The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected whilst in our hands. Please read this notice carefully as it explains how we and/or carefully selected third parties we work with, collect and use your personal information.
Whose Data we hold
to enable our company to carry out the processes required to trade, we hold personal data. Through our secure systems, we may hold data on the following individuals:
• Carefully selected Third Parties
The above list is not exhaustive and may be amended to during the review process.
What information do we collect and where do we get it from?
In order for us to provide our services to you and to manage those services we will ask you to share your personal information with us. The circumstances in which we use your information, the reasons why we ask for it and details of how we will use it are explained in section 3 of this notice. The information we collect about you varies depending on your particular circumstances and requirements and may include, for example:
• General information about the individual/client such as name, address, contact details, and date of birth.
• Financial details, such as bank account details, this can be used to pay employer incentive payments.
We may collect personal information from the following sources:
• The client or someone connected.
If our clients have provided information to us about someone else, we will confirm to them that that they have the consent of these individuals to share their personal information with us.
If you have provided information to us about someone else, you would have confirmed that you have the consent of these individuals to share their personal information with us. You should share this privacy notice with all individuals whose personal information you have shared with us as it may also apply to them.
Why do we collect this information and how will we use it?
We and/or our carefully selected third parties may collect and use personal information under the following circumstances or for the following reasons:
a) Where we have a justifiable reason, such as:
keeping records about the individual/client and our correspondence with them. This also means we can appropriately and effectively manage our relationship with the individual/client as well as satisfy any legal and regulatory obligations.
Preventing and detecting fraud, financial crime and anti-money- laundering.
Share the personal information with fraud prevention agencies. The personal information will be checked with and recorded by a fraud prevention agency.
If false or inaccurate information is provided and fraud is identified, details will be passed to the fraud prevention agency.
b) Where we have been given permission:
To use your sensitive personal information in order to provide you with appropriate information regarding the services you have taken up with us.
Who might we share your information with?
We may share your personal information with:
Other businesses that are providing a service to us or on our behalf which directly involves you.
Organisations that have a specific role laid out in law such as statutory bodies, regulatory authorities and other authorised bodies.
Other organisations where we have a duty to or are permitted to disclose your personal information by law (e.g. if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime).
Fraud prevention agencies and operators of registers available to the education industry to check information and prevent fraud.
Third parties we use to recover money you may owe us or to whom we may sell your debt.
Another company, if our business or part of it is bought or taken over by that company to ensure your training can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over.
Other third parties if you have given us your permission to do so or there is sufficient reason to believe they are acting on your behalf. Unless required by law, we would never share your personal data without the appropriate and necessary care and safeguards being in place.
How long will we keep your information?
We will keep your information only for as long as is reasonably necessary for the purposes set out in this privacy notice and to fulfil our legal and regulatory obligations.
Use and storage of your information overseas
The personal information we and our carefully selected third parties collect from you may be transferred to, stored and processed outside the European Economic Area (EEA). We or our service providers may use cloud based computer systems (i.e. network of remote servers hosted on the internet which process and store your information) to which foreign law enforcement agencies may have the power to require access. We will not transfer your information outside the EEA unless it was to a country our information regulator has assessed as having adequate data protection laws, or we had taken all reasonable steps to ensure the firm has the necessary privacy and security controls in place to protect your information as if it were in the EEA. Our contracts with these firms will detail the necessary requirements to ensure your information is protected. We will assess these firm’s security arrangements from time to time ensuring that they are only using your information as agreed.
All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How will we deal with others acting on your behalf?
To help manage your involvement with the services that we provide we will deal with individuals you nominate, including third parties we reasonably believe to be acting on your behalf provided they are able to prove their association with you. However, for your protection, we will need to speak to you directly, your legal representative, someone you have nominated and given us permission to discuss your personal details.
You have a number of rights concerning the personal information we use, these include the right to:
Ask for access to and a copy of your personal information.
Ask us to correct or delete the personal information.
Ask us to restrict or object to the use of your personal information at any time.
Where you have previously given us your permission to use your personal information, withdraw that permission. Where your permission is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you do not wish us to contact you again.
Complain to the Information Commissioner’s Office at any time if you object to the way we use your personal information. For more information please go to https://www.ico.org.uk
Please note that in some cases even when you make a request concerning your personal information, we may not be required, or may not be able, to honour it as this may result in us not being able to fulfil our legal and regulatory obligations or there is a minimum statutory period of time for which we have to keep you information. If this is the case then we will let you know our reasons.