Data Protection Privacy Policy

Reinforce Potential CIC
Last updated: 30th June 2025

  1. Introduction

Reinforce Potential CIC (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This privacy policy explains how we collect, use, and protect your personal data when you use our services.

We are a Community Interest Company (CIC) registered in England and Wales. Our services include Access to Work grant management, application support, and coordination of self-employed support workers.

Our registered office is:
September Cottage Queen Street, Paddock Wood, Paddock Wood, Kent, TN12 6PJ

  1. Who We Are

Reinforce Potential CIC operates as:

  • An Access to Work grant management company, supporting clients from the application stage through to grant delivery and ongoing management.
  • A coordination agency for self-employed support workers, recruiting, verifying, and connecting subcontractor support workers with clients receiving Access to Work grants.

Important note:


Our support workers are self-employed subcontractors, not employees. As such:

  • Subcontractors are responsible for their own tax, National Insurance, and statutory obligations.
  • We maintain records of Unique Taxpayer References (UTRs), DBS checks, and insurance documentation, in line with safeguarding and quality assurance requirements.

Data Controller Details:

  • Company Name: Reinforce Potential CIC
  • Contact Email: support@reinforcepotential.co.uk
  • Contact Phone: 01843835551
  • Address: September Cottage Queen Street, Paddock Wood, Kent TN12 6PJ
  1. What Personal Data We Collect

3.1 For Clients (Grant Recipients)

  • Identity Data: Full name, date of birth, National Insurance number.
  • Contact Data: Address, email, phone numbers.
  • Employment Data: Employer details, job role, workplace address.
  • Disability/Health Data: Information about disabilities, support needs, medical evidence.
  • Financial Data: Bank details for grant payments, invoices, receipts.
  • Access to Work Data: Application forms, grant award letters, approved support requirements, DWP correspondence.

3.2 For Support Workers (Subcontractors)

We collect the following from subcontractor support workers:

  • Identity Data: Full name, date of birth, National Insurance number.
  • Contact Data: Address, email, phone numbers, emergency contacts.
  • Employment Data: CV, qualifications, training certificates, references.
  • Right to Work Data: Passport, visa, or identity documents.
  • Background Check Data: DBS certificates, professional registrations.
  • Self-Employment Data: Unique Taxpayer Reference (UTR), proof of professional indemnity/public liability insurance.
  • Performance Data: Timesheets, client feedback, training records. 

3.3 For Employers/Workplaces

  • Organisation Data: Company name, address, contact details.
  • Contact Person Data: Names, job titles, emails, phone numbers.
  • Workplace Data: Site addresses, accessibility information, health and safety requirements.
  1. How We Collect Your Data 

We collect data through:

  • Access to Work application support forms.
  • Direct communications (email, phone, post, meetings).
  • DWP referrals and grant documentation.
  • Background check providers and referees.
  • Client and support worker feedback systems.
  • Our website and online portals.
  • Third-party service providers (IT, training).
  1. Legal Basis for Processing

We process your data under UK GDPR using the following bases: 

5.1 Contract Performance

  • Managing Access to Work applications and grant services.
  • Matching clients with suitable subcontractor support workers.
  • Managing service delivery and financial processing.

5.2 Legal Obligations

  • DWP reporting requirements for Access to Work grants.
  • Safeguarding vulnerable adults.
  • Right to work and identity verification for subcontractors.

5.3 Legitimate Interests

  • Business administration and service delivery.
  • Quality assurance and monitoring.
  • Fraud prevention.

5.4 Special Category Data (Health/Disability Information)

We process health-related data under:

  • Your explicit consent (see section 5.5 below).
  • Substantial public interest for equality of opportunity.
  • Contractual necessity for service provision.

5.5 Consent Clause (New)

For special category data (including health/disability information), we will seek your explicit consent before processing.

You may withdraw consent at any time by contacting us at:
[Your Data Protection Email]

Please note: Some processing (such as DWP reporting) may still be required by law. 

  1. How We Use Your Personal Data

6.1 Service Delivery

  • Supporting clients through Access to Work applications and grant management.
  • Matching clients with verified, self-employed support workers.
  • Coordinating support delivery in the workplace.
  • Processing service-related financial transactions.

6.2 Legal and Regulatory Compliance

  • Reporting to the DWP on grant use and service delivery.
  • Maintaining safeguarding and right-to-work documentation.
  • Keeping records of subcontractor DBS status, UTR, and insurance cover for due diligence.

6.3 Business Operations

  • Service quality monitoring and improvement.
  • Subcontractor training and development.
  • Customer service and complaint resolution.
  • Financial reporting and audit compliance. 
  1. Data Sharing and Recipients 

We may share your data with:

7.1 Government Bodies

  • DWP: For Access to Work grant processing and reporting.
  • Local Authorities: For safeguarding referrals when necessary.

Note:
We do not report tax or NI data for subcontractors to HMRC.

7.2 Service Providers

  • IT and database hosting providers.
  • DBS check agencies.
  • Training providers.

7.3 Professional Advisors

  • Legal advisors, accountants, auditors.
  • Insurance providers.

7.4 Within Our Organisation

Information is shared internally only where necessary for service delivery.

  1. Data Retention
  • Client records: 7 years after grant end.
  • Subcontractor records: 7 years after final service delivery.
  • Financial records: 7 years.
  • DBS and insurance records: Until renewal or subcontractor disengagement.
  • Safeguarding records: As per local authority guidelines.

Special category data is deleted at the earliest opportunity consistent with legal obligations.

  1. International Transfers

We do not routinely transfer data outside the UK.
If this becomes necessary (e.g., cloud storage), we use appropriate safeguards:

  • UK adequacy decisions.
  • Standard contractual clauses.
  • Binding corporate rules.
  1. Data Security

We use appropriate technical and organisational measures, including:

  • Encrypted data storage and transfer.
  • Secure user access controls.
  • Staff training in data protection.
  • Regular system updates and security reviews.
  • Secure disposal of physical and digital records. 
  1. Your Rights Under UK GDPR

You have the right to:

  • Access: Request copies of your data.
  • Rectification: Request corrections.
  • Erasure: Request deletion (where lawful).
  • Restriction: Ask us to limit processing.
  • Portability: Request a copy in a structured format.
  • Objection: Object to certain processing (e.g., legitimate interests).
  • Automated Decision-Making: Not be subject to purely automated decisions.

Note:
Some rights may be limited due to DWP, safeguarding, or other legal obligations.

  1. Exercising Your Rights

To exercise your rights:

  • Email: support@reinforcepotential.co.uk
  • Phone: 01843835551
  • Post: September Cottage Queen Street, Paddock Wood, Kent TN12 6PJ

We will respond within one month of receiving your request.

  1. Complaints

If you are unhappy with how we handle your data:

  1. Please contact us directly first.
  2. You can escalate to the Information Commissioner’s Office (ICO):
  • Website: https://ico.org.uk
  • Phone: 0303 123 1113
  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
  1. Data Protection Officer

We have appointed a Data Protection Officer (DPO).

Contact them at:

  • Email: support@reinforcepotential.co.uk
  • Phone: 01843835551
  1. Changes to This Policy

We may update this privacy policy periodically.

We will notify you of material changes via:

  • Email to registered users.
  • Updates posted on our website.
  • Notices included in service correspondence.
  1. Contact Information

For questions about this policy:

Reinforce Potential CIC

  • Address: September Cottage Queen Street, Paddock Wood, Kent TN12 6PJ
  • Email: support@reinforcepotential.co.uk
  • Phone: 01843835551
  • Website: https//reinforcepotential.co.uk

 

This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.