In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our clients/candidates, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to current and former clients, candidates & learners.
A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
We keep several categories of personal data on our clients/candidates & learners in order to carry out effective and efficient processes. We keep this data within our computer systems, for example, our Booking/CRM System.
Specifically, we hold the following types of data:
a) personal details such as name, address, phone numbers
b) name and contact details of your candidates/leaners
c) photographs of learners/candidates
d) gender, marital status, information of any disability you have or other medical information
e) booking history
f) information on your race and religion for equality monitoring purposes
C) COLLECTING YOUR DATA
You provide several pieces of data to us directly during the booking process and subsequently upon the start of your course.
In some cases, we will collect data about you from third parties, such as Awarding Bodies, trade references or credit reference agencies.
Data is kept in files or within the Company’s IT systems.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the training contract we have with you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
Activity requiring your data:
Carry out the training contract that we have entered into with you e.g. using your name, contact details, address etc.
Carrying out checks in relation to your right to work in the UK
Our legitimate interests
Ensuring efficient administration of contractual benefits to you
Assessing training needs
Ensuring our administrative and IT systems are secure and robust against unauthorised access
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
d) ethnic origin
We carry out processing activities using special category data:
a) for the purposes of equal opportunities monitoring
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil your requirements of delivering training/testing with you. This could result in us cancelling the booking.
G) CRIMINAL CONVICTION DATA
We will only collect criminal conviction data where it is appropriate
H) WHO WE SHARE YOUR DATA WITH
Employees within our company who have responsibility for booking, administration of payment and contractual benefits and the carrying out training related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reasons:
a)Processing with Awarding Organisations
c)Our IT Department
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We share your data with bodies outside of the European Economic Area. That country is America and the reason for sharing with this country is this is where our main Marketing company is based (MailChimp). We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws:
Mailchimp is also covered by the GDPR policy and that can be viewed here:
I) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
J) RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:
CPCS – 6 Years
City & Guilds – 3 Years
SWQR – 3 Years
NOCN – 3 Years
NPORS – 7 Years
SQA – 3 Years
K) YOUR RIGHTS
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
M) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
N) DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is:
Cheryl Loak - Director
0330 053 8283