letter you will have received to ESF.EVALUATIONS@DWP.GOV.UK.
Upon receipt of a completed ‘Annex 1’ form, the ESF evaluation team shall send out an invitation to create an account on the uploader website, with a username and password enclosed within email. Instructions on how to use the uploader are available on the uploader website once the provider has signed in/created an account.
Important: Providers are not required to use/acquire PGP software to submit participant data as has been required in the past. Please do not send participant data via email to the ESF evaluation team.
Exceptionally, there may be a small number of participants who should not be re-contacted. These include, but are not limited to:
Transgender participants without a Gender Recognition Certificate
VIPs: Members of Parliament, Senior Armed Services Personnel, Senior Civil Servants and Members of the Peerage. Please note that local dignitaries, pop stars and sports personalities are not classed as VIPs
Participants who have served a serious custodial sentence (e.g. murder)
Participants who have given evidence to police in criminal cases
Participants who have run away from home to escape an arranged marriage
Participants who consider themselves to be at serious risk of domestic violence
Grant Recipients / providers should take appropriate steps to ensure that the contact details for participants belonging to sensitive groups are not included in data transfers to the Managing Authority. In these cases, the unique ID, leave date, and provision details fields should still be completed on the participant contact details data schema, but, the personal data fields (name, surname, address, postcode, telephone number, mobile number) should be left blank.
Any queries, as well as submission of the ‘Annex 1’ form from the funding agreement letter should be directed to firstname.lastname@example.org