REFRAME Study Privacy Notice

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We are carrying out a study of people taking part in the REFRAME study to try to find out how the service might help young people in the future. The study is being funded by the Youth Endowment Fund (YEF). At the end of the study data collected will be stored in a secure archive and used to follow-up on children’s progress in the future. This will include, for example, assessing whether children who took part in YEF- funded projects were less likely to be excluded from school or get involved in crime in the future.

This privacy notice provides information about who we are, what we are doing, and why we are doing it. It also explains how we will use personal information we collect as part of the study.

1. Who are we?

This study is being organised by the Centre for Health Service Studies at the University of Kent (www.kent.ac.uk/chss)

When we collect and use participants’ personal information as part of the study, we are the controllers of the personal information, which means we decide what personal information to collect and how it is used.

2. What are we doing?

We are evaluating a new way of managing young people who come to the attention of the police who are found to have illegal substances in their possession. Our study explores whether this new approach is better than the approach usually employed. Our research will inform us about what works best for young people and their families.

Contact details:

Project Lead – Professor Simon Coulton, s.coulton@kent.ac.uk, 01227 824535
Data Protection Office –dataprotection@kent.ac.uk

The YEF, which funds this study, is dedicated to preventing children and young people becoming involved in crime and violence. Once we have finished our study, YEF-approved researchers will explore whether REFRAME, and other programmes funded
by YEF, had an impact over a longer period of time, including whether they reduced involvement in crime and violence. This is explained in more detail below.

3. Who has reviewed this study?

This study has been reviewed and approved by the University of Kent Social Research Ethics Committee ref SRC 0498

4. How will we use the personal information that we collect?

Data protection laws require us to have valid reason to use [your child’s/the child in your care] personal information. This is referred to as our ‘lawful basis for processing’.

We rely on the public task basis to use their personal information. We will only use special category information (such as information about health, religion, race or ethnic origin, or any criminal offence information) if it is necessary for research purposes or statistical purposes which are in the public interest.

We will use the information they give us to evaluate how well REFRAME has worked and to write a report about our findings based on all of the questionnaires and/ or interviews we have carried out.

The final report and any other publications produced by the University of Kent will not contain any personal information about the people who took part in the study and it will not be possible to identify individuals from the report. The report will be published on the YEF’s website.

Any personal information that [you/your child/the child in your care] gives us will be stored securely and kept confidential.

  • We may share this personal information with another person or organisation if [your child/the child in your care] tells us something during the study that makes us concerned about them or about someone else. Our Safeguarding Policy has more information about steps that we might take if we have concerns about [your child’s/ the child in your care’s] wellbeing, or the wellbeing of another person.
  • Once we have finished our study, we will share all of the information we have gathered about everyone who has taken part with the Department for Education (DfE). The DfE will replace all identifying information about the young people who have taken part in the study (their name, gender, date of birth, home address) with the young person’s unique Pupil Matching Reference number in the DfE’s National Pupil Database. Once this has been done, it is no longer possible to identify any individual young person from the study data. This process is called anonymisation.
  • Once information is transferred to the DfE to be anonymised, we hand over control to the YEF for protecting your personal information. The DfE will transfer
    the anonymised information to the YEF archive, which is stored in the Office
    for National Statistics’ Secure Research Service. The YEF is the ‘controller’ of the information in the YEF archive. By maintaining the archive and allowing approved researchers to access the information in the archive, the YEF is performing a task in the public interest and this gives the YEF a lawful basis to use personal information.
  • Information in the YEF archive can only be used by approved researchers to explore whether REFRAME, and other programmes funded by YEF, had an impact over a longer period of time. Using the unique Pupil Matching Reference numbers added to the data by the Department for Education, it will be possible to link the records held in the YEF archive to other public datasets such as education and criminal justice datasets. This will help approved researchers to find out the long- term impact of the projects funded by YEF because they’ll be able to see, for example, whether being part of a project reduces a child’s likelihood of being excluded from school or becoming involved in criminal activity.

5. How is information in the YEF archive protected?

The YEF have put in place strong measures to protect the information in their archive. As well as the pseudonymisation process described in section 4, the YEF archive is protected by the Office for National Statistics’ ‘Five Safes’ framework. The information can only be accessed by approved researchers in secure settings and there are strict restrictions about how the information can be used. All proposals must be approved by an ethics panel. Information in the YEF archive cannot be used by law enforcement bodies or by the Home Office for immigration enforcement purposes.

You can find more information about the YEF archive and the Five Safes on the YEF’s website [insert this link if you are working on a YEF Launch Grant Round Project: [insert link to the YEF guidance for participants relating to the grant round relevant to your project, available from the YEF archive web page: https://youthendowmentfund.org.uk/ evaluation-data-archive/]. We encourage all parents and guardians to read the YEF’s guidance for participants before deciding to take part in this study.

Once information goes into the YEF archive it can no longer be deleted as that would affect the quality of the archived data for use in future research.

6. Retention and deletion

The University of Kent will keep [your/your child’s/the child under your care’s] an anonymised copy of the data for a period of five years after the end of the study. Once the collection and quality assurance of data for the final participant has been collected and the data transferred to the YEF data archive all personal identifiable information will be removed from the dataset. At this point no individual will be identifiable using the data held by the University of Kent.

The YEF will keep information in the YEF archive for as long as it is needed for research purposes. Data protection laws permit personal information to be kept for longer periods of time where it is necessary for research and archiving in the public interest, and for statistical purposes. The YEF we will carry out a review every ten years to assess whether there is a continued benefit to storing the information in the archive, based on its potential use in future research.

7. Data protection rights

[You/You and your child/You and the child in your care] have the right to:

  • ask for access to the personal information that we hold about them;
  • ask us to correct any personal information that we hold about them which is incorrect, incomplete or inaccurate.

In certain circumstances, you also have the right to:

  • ask us to erase the personal information where there is no good reason for us continuing to hold it – please read the information in section 5 about the time limits for requesting deletion of your personal information;
  • object to us using the personal information for public interest purposes;
  • ask us to restrict or suspend the use of the personal information, for example, if you want us to establish its accuracy or our reasons for using it.

If you want to exercise any of these rights during the study period, please contact our Data Protection Officer using the details provided earlier. We will usually respond within 1 month of receiving your request.

If you want to exercise any of these rights after the study has finished (i.e. after the point when information has been shared with DfE), please contact the YEF. Further information and their contact details are available at hello@youthendowmentfund.org.uk.

When exercising any of these data rights, we may need to ask for more information from [You/You and your child/You and the child in your care] to help us confirm their identity. This is a security measure to ensure that personal information is not shared with a person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8. Other privacy information

Categories of personal information

  • First name
  • Surname
  • Date of Birth
  • Home address
  • Alternative address (if appropriate)
  • Telephone number
  • Email address
  • Social media contact details (if willing to provide)

Sharing their personal information

We only ever use [your/your child’s/the child in your care’s] personal information if we are satisfied that it is lawful and fair to do so. Section 4 above explains how we share data with the Department for Education and the YEF. If you decide to take part in the study, we may also share their personal information with the police who will provide any interactions they have had with the young person over a 12-month period, 6 months prior and 6 month after agreeing to participate in the study.

Data security

We will put in place technical and organisational measures in place to protect [your/your child’s/the child’s in your care] personal information, including:

  • Limiting access to specific named researchers who require access to conduct the study, such as contacting young people for follow-up.
  • Keeping personal details such as name and address separate from all other data and linking these using a unique identifier.
  • Keeping data on a secure encrypted server and ensuring data is regularly backed up for security purposes.

International transfers

We will not transfer your personal data outside the UK.

9. Feedback, queries or complaints

If you have any feedback or questions about how we use personal information, or if you want to make a complaint, you can contact the lead researcher or Data Protection Officer using the details provided earlier.

We always encourage you to speak to us first, but if you remain unsatisfied you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues: https://ico.org.uk/make-a-complaint/ .