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Restart scheme participant portals - all are "not mandatory"?

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Dear Department for Work and Pensions,

Please provide information that your Restart providers, due to the GDPR and the Data Protection Act 2018 cannot mandate participants to create an account with and or use providers employment and health related portals, as they all appear to grant providers direct access to all of users personal data and account use data?

As DWP and it's Restart providers can be both Data Controllers and Data Processors, it would appear that all the personal data that is generated by account holders or users of these portals is processed by your providers on behalf of the DWP. Please provide information that confirms this.

For example your provider Reed in Partnership uses a portal called the:

[1] Online Career Centre
https://reedinpartnership.careercentre.me/ accessed via reedrestart.co.uk

Noting it's Privacy Policy says:

5. WHO WE MAY SHARE PERSONAL DATA WITH (RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE PERSONAL DATA)

"(a) As part of providing the Services, we may disclose your personal data to your Institution [Reed] (which may include their administrators, coaches and other authorised personnel)"

7. RIGHTS OF INDIVIDUAL USERS

"(c) You may withdraw your consent to our future processing of your personal data (and stop using the Services) at any time by submitting a request in writing to your Institution or to us at [email address]"
https://reedinpartnership.careercentre.m...

But Reed's Restart Induction Pack makes no mention that use of it's 'Online Career Centre' appears to be entirely voluntary. (see 7, (c) above). Unlike Reed's Wellness portal https://www.workplacewellnessportal.com/ also accessed via reedrestart.co.uk which does state:

"Please note that the health assessment is not mandatory, and therefore, should you not provide us with consent, we would unfortunately not be able to carry out the health assessment" https://www.workplacewellnessportal.com/...

Though again Reed's Induction Pack does not state the 'Wellness' portal "is not mandatory"
https://www.whatdotheyknow.com/request/r...

Other portals include:

[2] IWORKS PARTICIPANT PORTAL
CPA 3a Ingeus Gtr Man

[3] Seetec’s Online Portal
CPA 4a Seetec Pluss

https://www.whatdotheyknow.com/request/r...

in the past DWP created it's own employment portal called Universal Jobmatch (UJ)
and DWP staff like a Work Coach could not access benefit claimants UJ account(s) and data unless they gave consent by explicitly opting-in. I am unable to find any information that your Restart providers have included any equivalent fully informed explicit opt-in consent for [1] and [2] and [3] for any Restart participant who creates and uses a portal account and or is, once an account is created has the option to prevent Restart providers staff from viewing and accessing account users data

Please provide information that confirms your Restart providers cannot issue a Mandatory Activity Notice for participants to create and use any employment or health portal account? Noting:

Universal Jobmatch Equality analysis, version 5
2013
"7.17 Advisers will only be able to access a JSA claimant’s Universal Jobmatch account with the consent of the claimant (even where the JSA claimant has been mandated to create a profile and a public CV in Universal Jobmatch)."
https://www.bl.uk/britishlibrary/~/media... pdf

Yours faithfully,

Frank Zola

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Dear Department for Work and Pensions,

To clarify, I wish to amend the following sentence of my request for information:

"Please provide information that confirms your Restart providers cannot issue a Mandatory Activity Notice for participants to create and use any employment or health portal account?"

To:

Please provide information that confirms your Restart providers cannot issue a Mandatory Activity Notice for participants to create an account on and or use any Restart providers own or commissioned employment or health portal, for which they are a Data Processor or Data Controller?

Yours faithfully,

Frank Zola

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Frank Zola left an annotation ()

Portal provider to DWP providers
https://www.abintegro.co/clients/skills-...

DWP Central FOI Team,

1 Attachment

Dear Frank Zola,

I am writing in response to your request for information, received 7th
September.

Yours sincerely,

DWP Central FoI Team

We don't know whether the most recent response to this request contains information or not – if you are Frank Zola please sign in and let everyone know.