NI Micro-business Hardship Fund Privacy Notice

This privacy notice describes how and why your personal data will be processed (‘collects’, ‘uses’, ‘retains’, ‘discloses’, ‘disposes of’) in relation to your application to the Micro-business Hardship Fund.

It also explains how you can control how we use your information in accordance with your rights under relevant data protection legislation.

Data Controller

Invest NI and the Department for the Economy are joint data controllers in respect of the personal data processed on applicants to the Micro-business Hardship Fund.

We process personal data in accordance with our obligations under the General Data Protection Regulation ('GDPR') and the UK Data Protection Act 2018 ('DPA').

For further information on our data handling practices you can also visit:
www.investni.com/privacy
https://www.economy-ni.gov.uk/dfe-privacy-notice

Contacting us

If you have a data protection query regarding the processing of your personal data, or to exercise any of your rights described below, please contact Invest NI by sending an email to dpo@investni.com or write to:

Data Protection Officer
Information Governance Team
Invest NI
Bedford Square
Bedford Street
Belfast
BT2 7ES

If you require a copy of this notice in an alternative format (including braille, disk, audio cassette or in minority languages to meet the needs of those who are not fluent in English), then please contact the Equality Team on:

T: 028 9069 8273
E: equality@investni.com
Text phone: 028 9069 8273

Purposes of the processing

Your data is processed for the purpose of administering the Micro-business Hardship Fund.

This includes:

  • Assessment of your eligibility
  • Verification of your application including
    • data matching to check for double funding
    • due diligence to verify your identity and prevent fraud
    • governance checks regarding management of public funds
  • Making payments to your business

The lawful basis for processing your data is the exercise of ‘official authority’ vested in Invest NI and the Department for the Economy for the purpose of carrying out our official functions or ‘public tasks’ as public sector bodies. Broadly these can be described as tasks related to economic development.

Sharing personal data

To facilitate administration of the Fund your data will be shared between Invest NI and the Department for the Economy.

To deliver this service we may also need to share your information with:

  • Contracted suppliers working on our behalf, who are subject to obligations of confidence;
  • Other public sector bodies in the interests of effective public governance and auditing purposes.

As required by law, we may disclose information to government bodies and law enforcement agencies for their enforcement purposes.

As this financial support is sourced from public funds Invest NI will, in the interest of openness and transparency, proactively publish limited information on the scheme.

This includes:

  • Name of applicant
  • Application title
  • Amount of assistance

As part of the application eligibility criteria checks for this scheme, Invest NI will also use the data you have provided to check against data held by Land & Property Services and HMRC, and Department of Communities and Department of Health related Covid-19 Funds.

Invest NI will also use your data to support other NI Government Departments and / or their agencies in administering other COVID-19 Funds. Currently this will include the Sports Hardship Fund.

Processing data outside Europe

Personal data processed for the delivery of this scheme will not be shared with third party organisations outside Europe.

Invest NI overseas offices have restricted access to Invest NI’s CRM system. This allows access to high level details of all companies on the system (such as name, address and contact details). Further access to business information is only granted on a case by case basis when a business requirement has been identified. In line with ICO guidance this is an ‘unrestricted transfer’ and complies with the requirements of GDPR.

Retaining personal data

Your data will not be retained for longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. Invest NI and the Department for the Economy will store and then destroy information in line with their respective retention and disposal schedules.

In the case of the Micro-business Hardship Fund this means your information will be retained for 7 years from the date of payment by both Invest NI, and the Department for the Economy.

Automated decision-making

Automated decisions, based on the information contained in the application form, will be carried out to assess the eligibility of an applicant.

This will entail the automated cross-referencing of specific fields on the application form; namely the VAT number; PAYE Number and whether previous grants have been awarded against data held by the respective organisations (see Data Sharing Section above).

If a VAT or PAYE number does not match the applicant then the application will not be successful. We request that you ensure that you enter the required information carefully and accurately.

Similarly we will cross-reference against databases from other government Covid19 support to establish whether you are eligible for this Fund. Depending on previous support you may be automatically deemed ineligible for this Fund.

Applicants have the option to access a human review of an automated decision if they feel an automated decision has been wrongly made based on the information provided. To request a review on this basis please contact with us through investni.com/contact-us.

Your rights

Right to access - you have the right to ask for the personal data that we hold about you to increase your awareness of and allow you to verify the lawfulness of the processing. To protect your privacy we may ask you to verify your identity.

Right to rectification - if you believe that personal data we hold on you is inaccurate or misleading then you have the right to request that it is rectified.

Right to erasure - In some circumstances you can ask for your personal information to be deleted.

Examples of right to erasure circumstances:

  • Where your personal information is no longer needed for the reason it was collected in the first place
  • Where you have removed your consent for us to use your information, where there is no other legal reason for Invest NI to use it
  • Where there is no legal reason for the use of your information

Please note that we cannot delete your information where:

  • We are required to have it by law
  • It is necessary to perform our functions as a public body
  • It is necessary for legal claims

It is envisioned that the right to erasure in relation to this Fund will be limited as the personal data is being processed in the exercise of 'official authority' i.e. following the requirements of legislation.

Right to restriction - in certain circumstances if you raise a complaint on how we have handled your personal data, you may also request that we 'restrict processing', meaning that the data will be preserved from further processing 'as evidence' either while we investigate your complaint or to support your complaint to the ICO.

Right to object - you have the right to object to processing if we are processing your information in the exercise of our public tasks, or is in our legitimate interests.

Right to data portability - in some circumstances, where you have provided your personal data directly to us that is processed by automated means and is done so purely on the basis of your consent, you will have the right to obtain and reuse your personal data in an electronic format for your own purposes across different services.

Right to lodge a complaint - If you are dissatisfied with any aspect of how Invest NI processes your personal data you can complain to the Information Commissioner's Office.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

T: 0303 123 1113 (local rate) or 01625 545 745
F: 01625 524 510
E: casework@ico.org.uk
W: https://ico.org.uk/