Privacy Policy

Purpose

The purpose of this document is to set out in detail the types of personal data we may collect about you when you interact with Workforce Skills Support Ltd. It also sets out how we’ll store, handle and keep that data safe.

Scope

This process affects anyone who engages with Workforce Skills Support Ltd.

Policy Objectives

Workforce Skills Support Ltd has a clear data protection and privacy policy as we want to fully inform anyone who engages with us to understand their rights, how we use your data and how we combine with third parties.

The policy has ten sections as follows:

Section 1 – Legal basis

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. These include the following:

• Consent
  In specific situations, we can collect and process your data with your consent, an example of this may be when a box is ticked to receive email newsletters.
• Contractual obligations
  In certain circumstances we need your personal data to comply with our contractual obligations, an example of this is to enable us to register and certify the qualifications that you are enrolled on.
• Legal compliance
  If the law requires us to, we may need to collect and process your data.
• Legitimate interest
  In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedoms or interests. An example of this may be that we use your purchase history to send you or make personalised offers via direct marketing information telling you about products and services that we think may be of interest.

Section 2 – When do we collect your personal data

We collect your personal data in the following ways:

• When you sign up for our enrolled training courses
• When you request information regarding training or assessment
• When you engage with us on social media
• When you visit our website and input your details to sign up for our services
• When you contact us by any means with queries, complaints, etc.
• When you choose to complete any surveys, we may send you
• When you’ve given a third-party permission to share with us the information they hold about you

Section 3 – What sort of personal data do we collect?

The types of personal data we collect are as follows:

• When you enquire about undertaking a training course or qualification with Workforce Skills Support Ltd we may collect your name, company name, contact details (address, phone number, email address), date of birth and national insurance number.
• When we register you with one of the awarding organisations we work with, for registration and certification purposes we collect your name, date of birth, CITB number (if applicable), ethnicity and gender.
• When we undertake the learning and assessment process we collect your name, date of birth, contact details, gender and any disabilities or learning difficulties.
• When we process payments we collect your payment card number, expiry date, security code, bank details, address, name and contact details.
• When we need to verify your identity or eligibility we collect your driving license details, passport details or birth certificate details.
• Information is gathered by the use of cookies in our web browser.
• Any personal details which may help us to recommend items of interest.

Section 4 – How and why do we use your personal data

We use your personal data to deliver the qualifications and training that you have expressed an interest in and supply you with information about the services and qualifications we provide. We want to give you the best possible customer experience. One way of doing this is to use your data to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. You can change how we use your data as is your right and more details are found in section 9 of this policy.

Section 5 – Using your data for personalised direct marketing

We want to bring you offers and promotions that are most relevant to your interests at times. To help us get a better understanding of you as a customer, we combine your personal information gathered from the training and qualifications you have undertaken with us and others, an example of this is when you have previously undertaken a qualification that is recorded on your personal learning record and held by awarding organisations. We may also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass data onto us.

Section 6 – How we protect your personal data

We understand that data security matters to all our customers and with this, in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘HTTPS’ technology which is also encrypted.

Access to your personal data is password protected and sensitive data (such as payment card information) is secured by SSL encryption. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

A notifiable breach will be reported to the relevant supervisory authority within 72 hours of Workforce Skills Support Ltd becoming aware of it, only if it is likely to result in a risk to the rights and freedoms of individuals. If unaddressed, such a breach is likely to have a significant detrimental effect on individuals – for instance, resulting in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage. The UK GDPR recognizes that it will often be impossible to investigate a breach fully within that time period and allows us to provide information in phases. If the breach is sufficiently serious to warrant notification to the public, Workforce Skills Support Ltd will do so without undue delay.

Section 7 – How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, an example of this is aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Section 8 – Who do we share your personal data with?

There are occasions when we are required to share your information with third parties to enable us to deliver the training you have chosen to undertake with us. These include:

• Awarding organisations to register and certificate your qualifications (ProQual, SQA, CITB, NPORS)
• Third-party assessors, trainers and internal quality assurers to deliver the training and qualifications you requested.
• The learner record service (LRS) to obtain your unique learner number (ULN) and access your prior training records.
  o Privacy Notice – The information you supply is used by the Education and Skills Funding Agency, an executive agency of the Department for Education (DFE), to issue you with a unique learner number (ULN) and to create your personal learner record, as part of the functions of the DFE. For more information about how your information is processed, and to access your Personal Learning Record, please refer to this link: LRS Privacy Notice
• Operation companies such as delivery companies to deliver certificates (please note that in order to keep your data safe and protect your privacy with these organisations we only provide the information they need to perform their specific services; they may only use your data for the exact purposes we specify in our contract with them; we will work closely with them to ensure that your privacy is respected and protected at all times and if we stop using their services, any of your data held by them will either be deleted or rendered anonymous).

Section 9 – What are your rights to your personal data

You have the right to request the following:

• Access to the personal data we hold about you.
• The correction of your personal data when incorrect, out of date or incomplete.
• When you withdraw consent or object and we have no legitimate overriding interest, or once the the purpose for which we hold the data has come to an end.
• That we stop using your personal data for direct marketing.
• That we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that Workforce Skills Support Ltd holds at any time and also to have the information corrected if it is inaccurate. To ask for your information, please contact the Data Protection Officer, Workforce Skills Support Ltd, Mansfield Business Centre, Ashfield Avenue, Mansfield, Nottinghamshire. NG18 2AE or email [email protected].

If we chose not to action your request, we will explain to you the reasons for our refusal. Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this data protection and privacy policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels, we must always comply with your request. To stop direct marketing communications from us, you can click the ‘unsubscribe’ link on any email correspondence that we send you or contact the Data Protection Officer (details above)

Section 10 – Contacting the regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioners Office. You can contact them by calling 0303 1231113 or going online to lodge a complaint. (please note we can’t be responsible for the content of external websites).

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

Section 11 – Staff Training

Workforce Skills Support Ltd is committed to training/briefing all staff handling personal data on their data protection responsibilities to provide awareness training on or shortly after an appointment with updates at regular intervals or when required. Specialist training for staff with specific duties, such as information security and database management and marketing will also be considered.

Key considerations are –

• So they know what is expected of them
• To be wary of people who may try to trick them into giving out personal details
• So that they can be prosecuted if they deliberately give out personal details without permission
• To use a strong password – these are long (at least seven characters) and have a combination of upper and lowercase letters, numbers and special keyboard characters like the asterisk or currency symbols
• Not to send offensive emails about other people, their private lives or anything else that could bring Workforce Skills Support Ltd into disrepute
• Not to believe emails that appear to come from your bank that ask for your account, credit card details or your password (a bank would never ask for this information in this way)
• Not to open spam – not even to unsubscribe or ask for no more mailings. Tell them to delete the email and either get spam filters on their computers or use an email provider that offers this service

To request further information on specific associated Awarding Bodies/organisations -Data Protection Policies, please contact – [email protected]

CITB Standards For Fair Processing Of Data

Delegates will be informed of the fair processing procedures of information provided through commercial training delivered by Workforce Skills Support through the joining instructions provided, joining instructions will contain the fair processing statement as detailed below:

FAIR PROCESSING NOTICE

The information you provide to the CITB Approved Training Organisation, {Workforce Skills Support}, will be used for administering Training Courses and for purposes connected with the Construction Industry Training Board’s (“CITB”) role as an Industrial Training Board in accordance with the Industrial Training Act 1982.

Your data will be held securely and treated confidentially and will not be disclosed to external parties other than as required for the purposes described above. This may include sharing your information on the CITB Construction Training Register as well as with employers, awarding organisations, competency card schemes or training providers.

Further information, including your legal rights and how your information may be used, can be found by:

• viewing the CITB Privacy Notice online at citb.co.uk/privacy;
• asking the Approved Training Organisation for information about how they manage your personal data.