The NEET Agent

Privacy Policy

Public privacy notice for The NEET Agent website, Opportunity Mapping and related services

Legal operator	MO SSC LTD trading as DAESP Culture / DAESP ABC / The NEET Agent
Company number	13711111
Registered office	235 Frances Street, London, England, SE18 5LA
Privacy / legal email	p3kay@daespculture.com
Telephone	07492 505008
Version	Version 1.1 - Website Edition
Effective date	13 September 2026

This public notice reflects the Data Protection, Privacy & Information Governance Policy and Safeguarding & Safer Working Policy used by The NEET Agent.

Our Privacy Principle Use what is necessary. Protect what is entrusted to us. Share only for a proper purpose. Keep people at the centre of the opportunity.

Quick privacy summary

Topic	What this means
What we do	The NEET Agent uses Passion & Purpose-Led Opportunity Mapping to understand what people want to achieve, identify possible pathways and opportunities, support safe introductions, and evidence progression.
Who we work with	Seekers of different ages, including young people; Businesses and Opportunity Providers; schools, colleges, councils, Jobcentre-linked services and other commissioners; employers commissioning workforce mapping; parents/carers and professional contacts.
AI and matching	AI and software may help read forms, classify information, suggest matches, analyse cohorts and draft pathways or documents. Important actions are subject to human review. We do not use AI as an uncontrolled decision-maker about a person's future.
Direct contact	Seekers and Businesses do not receive each other's direct contact details by default. A potential match is normally reviewed and introduced through The NEET Agent.
Children	Additional protections apply to under-18s, including age-appropriate information, high-privacy defaults, data minimisation and safeguarding controls.
Selling data	We do not sell participant personal information.
Your rights	You may have rights to access, correct, erase, restrict or object to use of your information, and safeguards relating to automated decisions. Contact us at p3kay@daespculture.com.

For Younger Users You can ask what information we hold about you, ask us to correct something that is wrong, and ask questions about who can see your information. Being under 18 does not remove your own privacy rights. If something makes you feel unsafe, tell a trusted adult or contact us. In an emergency, call 999.

1. Who we are	17. Workforce Opportunity Mapping
2. What this Privacy Policy covers	18. Self-commissioning, agreements and Work Passport records
3. Legal and regulatory framework	19. Public statistics and Opportunity Gap intelligence
4. Who this applies to	20. Photography, video, audio and testimonials
5. How The NEET Agent may work	21. Communications and marketing
6. What personal information we may collect	22. Cookies, analytics and website logs
7. Where information comes from	23. Who we may share information with
8. Why we use personal information	24. International transfers and overseas access
9. Our lawful bases	25. Security
10. Special-category, criminal-offence and safeguarding information	26. How long we keep information
11. Children and young people	27. Your data-protection rights
12. Online accounts and privacy by default	28. Children exercising privacy rights
13. Automatic matching, profiling and AI	29. Complaints
14. Paper forms, photographs and AI document ingestion	30. Personal-data breaches
15. Controlled introductions and contact details	31. Changes to this policy
16. Commissioners, cohorts and reporting	32. Contact us

1. Who we are

MO SSC LTD (company number 13711111) operates The NEET Agent and trades as DAESP Culture / DAESP ABC / The NEET Agent. Our registered office is 235 Frances Street, London, England, SE18 5LA.

For our own Opportunity Mapping, employer engagement, website and programme activities, we will usually act as a data controller because we decide why and how personal information is used. For some commissioned work, a school, council, college, employer or other organisation may remain the controller and we may act only on its documented instructions as a data processor. In genuine joint projects, controller responsibilities may be shared and documented.

Mueez Oladejo is the current Data Protection Lead. Privacy and data-rights enquiries can be sent to p3kay@daespculture.com. We do not describe ourselves as having a separate Data Protection Officer office where no such office exists.

2. What this Privacy Policy covers

This notice explains how personal information is handled when people use The NEET Agent website, complete Opportunity Mapping, create an account, submit or explore Opportunities, take part in a Meet First or progression activity, use commissioner or workforce features, upload documents, communicate with us, or take part in related commissioned services.

It also covers information received through paper forms, field outreach, schools, colleges, Jobcentre-linked services, community organisations, Businesses, commissioners and other authorised referral routes. The separate P3kay and Daesp application may form part of the wider business ecosystem, but an account on that application is not automatically required for basic Opportunity Mapping.

3. Legal and regulatory framework

We design our privacy arrangements with regard to the UK data-protection framework that applies to the activity concerned, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025, the Privacy and Electronic Communications Regulations 2003 (PECR), the ICO Age Appropriate Design Code / Children's Code where relevant, and applicable safeguarding and contractual information-sharing duties.

This list is not intended to replace the legislation. Where law or ICO guidance changes, we review our notices, forms, contracts, systems, AI use and operating procedures.

4. Who this applies to

Seekers and prospective Seekers, including school-age participants, people who are NEET or at risk of becoming NEET, people in education or training, graduates, employed people seeking a different opportunity, career changers and adults seeking progression.
Parents, carers and authorised adults where relevant.
Businesses, employers, sole traders and other Opportunity Providers.
Staff and representatives of schools, colleges, councils, Jobcentre-linked services, community organisations, charities, training providers, commissioners and funders.
Employees participating in Workforce Opportunity Mapping.
Suppliers, contractors and professional advisers whose business contact information is processed.

5. How The NEET Agent may work

We may work directly with a person, or we may undertake bulk, cohort or desk-based Opportunity Mapping without meeting every individual. Where the purpose can be achieved with anonymous, aggregated or pseudonymised information, we prefer not to receive unnecessary identifiers.

Direct participant contact remains possible where it is requested, authorised, useful for delivery, necessary for an opportunity, or required for safeguarding or welfare. Opportunity Mapping is not restricted to people who currently meet a statistical definition of NEET.

6. What personal information we may collect

6.1 Seeker and participant information

name or preferred name where required; age, date of birth or age band where relevant;
contact details and preferred contact route, including phone, text/WhatsApp, email or contact through a supporting organisation;
broad location, postcode, travel area and availability;
current stage, for example school/college, training, university/graduate, looking for work, employed and seeking a change, or another situation;
Passion & Purpose-Led Opportunity Mapping information, including ranked interests, ambitions, goals, sectors and types of Opportunity sought;
skills, experience, qualifications or portfolio/CV information where relevant;
support or barrier information where genuinely relevant, which may include Equipment, Knowledge or Lifestyle support needs;
matches, introductions, Meet First appointments, attendance, experiences, referrals, progression, outcomes and follow-up information;
agreement, Work Passport, development, training or evidence records where the user chooses or the programme requires them.

6.2 Business and Opportunity Provider information

organisation name, sector, location, public business information and named work contacts;
work email/telephone and preferred contact method/time;
Opportunities offered, including role/skill area, suitability, availability, conditions, requirements and status;
verification information, communications, contact history, follow-up and outcome information;
support or funding interests relevant to the Business.

6.3 Commissioner, school and professional information

name, role, organisation, work contact details, referral or commissioning instructions, meeting notes, contract information and reporting requirements;
cohort identifiers, batch/source information and authorised outcome reporting.

6.4 Technical and account information

account identifiers, login/security records, role and permissions, acceptance of Terms/Privacy versions and audit events;
device/browser information, security logs, IP address and similar technical records where generated by the website or security services;
cookie and consent choices where applicable.

7. Where information comes from

Information may come directly from the person concerned, from a parent/carer, school, college, commissioner, Jobcentre-linked service, youth/community organisation, Business, employer, training provider, referral organisation, paper form, programme communication, approved digital system, public business source or safeguarding authority.

Where personal information is obtained from another source, we consider whether privacy information needs to be provided directly to the individual and who is responsible for doing so. In commissioned cohort work, this responsibility should be agreed with the commissioner.

8. Why we use personal information

to understand a person's interests, purpose, goals, location, availability and progression preferences;
to perform Opportunity Mapping and identify sectors, pathways, Businesses, training, support and other possibilities;
to create, classify, verify and manage Opportunities;
to suggest potential matches and support authorised introductions or Meet Firsts;
to manage cohorts, referrals, commissioner delivery and outcome reporting;
to identify Opportunity Gaps and improve local opportunity supply;
to support Workforce Opportunity Mapping, internal progression or development programmes where commissioned;
to provide self-commissioned or other separately agreed progression services;
to operate accounts, communications, security, audit trails and service administration;
to safeguard children, young people and adults at risk;
to comply with legal, regulatory, insurance, accounting, contractual and dispute-resolution obligations;
to improve the service using appropriately minimised or anonymised information where possible.

9. Our lawful bases

The lawful basis depends on the activity. We do not rely on consent for everything simply because a person has agreed to participate.

Topic	What this means
Contract / steps before contract	Where processing is necessary to provide a service requested by an adult participant, Business, commissioner or client, or to take steps before entering an agreement.
Legal obligation	Where we must use or retain information to comply with a legal duty.
Legitimate interests	May apply to proportionate employer/business engagement, service administration, security, opportunity research and programme management after considering the person's rights and reasonable expectations. Children's interests receive particular weight.
Vital interests	Where necessary in an emergency to protect somebody's life.
Consent	Used where a real, informed and freely given choice is appropriate, particularly optional media/publicity, certain marketing or optional processing. Consent can be withdrawn where it is the basis used.
Public task / commissioner basis	We do not automatically claim public task because a public authority is involved. A public-sector commissioner may rely on its own public task while we process information on its documented instructions.

10. Special-category, criminal-offence and safeguarding information

Ordinary Opportunity Mapping is not designed to collect extensive health, ethnicity, religion, sexual orientation, biometric, criminal-history or other highly sensitive information. We should not ask for it merely because it may be interesting.

If sensitive information becomes genuinely necessary - for example for accessibility, safe participation, safeguarding, eligibility or a commissioned requirement - an appropriate Article 6 basis and any additional Article 9 or Data Protection Act 2018 condition must be identified. Criminal-offence information receives the additional protection required by law.

Safeguarding records are handled separately from ordinary Opportunity Mapping information, with restricted access and retention based on safeguarding, legal and commissioner requirements. Data-protection law will not be used as an excuse to withhold information that is genuinely necessary and lawful to share to protect somebody.

11. Children and young people

The NEET Agent may work with people from approximately Year 8 upward. For privacy purposes, additional care applies to under-18s even though different legal age thresholds may apply to particular activities.

When the website or digital service is likely to be accessed by children, we aim to use concise and age-appropriate explanations, high-privacy defaults, data minimisation, purposeful sharing, and design choices that take the child's best interests into account.

Where an online service is offered directly to a child and consent is the lawful basis, a child aged 13 or over may generally provide their own consent under UK GDPR rules. If the child is under 13, verified parental responsibility consent is required for that consent-based processing unless a lawful exception applies. Consent is not automatically the correct basis for core programme delivery.

Parents do not automatically own a child's personal information. The child's competence, best interests, confidentiality and safeguarding needs are considered when a parent or carer seeks access or makes a request.

12. Online accounts and privacy by default

An account should only collect the information needed for the functions being used. Bulk or initial Opportunity Mapping does not have to create a full participant account where the purpose can be achieved another way.

Under-18 accounts should not expose profiles, locations or direct contact details publicly by default. Role-based access and least-privilege principles should be used for administrators, commissioners and future staff. Shared logins should be avoided.

Account acceptance records may include the version of the Terms and Privacy Policy accepted, date/time, user/account reference and related audit information.

13. Automatic matching, profiling and AI

The platform may use rules, scoring, software and artificial intelligence to analyse Opportunity Mapping information and suggest potentially relevant Opportunities or Seekers. This is a form of profiling where personal information is used to assess interests, preferences, suitability or likely relevance.

Potential matching factors may include ranked passions/interests, purpose, sector, Opportunity type, geography, travel preference, availability, eligibility, skills, experience, age-related requirements and Business requirements. A match score is a suggestion, not a final acceptance or rejection.

AI may also support form reading, document extraction, classification, cohort analysis, Opportunity Gap analysis, pathway planning, drafting, administration and reporting. AI outputs can be incomplete or wrong and must be subject to proportionate human checking.

The NEET Agent does not intend to make a legal or similarly significant decision about a person solely by automated processing without the safeguards required by current law. Where solely automated significant decision-making is introduced, appropriate information, a route to make representations, and meaningful human intervention/challenge will be provided as required.

For children, profiling will only be used where it is appropriate to the service and consistent with the child's best interests and applicable Children's Code requirements. A DPIA will be considered where profiling or AI creates a high risk.

Human Review If you think a match, classification or AI-extracted field is wrong, contact us. Opportunity Mapping should be capable of changing as your goals change; it is not a permanent personality label.

14. Paper forms, photographs and AI document ingestion

Paper Opportunity Mapping forms remain personal information from the moment they are completed. They should be transported and stored securely, digitised into approved systems where appropriate, checked for readability and completeness, and securely destroyed when the working original is no longer needed unless a legal, safeguarding or commissioner reason requires retention.

Images or PDFs of forms may be processed using approved AI/document-understanding services to detect individual forms, read checkboxes, printed text or legible handwriting, classify fields and create structured records. Low-confidence or ambiguous fields should be routed for human review before the record is approved.

Unreviewed extraction should not automatically be treated as verified evidence for public live statistics. Where practical, routine paper working copies are normally destroyed within 30 days after a verified digital transfer unless there is a justified reason to retain them longer.

Identifiable participant or child information should not be entered into unapproved public/consumer AI tools by default. Where an AI supplier processes identifiable programme data, supplier terms, security, data-processing arrangements, international transfers, model-training settings and DPIA requirements must be assessed.

15. Controlled introductions and contact details

The platform is designed so that a potential match does not automatically expose one side's direct contact details to the other. Seekers normally do not receive a Business's private phone number, email, named staff contact or exact private location at the browsing/matching stage, and Businesses do not automatically receive a Seeker's personal contact details.

A typical flow is Potential Match -> The NEET Agent review -> appropriate confirmation -> authorised introduction or Meet First -> release of the information genuinely needed for that stage.

Only the minimum information reasonably necessary for the specific Opportunity should normally be shared. An employer does not automatically receive a person's full Opportunity Mapping history. Where employment-agency legislation requires particular hirer or assignment information to be provided at the appropriate work-finding stage, we will provide that information as required rather than using privacy controls to withhold legally required information.

16. Commissioners, cohorts and reporting

Schools, colleges, councils, Jobcentre-linked services, charities, community organisations, employers and other commissioners may commission or support Opportunity Mapping. Depending on the arrangement, the commissioner may be controller and we may be processor, or we may each have separate or joint responsibilities.

Commissioner dashboards and reports should use aggregated, anonymised or pseudonymised information wherever that meets the purpose. Individual-level access is limited to what is authorised, necessary and lawful. A commissioner does not automatically receive unrestricted access to every participant record.

For bulk Opportunity Mapping, the first question should be whether the work can be completed from a cohort brief without names. Where identifiable datasets are needed, role allocation, security, sharing, retention and end-of-contract return/deletion should be documented.

17. Workforce Opportunity Mapping

An employer may commission The NEET Agent to map the passions, goals, underused skills, development needs and internal opportunity interests of existing staff. This can produce aggregate workforce intelligence and, where appropriate, individual development pathways.

Employees should be told what information is being collected, why, who will see individual answers and what will be reported only in aggregate. Individual information is not automatically disclosed to managers merely because the employer paid for the programme. Any use of Workforce Opportunity Mapping for employment decisions must have an appropriate lawful basis, transparency and fair process.

18. Self-commissioning, agreements and Work Passport records

A person may choose to Become Their Own Commissioner and ask The NEET Agent to support a longer progression journey. Information used for this may include goals, pathway plans, agreed services, milestones, evidence and review history.

Creating an account or selecting self-commissioning does not by itself create an automatic fee. If a separately chargeable service is offered, the commercial terms and privacy information for that service will be provided before it begins.

The platform may allow users to create, upload or store employment contracts, development agreements, training evidence, Work Passport records, external agreements and progression evidence. We process such documents to provide the requested record, review, planning or AI-assisted service and apply additional care where documents contain third-party or sensitive information.

19. Public statistics and Opportunity Gap intelligence

The platform may publish live or regularly updated figures such as mapped Seekers, participating Businesses, verified live Opportunities, Meet Firsts, experiences and progression. Public figures should be generated from defined, approved statuses rather than unverified leads.

We may also analyse mapped demand against Opportunity supply by sector, geography, cohort or other categories. Public or commissioner-facing Gap data should be aggregated or otherwise protected so that individuals are not unnecessarily identifiable. Very small groups may be suppressed, combined or described more broadly where needed to reduce re-identification risk.

20. Photography, video, audio and testimonials

Optional media/publicity is separate from ordinary Opportunity Mapping. Participation should not depend on agreeing to be photographed, filmed or used in promotional content unless a specific commissioned activity genuinely requires recording for a stated purpose.

Where consent is the lawful basis, people should be given genuine choices about what may be captured and how it may be used. For identifiable promotional media involving an under-18, appropriate young-person agreement and adult/commissioner confirmation may be required. A school's general photo permission is not automatically treated as permission for a new The NEET Agent publication purpose.

Public-use media should be periodically reviewed, normally at least every 24 months, to confirm that continuing use remains appropriate. A minimal record of permission and later withdrawal may be retained to prevent accidental reuse.

21. Communications and marketing

Service messages about Opportunity Mapping, an account, safeguarding, a requested Opportunity, an introduction or programme administration are different from optional promotional marketing.

Electronic marketing is handled in line with PECR and data-protection rules. Under-18 participants are not added to promotional marketing lists simply because they took part in Opportunity Mapping. Business-to-business employer engagement may use proportionate work contact details and provide a practical route to object or opt out where required.

Where a person opts out of marketing, a minimal suppression record may be kept so that the opt-out is not accidentally reversed.

22. Cookies, analytics and website logs

The website may use cookies or similar technologies that are strictly necessary for security, account login, session management, preferences and core functionality. These may operate without optional marketing consent where law permits.

Optional analytics, advertising or similar non-essential technologies should only be enabled in accordance with applicable consent requirements. Where such tools are used, the website should provide a cookie/settings mechanism explaining the categories and choices available.

Technical logs may be retained where reasonably necessary for security, fraud prevention, diagnostics and service reliability. We do not use technical logs as an excuse to build unnecessary behavioural profiles.

23. Who we may share information with

schools, colleges and commissioners for agreed delivery, reporting, safeguarding and authorised referral purposes;
parents/carers where appropriate and lawful;
Businesses and Opportunity Providers, limited to information needed for an authorised Opportunity or introduction;
training, support or referral organisations where the referral is authorised or otherwise lawful;
safeguarding bodies, children's or adult social care, LADO, police, emergency services or other statutory bodies where necessary and lawful;
approved website hosting, authentication, cloud storage, communications, analytics, AI/document-processing and other technology suppliers acting under appropriate terms;
insurers, accountants, auditors, legal advisers and other professional advisers where reasonably necessary;
regulators, courts or public authorities where disclosure is required or lawfully necessary.

We do not sell participant personal information. Sharing is based on a defined purpose and the minimum information reasonably necessary for that purpose.

24. International transfers and overseas access

Some approved technology suppliers, sub-processors or authorised contractors may access or process information outside the UK. We do not assume that an international transfer is lawful merely because a supplier is well known.

Where UK personal information is transferred to a country without an applicable UK adequacy regulation, we will use an appropriate transfer mechanism and any additional safeguards required by law, such as an approved UK transfer agreement/addendum and a transfer-risk assessment where appropriate.

Overseas developers or contractors are not automatically permitted to browse live participant data. Access should be role-based, limited to what is needed, governed by confidentiality and data-processing terms, and preferably use test or de-identified data where live identity is unnecessary. If a material supplier or transfer changes the risk or information people need, this notice and just-in-time information should be updated.

25. Security

We use proportionate technical and organisational measures based on the sensitivity, volume and risk of the information. These include appropriate access controls, unique credentials, multi-factor authentication for core business systems, secure business devices, encryption where available, secure sharing, restricted safeguarding records, controlled paper handling, updates, backups, access removal and incident logging.

No security measure can guarantee that an online system will never experience an incident. We therefore also maintain breach-response and recovery procedures.

26. How long we keep information

We do not apply one arbitrary retention period to every record. Retention depends on the purpose, active Opportunity Mapping, safeguarding, commissioner requirements, audit, legal obligations, complaints and legal claims. Identifiable information is not kept indefinitely without a continuing reason.

Record type	Current default	Review / action
General enquiry / lead	Review around 12 months after the last meaningful interaction.	Delete or anonymise unless a continuing purpose, opt-out, complaint, safeguarding or legal reason remains.
Active Opportunity Mapping record	Retain while there is a genuine continuing Opportunity Mapping, pathway, follow-up, reporting or safeguarding purpose.	Review at least annually; remove obsolete data and anonymise identity where possible.
Closed / inactive participant record	Case-by-case once no current service purpose remains.	Retain only the minimum needed for safeguarding, audit, claims or evidenced outcomes; prefer aggregate longitudinal data.
Business contact	While relevant to the active Opportunity network.	Review at least every 24 months; update, suppress or delete obsolete named contacts.
Media / consent	For the stated purpose while ongoing use remains justified.	Review public use at least every 24 months; stop future consent-based use after valid withdrawal where required.
Contracts / invoices / financial	Normally at least 6 years where required for company, tax, accounting or legal purposes.	Do not retain unnecessary participant data merely because a financial record must be kept.
Privacy rights / complaints	Normally up to 3 years after closure unless dispute, claim or law justifies longer.	Keep enough to evidence handling and outcome; minimise underlying copies.
Paper working copies	Only until verified transfer where no other reason exists.	Where practical, securely destroy routine working originals within about 30 days after verified digitisation.

27. Your data-protection rights

Depending on the circumstances and lawful basis, you may have rights to be informed, obtain access, correct inaccurate information, request erasure, restrict processing, object, receive data portability in applicable circumstances, withdraw consent where consent is relied on, and receive safeguards in relation to automated decision-making.

You do not need to use legal language to make a request. Contact p3kay@daespculture.com. We may ask for proportionate information to verify identity. Subject access requests are normally handled within one month; the period may be extended where the law allows because of complexity or the number of requests.

Not every right applies in every situation. Safeguarding, legal duties, another person's rights, legal claims and applicable exemptions may affect what can be erased or disclosed.

Your Right to Object Where we rely on legitimate interests, you may have a right to object to that processing. Tell us what you object to and why. We will consider the circumstances and respond in accordance with data-protection law.

28. Children exercising privacy rights

Children can have privacy rights in their own right. We consider the child's age, understanding, best interests, confidentiality and the particular request. A parent/carer request is not automatically treated as a request on behalf of the child without considering authority and safeguarding.

Where a school or commissioner is the controller and we act as processor, a request may need to be routed to or coordinated with that controller.

29. Complaints

If you are unhappy with how we use personal information, contact the Data Protection Lead at p3kay@daespculture.com. We provide an electronic route for privacy complaints. In line with current Data (Use and Access) Act complaint requirements, we aim to acknowledge a data-protection complaint within 30 days and investigate and respond without undue delay.

You also have the right to complain to the Information Commissioner's Office (ICO). Information about making a complaint is available at ico.org.uk. We will not prevent or discourage a person from approaching the ICO.

30. Personal-data breaches

A personal-data breach may include loss, accidental destruction, hacking, unauthorised access, information sent to the wrong person, a lost device or lost paper forms. We will contain and record incidents, assess risk, notify the relevant commissioner/controller where required, and notify the ICO and affected people where the legal thresholds are met.

Where we are the controller and a breach is reportable to the ICO, notification will be made without undue delay and, where feasible, within 72 hours of awareness.

31. Changes to this policy

We review this policy when the service, law, systems, processors, AI use, child access, international transfers or commissioning model changes materially. The version and effective date appear at the start of the document.

Where a change materially affects existing personal information, we will take reasonable steps to bring the new information to affected users before or when the new processing starts, as required.

32. Contact us

MO SSC LTD trading as DAESP Culture / DAESP ABC / The NEET Agent

Company number: 13711111

Registered office: 235 Frances Street, London, England, SE18 5LA

Data Protection Lead: Mueez Oladejo

Privacy / data-rights email: p3kay@daespculture.com

Telephone: 07492 505008

MO SSC LTD has completed the applicable ICO data-protection registration arrangements. Confidential regulator account/security credentials are not published in this public notice.

The NEET Agent Privacy Principle Use what is necessary. Protect what is entrusted to us. Share only for a proper purpose. Keep people at the centre of the opportunity.