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Privacy Policy

The Growth Company Employment Privacy Notice

We take the security of your personal data very seriously.  This privacy notice sets out why we need your information, what we need and how we will use it.

It is important that you read this privacy notice together with any other privacy information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.


Why do we collect your data?

The Growth Company (GC) is involved with the delivery of services for various commissioners and public bodies including the Department for Work and Pensions (DWP). The DWP are the commissioner for the Kickstart scheme and their privacy policy can be found here.  The Growth Company have an obligation to collect information in line with the purposes of the aims and objectives of the Kickstart programme, to ensure we are able to effectively deliver the scheme.  We also have an obligation to you as an individual to collect the data that is necessary, and only that which is necessary, to help you achieve your aims and objectives.

The Growth Company are a “Data Controller” and work alongside DWP and your Kickstart employer who are also “Data Controllers” in their own right (and will provide you with their own privacy policies).  The Growth Company only process data for which we have a lawful basis to do so in line with the General Data Protection Regulation (article 6).

In the cases of the Kickstart scheme our lawful basis for processing is:

  • Performance of Contract which means processing your data where it is necessary to perform the contract to which you are a party or to take steps at your request before entering into such a contract, i.e. the Kickstart scheme.
  • Where GC collect special category data this is only done with your consent. Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data.

We understand the value and importance of trust where data is concerned, and as such, we will always handle your data with the upmost respect.

What information do we collect?

The Growth Company we will only ask you for data that is needed to deliver, monitor and evaluate our services, and this includes:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, age, nationality, national insurance number and gender.
  • Contact Data includes home address, email address and telephone numbers and emergency contact details
  • Employment & Educational Data includes job title, qualifications, employment status, references, employment ID, employment records and salary.
  • Special Categories of Personal Data includes details about your race or ethnicity, and information about your health.

If you have contacted us for support or joined one of our programmes, we may have a “legitimate interest” (GDPR Article 6 (f)) to contact you for Sales and Marketing purposes to see if we can offer you any further support or would be willing to take part in research and evaluation surveys to help improve our services.  If you feel you don’t need any further support from us, you can opt out from any future communications and contact us whenever you need us again in future.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How is your data used?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To perform the contract we are about to enter into or have entered into with you, the DWP and your employer.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests (providing your fundamental rights do not override those interests).
  • Where we need to comply with a legal or regulatory obligation, for example where this is a requirement to provide Safeguarding support to those who access our services and who may be at risk.

Where is your data stored?

The data held on The Growth Company’s systems is processed within the UK.

Sharing your data

We may have to share your personal data with the parties set out below for the purposes of the Kickstart programme:

  • Your Employer.
  • The DWP.
  • Other trusted Third Parties such as training providers or organisations to provide additional support and guidance.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify both you and the relevant regulator(s) of a breach where we are legally required to do so. 

Data Retention

We will not store your data for longer than is necessary to fulfil the contractual obligations, including satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us.

Your Data, Your Rights

For any data we record, you have the following rights (for more details please see Your legal rights below):

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

You also have the right to withdraw consent at any time and can exercise this right by writing to:

Data Protection Officer, The Growth Company,  Lee House, 90 Great Bridgewater Street, Manchester, M1 5JW

Your responsibilities

The Growth Company will protect your data according to GDPR legislation; however, this does not negate the need for everyone to be fully aware and vigilant of their own responsibilities in protecting their own data.  We encourage and remind you to be aware of your surroundings at all times and to not leave information unattended in any format (i.e. physical or digital).

The Growth Company cannot accept responsibility for loss or theft of data resulting from negligence of an individual.  If you would like to discuss how to better understand data security please do raise this with your main point of contact.



If at any time you feel unhappy with any aspect of our service, in particular the way we have handled your data, you must inform us as soon as possible.  In this first instance, you should first speak to your point of contact at The Growth Company whom you have been dealing with and explain your concerns. It is our aim that they will be able to help resolve any issues you may have.

However, if after discussing your concern you are not satisfied you do have a right to make a formal complaint by following the process on our website:

If you feel we have been either unable or unwilling to resolve your data concerns you have the right to make a complaint to the supervisory authority for UK Data, the Information Commissioner’s Office (ICO), using the details below:

The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Telephone: 08456 30 60 60


For more information, including a template you can use to raise a concern, please visit the relevant page at the ICO website here:

Your legal rights

You have the right to:

  • Request access to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.