The following Privacy Notice is to let you know how we promise to look after your personal data, your privacy rights, and how the law protects you. We hope that the information is clear and easy to understand, however, if this is not the case, or you require any further clarity, please contact our Data Protection Officer David Armstrong on 0191 490 4648 or email firstname.lastname@example.org.
Our Privacy Promise to you:
- To keep your data safe and private
- To never sell your data
- To give you ways to manage and review the data which we hold
How the law protects you
As well as our privacy promise to you, your privacy is protected by law. The law itself is currently under review.
The Data Protection Act 1998 (DPA) governs all organisations who hold personal data on individuals. On 25 May 2018 the General Data Protection Regulation (GDPR) comes into force. Our interpretation of this regulation is that the GDPR takes many of the core principles of the DPA, and modernises them in view of the shift in digital technologies and digital communication/storage. The GDPR aims to hold organisations more accountable for the protection of your personal data, and provide you with more rights as to how this is collected, used, retained and destroyed.
The law says that we are allowed to collect and use your personal data only if we have a reason to do so:
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it
In terms of the information we hold for you as a training provider, this is no different to that held for example by a school or college.
WHY WE HOLD PERSONAL DATA
We hold personal data on learners and employers for the following reasons:
- Information we are required to collect by law or to claim funding.
- Information we need to deliver your chosen course of study and monitor progress.
- Additional information that will allow us to personalise our support to meet your individual needs.
- Information we use for marketing, communications and advice. At no time will your personal data be passed to other organisations for marketing or sales purposes. Your employer may be contacted by Access’ Business Solutions team.
- Information we gather to provide facilities and to ensure security (such as CCTV video).
The personal data we hold includes:
- Personal information (such as name, date of birth, national insurance number, address, emergency contact information).
- Special categories of data including characteristics information such as gender, age, ethnic group.
- Progression information (such as units in progression/achieved, examination results, individual learning plans, records of discussion, support requirements).
- Employment information (such as business name, contact, job description, start date, salary).
- Financial information (information such as bank details, payment records, tax records).
The following is a list (not exhaustive) of the ways that we may use or are required to share your personal information:
|What we use your personal information for||Our Reasons||Our Legitimate Interests||Stakeholder|
|To return your information to the Education and Skills Funding Agency (ESFA)||Our Legal Duty||We must report your progress to the Agency each month to receive funding
|To check your prior learning||Our Legal Duty||We must obtain your Unique Learner Number from the Learner Record Service, this also provides a history of your past study
|To register you with the relevant Awarding Body and supply evidence of learning/ competencies||Our Legal Duty||We must register you with the correct Awarding Body, after completing your Apprenticeship they will then issue your certificate
|To report progress to your employer||Fulfilling Contracts
Our Legitimate Interest
|Your employer requires regular progress reports on your off the job training
|To return your information to the Education and Skills Funding Agency (ESFA)||Our Legal Duty||1) Funding agencies require evidence that your Apprentice is employed in a suitable position
2) To obtain your employer incentive payment
|To let you know of potential new opportunities||Our Legitimate Interest||We may from time to time contact you to ascertain if you have any further requirements for training/development
|To gather your views about us as a training provider||Our Legitimate Interest||We may from time to time contact learners and employers to ask how well we are doing and improve our services
|To profile our performance as a provider, for example the success of learners studying in a particular sector, or the difference between the success of male and female learners||Our Legitimate Interest||We may group your information and carry out analysis as part of our quality assurance process
This is carried out with the intent of identifying any areas we are performing less well, and introduce improvements
Where we collect personal information from
We initially collect information on you at the point in which you engage with Access Training. For learners this would be during the application process, and for employers this would be in the early stages of expressing an interest in recruiting an apprentice.
We may also collect personal information:
- In emails and letters
- During telephone conversations
- During 1-1 meetings with your Trainer/business contact
- When you visit our website
- Through surveys
- Through third parties:
- Awarding Bodies
- Government Agencies and Departments
- Public information sources, for example Companies House
- Market Researchers
We will hold your information securely.
To prevent unauthorised disclosure or access to your information, we have implemented strong organisational and technical security safeguards.
If information is shared with another organisation (possible reasons for this are given in the section below) we will ensure an Information Sharing Agreement is in place.
Who we share your personal information with
Access training will never sell your data. Access will only ever share your data with the required organisations to fulfil our legal duties as a training provider.
A list of those agencies/organisations that we currently share limited information is shown below:
- The Education & Skills Funding Agency (ESFA): https://www.gov.uk/government/organisations/education-and-skills-funding-agency
- The National Apprenticeship Service: https://www.gov.uk/apply-apprenticeship
- The Learner Records Service: https://idp.lrs.education.gov.uk/
- One Awards: oneawards.org.uk
- NOCN: nocn.org.uk
- OCR: ocr.org.uk
- City & Guilds: https://www.cityandguilds.com
- NCFE: https://www.ncfe.org.uk
- AAT: https://www.aat.org.uk
- CMI: https://www.managers.org.uk/education-providers
- EAL: http://eal.org.uk
- Ofsted: https://www.gov.uk/government/organisations/ofsted
- Local Authorities
Sending data outside of EEA
The General Data Protection Regulation is a European regulation and as such only offers protection to your data within the European Economic Area (EEA). Access Training does not need to send your data outside of the EEA as part of its day to day business as a training provider. In view of this we have taken the decision to only release data to you, on your request, and not at the request of another organisation outside of the EEA.
If you choose not to give us personal information
We may need to collect personal information by law, or under the terms of our legal obligation as a training provider. If you choose not to give us this personal information, it may prevent us from meeting our obligations. This may result in us being unable to continue as your training provider.
If you have any concerns about the personal information we are asking you to share with us, or have any concerns regarding our intent, please contact our Data Protection Officer, David Armstrong on 0191 490 4648 or email@example.com.
Access Training will only share your personal data with bodies or organisations who fully comply with the GDPR framework. Any data collection that is optional would be made clear at the point of collection.
We may use your personal information to tell you about relevant opportunities, this is what we mean by ‘Marketing’. For learners this may be a vacancy with an employer that may be suitable, or for the opportunity to progress to higher or additional qualifications. For employers this may be to survey your training needs, or to match suitable candidates or training programmes to your business.
The personal information we have is made up of what you tell us, the data we may have collected, or from third parties we work with. We study this to form a view of what we think you may want or need, or what may be of interest to you.
We can only use your personal information to contact you if we have either your consent, or a ‘legitimate interest’. This is when we have a business reason to do so, and it must not go against what is right and best for you.
You can ask us to stop contacting or update your choices at any time by contacting us.
Visitors to our website
When you visit www.accesstraining.org we collect standard internet log information and visitor details of behaviour patterns. We do this to find out such things as the number of visitors to different parts of the site. We collect the information in a way which does not identify anyone. If we want to collect personally identifiable information through our website we will be upfront about this and will make the purpose clear (eg. to apply for vacancies online or to make an enquiry).
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. These also enable us to see information like how many people use the website and what pages they tend to visit. Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us. You can choose to change your browser settings if you do not want us to store cookies on your computer. Please be aware that cookies may be required to complete certain functions on our website.
Links from our Website
How long we keep your personal information
We will keep your personal information as long as you are engaged with Access Training as a learner or employer.
After you stop being a learner or employer, we may keep your personal information for up to 10 years for one of these reasons:
- To respond to any questions or complaints
- To show that we treated you fairly
- To retain records according to the rules that apply to us.
Access Training is primarily funded through public funds, and as such we are required to keep data for a variety of legal, regulatory or technical reasons. In some cases, records must be maintained for auditory purposes by funding bodies. We will make sure that your privacy is protected and only use it for those purposes.
How to get a copy of your personal INFORMATION
You can access your personal information we hold by writing to us at this address:
FAO David Armstrong
Access Training Limited
Gateshead Skills Academy
Kingsway South : 8th Avenue
If would like to discuss any general requirements ahead of making a request, please contact our Data Protection Officer, David Armstrong on 0191 490 4648 or firstname.lastname@example.org.
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think may be wrong or incomplete. Please contact us if you want to do this and we will take reasonable steps to check its accuracy and correct where necessary.
What if you want us to stop using your personal information?
You have various rights to object to our use of your personal information, these are officially known as the; ‘right to object’, ‘right to erasure’ and ‘right to be forgotten’.
There may be legal or other regulatory reasons why we need to keep or use your data, but please contact us if you think that we should not be using it.
We may sometimes be able to ‘restrict’ the use of your data. This means that it can only be used for legal or regulatory reasons, but not for other reasons while it is restricted.
If you want to object to how we use your data, or ask us to delete or restrict how we use it, please contact us.
You have the right to ‘change your mind’. We may have collected information at a point in time where you consented to us using it in a certain way, for example to market new opportunities to you. If you have since changed your mind, you can withdraw that consent. Please contact us if you wish to do so.
SENSITIVE PERSONAL DATA
Some of your personal data is deemed to be sensitive, examples of this may include:
- Details of any health problems, disabilities or individual learning needs
- Information around gender reassignment
We would only share sensitive personal data with your express written permission, or if there are special legal reasons (such as a request for information by a court).
How to complain
Please let us know if you are unhappy with how we have used your personal information. Contact our Data Protection Officer, David Armstrong on 0191 490 4648 or email@example.com.
You also have the right to complain to the Information Commissioners Office.
Formats for sharing data
You have the right to obtain your personal information in a format that can easily be re-used. You can also ask us to pass your personal information to other organisations in this format. We are happy to work with you to provide your information in an acceptable format, these may include:
- Large Print or Braille Format
- Text Documents .doc .docx .rtf
- Data Formats .xls .xlsx .csv .dbs .dbsx .html .xml
- Image Formats .pdf .jpeg .gif
Changes to this privacy notice
We will keep this Privacy Notice under regular review and reserve the right to change it as necessary from time-to-time or if required by law. Any changes will be immediately posted on our website.