Personal Data Privacy Policy

Introduction

Awbery is committed to ensuring that your privacy is protected and the fair and transparent processing of your personal data.

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

Who are we?

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), Awbery Management Centre Ltd is the ‘controller’ and ‘processor’ of participant personal data. Awbery Management Centre Ltd is a Leadership, Development, HR and Coaching Solution Provider.

Awbery Management Centre Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Business Development Director Mary Sisson; mary.sisson@awberymanagement.co.uk or by writing to us at our registered address:-

Management House

76 High Street,

Repton,

Derbyshire,

DE65 6GF.

We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

What personal data do we collect and hold on you?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

We receive information about you when your organisation has put you forward to attend a workshop/ Programme. We will collect, store, and use the following categories of personal information about you:

  • Name,
  • Job title,
  • Line manager/mentor name,
  • Mobile telephone number,
  • Email address,
  • Company contact details,
  • Date of birth, gender,
  • Home address,
  • Previous postcodes
  • Qualification information, i.e. start date of qualification, your assignments
  • Learner support information

We require this sensitive personal data, such as information about your health, to enable us to administer requests for reasonable adjustments, or sensitive personal data relating to an investigation, complaint, or appeal. Such information should only be provided to us with your explicit consent.

We may also collect other categories of personal data if required in relation to a specific qualification or programme, and personal data if required to carry our quality assurance processes, investigations, complaints and appeals.

How do we use your personal data?

We may use your personal data where this is necessary to pursue our legitimate interests as a provider of training, assessment, and certification products and/or services, including to:

  • provide you with information regarding the programme/ workshop for which you have registered;
  • undertake administration in relation to the programme/ workshop for which you have registered;
  • liaise with the appropriate awarding body to obtain a certificate, credentials or other record of learning;
  • contact you directly in relation to our quality assurance processes, investigations, appeals, and complaints;
  • assess and provide reasonable adjustments in relation to your learning or assessment where requested.
  • Contact you regarding your qualification journey and keep a track of where you are on your journey
  • To provide customer care, including responding to your requests if you contact us with a query
  • To administer accounts, process payments and keep track of billing and payments

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with your organisation, or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Accessing and updating your data

You must maintain the accuracy of your information and ensure all your details, including but not limited to, name, address, title, phone number, e-mail address and payment details.

Who do we share your personal data with?

We will share your personal data, in relation to your learning, assessment, or certification with the appropriate awarding organisation, The Institute of Leadership & Management (TILM) or Chartered Management Institute (CMI) and the Skills Funding Agency (SFA) and your employer.

If you are undertaking an ILM qualification they may share your details with TILM to enable TILM to offer you student membership in relation to leadership and management. You can find out more about TILM at www.institutelm.com

If you are undertaking a CMI qualification they may share your details with third party processors and regulators such as i.e. OFQUAL. For further information please visit:- https://www.managers.org.uk/policies/privacy-policy

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 Learning 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 our Privacy Notice

We may also share your personal data with a third party providers including:

  • legal and other professional advisers, consultants, and professional experts;
  • service providers contracted to us in connection with provision of learning, assessment, and training products and services such as markers, moderators, assessors, certification or credentialing providers, IT services and customer relationship management services; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will ensure there is a contract in place with such third parties which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

We take all reasonable steps to ensure that our team protect your personal data and are aware of their data security obligations. We limit access to your personal data to only those who have a genuine business need to know it.

We may also share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will retain personal data relating to your learning, assessment, and certification to enable us to provide information about your learning or a replacement certificate.

We will retain personal data relating to our quality assurance processes, appeals, or investigations for a period of 7 years in line with our Retention Policy to ensure we are able to comply with any contractual, legal, audit, accountancy obligations and other regulatory requirements, or any orders from competent courts or authorities. Please contact us if you would like to see a copy of this policy.

Where do we store your personal data and how is it protected?

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Users responsibility

You may be given access to our web Portal ‘The Awb’ when completing a Programme. You are responsible for the security of the password which you will be given. Make sure you keep it in a safe place and do not share it with others. Always remember to log out after your session ends, to ensure that others cannot access your private personal information. You should always take this precaution even if you are not using a public computer, library, community hub or internet café, but even when using your private computer in your home.

Your duty to inform us of changes

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.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to

Request access

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. We will then send you an Access Request Form for you to complete and return to us. We will respond within 1 month of request.

Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if there is no basis for your request, or if it is excessive.

Request correction

We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided above to let us know if any of your personal data is not accurate or if there are any changes to be made, so that we can keep your personal data up-to-date.

Request erasure

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Request to object

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Request the restriction of processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Mary Sisson in writing (see below for contact deytails).

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We will send you a Subject Access Form to complete which will provide us with 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.

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/for more information on how to report a concern to the UK Information Commissioner’s Office.

Changes to our policy

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. Please check back frequently to see any updates or changes to our Policy.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Currently we operate an ‘implied consent’ policy which means that we assume you are happy with our use of cookies. If you are not happy, then you should either not use this site, or you should delete our cookies once you have visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)

 

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

Cookies on the Awbery site

Google Analytics – we use this to understand how the Awbery Internet site is being used in order to improve the user experience. Your user data is all anonymous. You can find out more about Google’s position on privacy as regards its analytics service at

http://www.google.co.uk/intl/en/analytics/privacyoverview.html

Other information we collect

External web services. We use a number of external web services on the Awbery website, mostly to display content within our web pages. For example, to show videos we use YouTube and Vimeo. This is not an exhaustive or complete list of the services we use, or might use in the future, when embedding content, but these are the most common. We cannot prevent these sites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads etc.

Email tracking. Some emails that we send you have no tracking in at all, for example personal correspondence or emails with invoices attached. Other emails we send we put in tracking so that we can tell how much traffic those emails send to our site and we can track, at an individual level, whether the user has opened and clicked on the email. We rarely use the latter information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. Sometimes we do use the personal information e.g. to re-email people who didn’t click the first time. If you want to be sure that none of your email activity is tracked then you should unsubscribe from the Awbery newsletter.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Disclaimer

The material on our site is given for general information only, and does not constitute professional advice. You should take specific advice before taking a course of action as we do not accept directly or indirectly any responsibility for loss arising directly or indirectly from reliance on information on this site.

 

Given that the Internet uses an open system we cannot warrant that the site and downloads reach you virus-free. You must, therefore, take all appropriate precautions for your own safety.

Contact

If you have any questions about this privacy notice, please contact Mary Sisson at Awbery Management Centre Ltd, Management House, 76 High Street, Repton, DE65 6GF.

Copyright

© 2018 Awbery Management Centre Ltd & ILM (We acknowledge that the body of this policy is based on the ILM Learner Personal Data Policy). All rights reserved.