South Midlands Growth Hub Privacy Notice

1. Council contact details

1.1. West Northamptonshire Council

Registered Office:
One Angel Square
Angel Street
Northampton, NN1 1ED
Contact centre telephone: 0300 126 7000

The Data Controller is West Northamptonshire Council
ICO registration number: ZA896620
The Growth Hub team can be contacted by email at [email protected]

1.2 This privacy notice sets out the information for the South Midlands Growth Hub:

The South Midlands Growth Hub provides free business advice and guidance across the South Midlands (Bedfordshire, Milton Keynes, and Northamptonshire). We’re a multipurpose, multifunctional hub that goes above and beyond for all businesses, regardless of their size, industry or stage along their journey to success.

This privacy notice covers the processing of personal data carried out by the South Midlands Growth Hub and associated services, as required to deliver business support. This includes the South Midlands Growth Hub including all its funded and part-funded programmes as well as legacy programmes, our newsletter, and the relationship to the Business Support Service.

1.3 This privacy notice should be read in conjunction with the:

2. Information that we hold

2.1. Information about the types of data we collect to deliver this service

The personal and special category data we collect varies according to the purpose of the contact. Applications for our services are not restricted to people living or working in West Northamptonshire. Anyone is entitled to contact the South Midlands Growth Hub about our service.

The information we hold may include:

your full name
your address (including postcode), if it is a personal address for your business
your telephone number(s)
your email address
payment details (card numbers, etc.) which are held securely and encrypted in the Council’s financial systems
further personal details such as gender
imagery (photographs & video footage)

Where applicable we will also collect and process Special Category Data for equality and diversity monitoring, all of which are optional and not a requirement of receiving support from the Growth Hub:

Age bracket
Racial or ethnic origin
Disability
Sexual orientation

3. How and why your information is collected and used

3.1. How we collect this personal information

Most of the personal information we process is provided to us directly by you in the following ways:

Face to Face
Reports
Online application form(s)
Telephone
Email or in writing

We may also receive information from the following:

Programme delivery partners including but not limited to: specialist program partners or event partners (it will be clear in communication who the different partners are)
Referral partners (for example: local councils, chamber of commerce, BIPC)
Publicly available information from sources such as Companies House
Information from third party databases including credit reference agencies

3.2. Why we collect your information

There are a number of reasons why we need to collect and use your personal information.

Much of what we do in the Growth Hub is governed by legislation, which requires us to provide various services across South Midlands. We process personal data to deliver our services as set out in section 4.1 below:

The information we collect, and store is also used to provide an auditable record of service delivery and enables us to contact people for further support for the business, initiating reports/issues to request further information or provide updates.

Whenever we collect information, we always limit this to only the details that are needed. We ensure that data is used and stored safely and securely. We require anyone we share information with, or who uses it on our behalf, to process your data in line with the principles set out in this privacy notice.

All Growth Hub staff have received training on data protection and information security.

3.3 Lawful processing

We rely on the following lawful reasons to process your personal data in the South Midlands Growth Hub.
UK GDPR Article 6 – Personal Identifiable Information (PII)
a.    Consent has been provided by the data subject;
b.    Processing is necessary for the performance of a contract;
c.    Processing is necessary for the performance of a task carried out in the public interest;
d.    Processing is necessary for the purposes of the legitimate interests pursued by the controller.
UK GDPR Article 9(2) – Special Category Data (SCD)
a.    Explicit consent has been provided by the data subject;

4. What we do with the information

4.1 How we use your personal information

We use the data we collect to:

enable the delivery of a service such as providing ongoing specialist support
evidence service delivery to our funders: The Department of Business and Trade (DBT) and any specific programme funders
provide tailored employment support
evaluate and improve the Growth Hub programme and services
ensure compliance with funding and legal requirements

The information will only be used for the purposes stated when it was collected. Information will not be sold, rented or provided to anyone else, or used for any other purpose than that for which it was originally collected unless required to by law.

4.2. Who we share your information with

The South Midlands Growth Hub is a funded business support service, and it is necessary that we share the details you provide to us with our funders such as the Department for Business and Trade, or any specialist programme funders for research and evaluation purposes in line with the funding agreement.
We may also share the details you provide us with other project delivery partners, as well as other identified organisations who can provide additional support within the context of this support service.

Any sharing of personal data is always done:

on a case by case basis
using the minimum personal data necessary
with the appropriate security controls in place

We may also share your data with selected third parties who provide operational services that the Growth Hub uses.

These are:

Gavin Willis Web Creative Marketing: Manage and host the South Midlands Authorities website
Alcium Software: Manage and host our web-based Customer Relationship Management system
Growth Canvas: Tool used to help businesses increase growth and productivity
Fliweel.tech: AI phone system management

We limit access to your personal information to those who have a genuine business need to know it on the programme or where you have consented to the sharing of your personal data. When we publish information into the public domain, we will follow procedures to remove personal data associated with the record before publishing.
We will share personal information with law enforcement agencies or other authorities only if required by applicable law and in accordance with UK GDPR and the Data Protection Act 2018.

4.3 Automated decision making

We do not use automated decision making for this processing. Automated decision-making is where decisions are made about you without any human influence on the outcome. These may affect your legal rights or have an impact on your circumstances, behavior or choices.

4.4 Data Profiling

There is no profiling undertaken in relation to this processing. Profiling is where parts of an individual’s personality, behavior, interests and habits are analysed to identify their preferences, make predictions or decisions about them.

4.5 Automated Processing including AI

The South Midlands Growth Hub service uses automated processing or Artificial Intelligence in respect of your personal data including:

Web chat system
AI phoneline Business Adviser support and triaging
Internal or external text generation tools to create case file notes and reports

5. How long we keep your information for and how we securely dispose of it after use

5.1. Information about how your personal data is kept

We only keep information for as long as it is needed in line with the council’s retention schedule. This will differ according to the type of information we hold and its purpose. It will be based on either a legal requirement (where a law says we have to keep information for a specific period of time), a regulatory requirement or accepted business practice.

5.2 We will securely dispose of your information in line with the Council's Retention Schedules.

6. How we store your information

6.1. Physical (paper) records

Any physical records of personal data may be collected from various sources throughout the programmes of support, they will be processed by sorting and filing this information will be transferred as soon as practically possible into an electronic format as per section 6.2.
All paper records will be destroyed using the councils certified confidential waste system.

6.2 Electronic information

Digital data is securely stored on the South Midlands Growth Hub/West Northamptonshire Council computer network or on cloud severs in the UK.

Digital data is also securely saved on our cloud based information management system, Alcium Evolutive.

7. Your data protection rights

7.1. The law gives you a number of rights to control what personal information is used by us and how we can use it. Please see section 5 of the council's Privacy Policy for further information.

7.2. Please be aware that your rights may differ depending on the lawful basis for processing your personal data.

8. Who to contact

8.1. If you would like further information about how we use your personal information, or you wish to exercise one of your data rights or you wish to complain about the use of your personal information please contact the Data Protection Officer.

8.2. If you are still dissatisfied with how we have used your data once you have made a complaint through the council’s internal complaints procedure you have the right to complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

9. Changes to this Service Privacy Notice

9.1 Privacy notices are live documents and will be updated or revised periodically in line with service changes and / or new legislation requirements.

This privacy notice was last updated: June 2026
The update reference number is: PNS/26/060/A

Last updated 20 August 2026