All activity on www.thetrainingcircle.co.uk (our website) is logged and monitored to help keep personal information secure and to ensure that we comply with our obligations under the Data Protection Act 1998 (the DPA) and the General Data Protection Regulation (the GDPR) from May 2018.
Changes to the policy
- We'll only collect and use your information where we have lawful grounds and legitimate business reasons to do so
- We'll be transparent in our dealings with you and tell you how we’ll collect and use your information
- If we collect your information for a particular purpose we'll only use it for that purpose, unless you’ve been otherwise informed and given your permission where relevant
- We won’t ask for more information than we need for the purposes for which we’re collecting it
- We'll update our records when you tell us that your details have changed
- We'll periodically review your personal information to ensure we don’t keep it for longer than is necessary
- We'll ensure that your information is securely disposed of at the end of the appropriate retention period
- We'll observe your rights under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are dealt with promptly and transparently
- We'll train our staff on their privacy obligations
- We'll ensure we have appropriate physical and technological security measures to protect your information regardless of where it’s held
Information we hold about you and how we’ll use it
We will collect data about you, both personal data (such as your name and contact details) and also special categories of data (such as what you will need to provide to us to verify your identity when taking an exam through our awarding bodies ). The personal data and special categories of data will be stored, processed, used and disclosed by us in the following ways:
- Conduct customer satisfaction surveys
- Verify details you have provided
- Process your data to send you relevant and targeted marketing materials, vacancies, promotions, offers, events or other communications which we think are likely to be of interest to you, where you have consented to be contacted for such purposes. You have the right to ask us not to process your personal information for marketing purposes and if at any time you wish to opt out of such use then you may contact email@example.com
- To improve our customer service and to make our services more valuable to you
- To send you details of reports, promotions, offers, networking and client events and general information about the industry sectors which we think may be useful to you
- To carry out our obligations arising from any contracts entered into between you and us
From time to time we may seek your consent to process, use or disclose your information for any other purpose not listed above.
How long we hold information about you
We are required by law to hold your information for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller.
We will use reasonable endeavours to ensure that your Personal Data is maintained and up to date. However, you are under a duty to inform us of any and all changes to your Personal Data to ensure that it is up to date and we will update or delete your Personal Data accordingly.
Information we receive from other sources
- We also work closely with a number of third parties, such as regulatory authorities or government departments, and may receive information about you from them.
- We may use this information on its own or combined with any of the information we receive or collect from you for any of the below purposes.
We may use this information:
- To monitor and improve our service offering to you, as well as to notify you of changes to our website or service. Where we collect information by way of feedback or a survey, this will only ever be published anonymously as a combination of responses, rather than individually, unless otherwise agreed with you
- To carry out our obligations under any contracts between you and us, and provide you with services and information that you request from us
- To provide you with information about other services we offer that are similar to those you’ve already enquired about or received
- To provide you with information that you have consented to receive
- As part of a recruitment process, when applicable
- We will retain and process your personal information for as long as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Passing on information about you to third parties
To operate effectively as a business we may need to pass your information on to selected and trusted third parties. The third parties we may share information with are:
- Awarding bodies
- government bodies, departments or other third parties, and departments for research and statistical purposes
- third-party processors
- any third party to whom we may need to disclose personal information in order to comply with our legal, regulatory and statutory obligations. This may be as part of a legal process, (for example, in response to a court order or in response to a law enforcement agency’s request, or where they believe it’s necessary). This could be to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety, property or rights of any person. It could also include non-compliance with our website rules, or as otherwise permitted
- any third party where you’ve given your consent
Other third party websites
Our website may, from time to time, contain links to and from third-party websites, including those of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We don’t accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Security and safe storage of your personal information
Once we’ve received your information, we'll use appropriate procedures and security features to try to prevent unauthorised access.
Unfortunately, the transmission of information via the internet isn’t completely secure. Although we endeavour to protect your personal data, we can't guarantee the security of data transmitted over the internet. Any transmission of data is at your own risk.
Information supplied by you to us, or that we collect about you, may be transferred and stored by us or contractors for the purpose of providing services to you outside the European Economic Area. Where this occurs we use the model clauses as issued by the European Commission or other appropriate safeguards where applicable. By submitting personal data, you agree to this transfer, storing or processing.
We may monitor the use and content of emails, calls and secure messages sent from and received by us so that we can identify and take legal action against the unlawful or improper use of our systems. The main examples of unlawful or improper use are attempting to impersonate Humres, the transmission of computer viruses and attempts to prevent this website or its services from working.
Our Legal Basis for processing your Personal Data:
We will store and process your data due to one of the following two reasons; consent or contract
You can give us your consent by choosing to opt-in through a tick box when registering on our site, via an email conversation with one of our colleagues or in another way of your choosing.
We will keep a record of your consent and you may opt-out at any point.
We have a contract with an individual and we need to process their personal data to comply with their obligations under the contract.
Or where we haven’t yet got a contract with the individual, but they have asked us to do something as a first step (eg provide a quote) and we need to process their personal data to do what they ask.
We will keep a record of consent and you may opt-out at any point.
How can you access, correct your information and withdraw consent?
You’re able to correct the information we hold about you as follows:
- You may make a request to access your personally identifiable information that’s held by us and maintained in our database. To do this you need to email your request to firstname.lastname@example.org
- From 25 May 2018, depending on the circumstances, you may also have the right to:
- Request erasure of personal information we hold about you
- Request restriction of processing of such information
- Object to the processing of such information
- Request a copy of such information in a portable format
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
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If you have concerns about the way we handle your personal data, you can contact the ICO or raise a complaint.
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