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Partner Programme Privacy Notice

Updated: September 2020

This privacy notice aims to provide you with transparency and understanding about the personal data collected by Right Management Limited (the Data Processor), on behalf of the Data Controller, the Ministry of Defence (MoD), in an agreement known as the Career Transition Partnership (CTP). Right Management’s registered office is in 50 Bank Street, Canary Wharf, London, E14 5NS, United Kingdom.

This notice is in compliance with data privacy law, including the General Data Protection Regulation (EU) 2016/679, known as GDPR, and the supplementary provisions as defined in the UK Data Protection Act 2018.

This privacy notice applies to Partners and Spouses of MoD serving personnel, who:

  1. Apply for support via the Partner Career Support Programme (PCSP)
  2. Are eligible for, and supported by, the PCSP
This privacy notice does not apply to Right Management Limited employees or associates, or other users of our Sites and Services. A privacy notice for those military personnel leaving the services and in resettlement can be accessed here.

Your data privacy and information security is paramount and we place great care in the responsible, transparent and safe handling of data. This notice describes the type of personal data and information we collect, how we use it, how long we process and store it, how we protect it, with whom we share it, to whom we transfer it and the rights that you can exercise regarding our use of your personal data. We also describe how you can contact us to further enquire about our privacy practices or to exercise your rights.

You can click on one of the links below to jump to the listed section:

Your rights as a Data Subject
When we process your data
Information we collect
How we use the information we collect
MoD research
Legal basis for processing
How we protect personal information
How long we process and store the data
Information we share
Updates to our privacy notice
How to contact us

Your rights as a Data Subject

When permitted by applicable law, a data subject can exercise the following specific rights:

a) Right of Access: You have the right to view the data we hold on record for you to ensure your personal data is being processed in accordance to the law. This is more commonly referred to as a Subject Access Request
b) Right to Rectification: You have the right to request the rectification of any inaccurate or incomplete data held about you, in order to protect the accuracy of such information and to adapt it to the data processing. If you believe any of the data we process about you is incorrect or incomplete, please contact us and we will take reasonable steps to check its accuracy and correct it where necessary
c) Right to Erasure: Otherwise known as ‘The Right to be Forgotten’; you have the right to request that we no longer process your personal data and erase all information about you. Please be aware, this is not an absolute right and there may be legal or regulatory reasons why data cannot be erased at the time of the request
d) Right to Restriction of Processing: You have the right to request we restrict the processing of your data for certain purposes
e) Right to data portability: You have the right to request data portability from the Data Controller, meaning that you can receive your personal data in a structured and commonly used format, or that you can request the transfer of your data to another Data Controller
f) Right to object: At any time, and without having to justify your decision, you have the right to object to the processing of your data for direct marketing purposes. Please be advised CTP will not use your data for direct marketing purposes; we will only ever contact you in relation to the PCSP you registered for. Please note: if you withdraw your consent at any time, the previous processing of data that we have done with your consent will remain lawful
g) Right not to be subject of automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect or similarly significantly affects you. Right Management Limited do not use processes in which automated decision-making (including profiling) takes place
h) Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged GDPR infringement. The supervisory authority in the UK is the Information Commissioners’ Office (ICO). More information can be found at https://ico.org.uk/

Whenever the processing is based on consent, as under Article 7 of the GDPR, while you may withdraw your consent at any time, there may be circumstances where we will still need to process a portion of your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific requirements.

If you wish to exercise any of your rights in relation to data privacy, or understand more about them in the context of the service we provide for you, please refer to the How to contact us section below. Click here to jump to that section.

When we process your data

We process your data from the moment you give consent for Right Management Limited and the Ministry of Defence to process your data by applying for the PCSP.

Thereafter, if you:
  1. Complete questionnaires and evaluations related to the PCSP
  2. Engage in career coaching, video, telephone or video call
  3. Enter your details on CTP MyCareerPath
  4. Message us via our social media channels or any ctp.org.uk email address
  5. Visit our Sites including our social media channels outlined above
  6. Otherwise use our Services.

Information we collect

In order to deliver the programme, we will collect a selection of personal data, including, but not limited to:
  • Contact information (including full name, alias, personal email address, contact telephone number)
  • Personal details, which will include your partner’s Service, service number, rank and your current town/city of residence
  • Information you provide via the MyCareerPath site including Career Pulse responses and scores
  • Information you provide during career guidance, including salary expectations, industry preferences, employment details etc
  • CV data e.g. employment history, academic or vocational qualifications etc. This will include information provided via the myCV tool on the MyCareerPath site
  • Information you provide in evaluation surveys
  • Information you provide in any email sent to a ctp.org.uk address
  • Username and password when you register on our online platforms
  • User IP address
  • Identification information you may be asked to provide, should you wish to exercise specific data rights.

How we use the information we collect

The CTP uses the data gathered for the following purposes (as permitted under local law):
  • To fulfil the services contracted; supporting military Partners and Spouses in maximising their efforts to gain or maintain employment suitable to their own personal circumstances
  • To ensure you are eligible to participate in the programme
  • To ensure the information we have is accurate, allowing us to correct it if needed
  • To help us understand your circumstances, determine your needs, tailor our support and guide you in achieving your sought outcome
  • To communicate information and content appropriate to your programme with you, via email, telephone call, video call and text message
  • To enable us to effectively handle any potential queries and/or concerns you may have
  • For the effective operation, evaluation and improvement of our service. This includes: reporting, developing, enhancing, analysing and improving our services; managing our communications and performing data/statistical analysis
  • For research purposes (see Research section for more detail)
  • To comply with and enforce all applicable legal requirements, relevant industry standards, contractual obligations and our policies
  • To identify, protect against, and attempt to prevent fraud and other unlawful activity
  • We use various IT resources and productivity tools, such as e-mail, to communicate with each other and with you. We keep a history of this for as long as is needed for follow-up, accountability and security. This data is hosted and backed up on UK based servers
  • In order to optimise your user experience and to better tailor our offer to you, we use Cookies and similar technology, where permitted under law and consistent with our Cookie Policy.

MoD research

As part of this programme, you will be asked to complete a Circumstances Questionnaire at the start of your programme, and an Impact Evaluation at the end of the programme. Some of the questions are marked as mandatory because CTP need the information requested to understand your current circumstances in order to support you effectively.

The remaining questions in the Circumstances Questionnaire are entirely voluntary and are the research questions set by Defence People, an MoD department working with the MoD Families Policy Team. These are not mandatory questions and you can skip through them, should you wish.

The research questions aim to capture information on the views and experiences of spouses/partners who are taking part in the programme, in order to understand the impact of the PCSP.

Your replies will be treated in the strictest confidence, and to make sure your views remain confidential, your responses will be anonymised before they are sent to the research team and only grouped answers will be reported.
Should you have any complaints about the survey, you can email the Defence People team at: People-Strat-CDPREGroup@mod.gov.uk

Legal basis for processing

All processing will be carried out based on adequate legal grounds which may fall into several categories, including:
  1. Fulfilment of Contract
  2. Explicit consent from you, where required by applicable law
  3. Legitimate interest e.g. letting the user access the website to be provided with the services offered, to enhance the security of our network and information systems, to identify and prevent fraud, to understand how people interact with our Sites, to determine the effectiveness of our communications.
Whenever we process data under the lawful basis of Legitimate Interest, we will ensure that we keep your rights in high regard. You have the right to object to processing (more details in section Your rights as a Data Subject, above). Please bear in mind that if you exercise your right to object, this may affect our ability to carry out and deliver services to you for your benefit.

How we protect personal information

We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. Our information security standards are ISO 27001 aligned.
We process the personal data we collect for the purposes defined in this notice, and for a period only as long as necessary for the purposes we collected it. Different laws and contractual obligations may also require us to process different data for different periods of time.

All data gathered by Right Management Limited, in association with the MoD agreement, is stored and backed up on UK based servers and treated with the strictest confidence and integrity.
We do not disclose personal data that we collect about you, except as described in this privacy notice.

A small number of third-party suppliers, who perform services on our behalf based on our instructions, for example web developers and IT support, will have access to some of the data processed. However, these are trusted suppliers that have undergone a due diligence process to ensure they are GDPR compliant. Robust contracts with processing/data sharing agreements are in place with these suppliers to ensure they too handle your personal data carefully. We never sell your data to third parties.

In addition, we may disclose personal data about you on the following basis:
  1. To law enforcement authorities or other government officials based on a lawful disclosure request
  2. If we are required to do so by law or legal process
  3. When we believe disclosure is necessary or appropriate to prevent physical harm, risk to life or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

Updates to our privacy notice

This privacy notice (including any addenda) may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by indicating at the top of each Notice when it was most recently updated.
If you have any questions/comments about this privacy notice, if you would like to exercise your rights, or you think you have identified any weakness or data privacy related concern on one of our Sites, please email us at:

Or write to us at:

The Data Privacy Officer
Right Management Ltd
50 Bank Street
Canary Wharf
London E14 5NS