Privacy policy.
LPrivacy Notice for Learners/applicants Applicants
Approved: Jan 2024
Review date: As required
This privacy notice describes how we collect and use personal information about learners/applicants, in accordance with the UK General Data Protection Regulation (UK GDPR).
Following Brexit, Regulation (EU) 2016/679, General Data Protection Regulation (GDPR) is retained EU law and known as UK GDPR. The UK GDPR sits alongside an amended version of the Data Protection Act 2018 that relate to general personal data processing, powers of the Information Commissioner and sanctions and enforcement. The GDPR as it continues to apply in the EU is known as EU GDPR.
Who Collects This Information
GreyCircle is a “data controller.” This means that we are responsible for deciding how we hold and use personal information about learners/applicants.
We may collect, store and use the following categories of personal information about you:
Categories of Learners/applicants Information We Collect, Process, Hold and Share
• Personal information such as name, ILM centre number, date of birth, gender and contact information;
• Emergency contact and family lifestyle information such as names, relationship, phone numbers and email addresses;
• Characteristics (such as ethnicity, language, nationality, country of birth)
• Attendance details (such as sessions attended, number of absences and reasons for absence);
• Performance and assessment information;
• Relevant medical information;
• Images of learners/applicants engaging in activities;
• Information about the use of our IT, communications and other systems, and other monitoring information.
Collecting this Information
Whilst the majority of information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the UK General Data Protection Regulation, we will inform you whether you are required to provide certain information to us or if you have a choice in this.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
How We Use Your Personal Information
We hold learner data and use it for:
• Enrolment (and to confirm the identity of prospective learners/applicants);
• Providing services and access arrangements;
• Support delivery of the course;
• Managing internal policy and procedure;
• Enabling learners/applicants to take part in assessments, to publish the results of examinations;
• To carry out statistical analysis for diversity purposes;
• Legal and regulatory purposes (for example diversity monitoring and health and safety) and to comply with legal obligations and duties of care;
• Making use of photographic images of learners/applicants in publications, on the website and on social media channels, and
• Security purposes
The Lawful Bases on which we use this Information
We will only use your information when the law allows us to. Most commonly, we will use your information in the following circumstances:
• Consent: the individual has given clear consent to process their personal data for a specific purpose;
• Contract: the processing is necessary for a contract with the individual;
• Legal obligation: the processing is necessary to comply with the law (not including contractual obligations);
• Vital interests: the processing is necessary to protect someone’s life, and
• Public task: the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
We need all the categories of information in the list above primarily to allow us to comply with legal obligations. Please note that we may process information without knowledge or consent, where this is required or permitted by law.
Sharing Data
We may need to share your data with third parties where it is necessary. There are strict controls on who can see your information. We will not share your data if you have advised us that you do not want it shared unless it’s the only way we can make sure you stay safe and healthy or we are legally required to do so.
The recipient of the information will be bound by confidentiality obligations, we require them to respect the security of your data and to treat it in accordance with the law.
We do not share information about our learners/applicants with anyone without consent unless otherwise required by law.
Storing Learner Data
The centre keep information about learners/applicants on computer systems and sometimes on paper.
Except as required by law, the centre only retains information about learners/applicants for as long as necessary in accordance with timeframes imposed by law and our internal policy.
Retention Periods
Except as otherwise permitted or required by applicable law or regulation, the centre only retains personal data for as long as necessary to fulfil the purposes they collected it for, as required to satisfy any legal, accounting or reporting obligations, or as necessary to resolve disputes.
Security
We have put in place measures to protect the security of your information (i.e. against it being accidentally lost, used or accessed in an unauthorised way).
Requesting Access to your Personal Data
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you want to request information, please see our Subject Access Request policy, for the procedures we take.
To make a request for your personal information contact Nick Taylor.
Right to Withdraw Consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Becky Heaton. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Contact
If you would like to discuss anything within this privacy notice or have a concern about the way we are collecting or using your personal data, we request that you raise your concern with Nick Taylor in the first instance.
We have appointed a data protection officer (DPO) to oversee compliance with data protection and this privacy notice. If you have any questions about how we handle your personal information which cannot be resolved by Nick Taylor, then you can contact the DPO on the details below:
Data Protection Officer: Becky Heaton
Email: becky@educoach.uk
You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues at https://ico.org.uk/concerns.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.