CWCT Privacy Policy

Introduction

Coventry and Warwickshire Chamber of Commerce Training (CWCCT) will ensure that personal data is collected, handled, stored and shared in a secure manner. We value your privacy and want to be clear about the data we collect and process. Data will never be sold to third parties. The overarching principle is that all data collected and stored by CWCCT is done for the sole purpose of CWCCT’s operational business and/or contractual requirements and in the interests of the individual’s relationship with CWCCT.

This will include communication regarding the service offer, marketing of events, notification of publications and news, education and learning quality standards. CWCCT is the data processor of your personal data on behalf of the Education and Skills Funding Agency (ESFA) and a data controller of personal data related to its staff. CWCCT is subject to the Data Protection Act (DPA) 1998 and the General Data Protection Regulation (GDPR) which protects the rights of individuals, detailing what organisations can and cannot do with information.

Use of Personal Data

CWCCT processes the personal data of individuals, including those applying for training courses, those following vocational training courses, staff and other individuals accessing its services for the provision of skills and knowledge development.

Individual information is processed for the purposes of:

  • Recruitment and enrolment;
  • Learning and study matters – off the job training; workplace assessment; registration; attendance; tracking progress; certification; learner records;
  • Administering learner-related services from application to course completion;
  • Compliance with contractual requirements for relevant external agencies, including the Education and Skills Funding Agency (ESFA) and awarding certification bodies;
  • Production of statistical information for use of services, including enrolments, progression, achievement and destination;
  • Supporting communication with applicants and learners;
  • Completion of assessments, verification of qualifications;
  • Monitoring of complaints, disciplinary cases and appeals;
  • Provision of support services, including additional learning support, pastoral and learning resources;
  • Compliance with immigration checks in relation to right to work and access public funding;
  • Monitoring equality and diversity objectives within the business;
  • Safeguarding and learner and staff welfare;
  • Safety and security, including that of the learning and working environment;
  • Administering finance, including learner charges and employer incentives;
  • Dealing with complaints, grievances and disciplinary actions

CWCCT also processes personal data in relation to staff, both teaching and non-teaching. This is undertaken to as part of recruitment activity and to comply with the requirements of UK employment law. In addition, it is used to facilitate operational activity within the relevant department.

We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following to:

  • Interact with you before you are enrolled, as part of the admissions process (e.g. to send you information or answer enquiries about our courses);
  • Once you have enrolled, to provide you with the services as set out in your enrolment guide;
  • Deal with any concerns or feedback you may have;
  • For any other purpose for which you provide us with your personal data

 

PRIVACY POLICY
April 2018 3

Personal Data Collection

  • CWCCT collects personal data from individuals at various stages. The volume and nature of the personal data collected is outlined below:
  • Initial email/telephone enquiry:
  • Name and address
  • Contact details (telephone number, email address)
  • Subject / area of interest
  • Details from application forms:
  • Name and address
  • Contact details (telephone number, email address)
  • Age / date of birth
  • Gender
  • Ethnicity
  • Nationality and national insurance number
  • Educational records to date

Disability declaration

Further data collected at enrolment or updated during an individual’s time in learning:

- Home address
- Entry and other qualifications, courses completed, dates of study and examination results
- Employment history
- Demographic information
- Funding and fee related information
- Information needed to provide services in relation to disability, wellbeing or any other type of pastoral         support
- Course details
- Attendance, progress and current status
- Assessment results: assessments of your work, details of examinations taken, qualifications awarded and     other information in a student record

- Photograph for identification
- Eligibility (to receive Government funding) information (passport number)
- National insurance number
- Information about your family or personal circumstances as required by the Education and Skills Funding     Agency (ESFA)
- Information concerning your health and medical conditions eg. disability or learning difficulty
- Certain criminal convictions (for learners on adult social care and child care courses)
 Data collected for statutory monitoring and reporting purposes:
- Ethnic origin
- Attendance on course of study

Additional personal data may be collected where relevant in relation to employer placements, professional body requirements, appeals/ complaints /disciplinary cases. We will allocate you a unique learner reference number.

 

PRIVACY POLICY
April 2018 4
We may also process your personal data because it is necessary for the performance of tasks carried out in the public interest or because it is necessary for our or a third party's legitimate and/or legal interests. In this respect, we may use your personal data for the following to:

  • Monitor and evaluate the performance and effectiveness of CWCCT, including by training our staff or monitoring their performance
  • Maintain and improve the standard of service delivery
  • Promote equality and diversity
  • Seek advice on our rights and obligations, such as where we require our own legal advice
  • Recover money owed to us

We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following to:

Meet our compliance and regulatory obligations, such as CWCCT’s legal obligation for the ongoing collection of data about individual learners and learning undertaken through the individual learning record (ILR)

  • Anti-money laundering laws and safeguarding requirements
    Prevent and detect of crime
    Assist with investigations (including criminal investigations) carried out by the police and other competent authorities

We may also process your personal data where:

  • It is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional)
    It is necessary to protect your or another person’s vital interests
    We have your specific or, where necessary, explicit consent to do so

CWCCT collects the following information from staff:

Initial application:
- Name and address
- National insurance number
- Contact details (telephone number, email address)
- Self-declaration of permission to work in the UK
- Relevant qualifications or indication of highest qualification held
- Professional development / training and membership of any professional body
- Employment history
- Supporting statement
- Referee details
- Criminal record disclosure
- Declaration about any disability as defined under the Equality Act 2010

Once a candidate has been made an offer of employment:
- Bank details
- Emergency contact details
- Beneficiary declaration
- Qualification information required to be shared with awarding bodies
- Health information
- DBS compliance check
- Right to Work in the UK evidence (as prescribed by the Home Office)

Further personal data captured about an employee is likely to relate to any performance or appraisal process and any information needed to maintain a sickness/absence record.

 

PRIVACY POLICY
April 2018 5

Personal Data Sharing

CWCCT is required to share personal data with certain other organisations in order to meet statutory requirements or to provide services to its learners. Sharing will be undertaken in line with the requirements of data protection law, either through the consent of the individual, or another relevant legal channel. The personal data that is shared will be limited precisely to what the other organisation needs to meet its requirements or deliver its services.

The information below outlines the key partners with whom CWCCT shares personal data with on a periodic basis. You have the opportunity to opt out of some of these data sharing arrangements when you register with us, but you should carefully consider the possible impact of doing this. Unless an opt-out is in place, we may disclose limited personal data to a variety of recipients including:

Our employees, agents and contractors where there is a legitimate or legal reason for their receiving the information, including:
- third parties who work with us to provide specialist training services;
- third parties who work with us to provide support services;
- third parties who are contracted to provide IT services for us;
- internal and external auditors

Those with an interest in tracking progress and attendance, including:

  • Current or potential employers
  • Professional and regulatory bodies
  • Government departments and agencies where we have a statutory obligation to provide information (e.g. the Education and Skills Funding Agency)
  • National/Local Government Departments and other public bodies eg.Ofsted
  • Crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions)
  • Parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure)
  • Awarding bodies for validation of registrations and awards
  • Student Loans Company in connection with fees and loans
  • External examiners for examination, assessment and moderation purposes
  • CWCCT’s insurers and legal advisers for the purpose of providing insurance cover or in the event of a claim
  • Employers who request a reference from CWCCT

Data Retention

CWCCT takes its obligations of not holding personal data for any longer than is necessary very seriously. Data will be retained:

  • Applicant data will be retained for 12 months
  • Learner data will be retained as per contractual requirements (6 years from the end of the financial year in which the last payment for ESFA funded learning services or where learning services have been funded using monies from the European
  • Structural and Investment Funds or where any payments made for learning services have been used as match-funding for a European Structural and Investment Fund Co-Financing project CWCCT will retain documents necessary to verify the services provided. Documents will be retained for a minimum of three years after the European Commission has made its final payment. For the 2007-13 ESF Programme this is until at least 31 December 2022 and for the 2014-20 ESF Programme until at least 31 December 2030
  • Non-government funded training services delegate and learner data will be retained for 3 years post training delivery
    Staff data will be retained for 7 years following the date of leaving employment

PRIVACY POLICY
April 2018 6

In some cases, there are good reasons as to why CWCCT needs to retain data about learners and other individuals for a significant period of time. The most important reasons are outlined below:

  • In order that awards can be verified in the long-term
  • For alumni services and ongoing relations with CWCCT
  • For careers and employability services
  • To deal with complaints, appeals and disciplinary cases
  • For statutory reporting purposes
  • For compliance with ESF match funding rules
  • To produce references on request for previous employees

Data Corrections

If you believe CWCCT holds information about you that is factually incorrect please email enquiries@cw-chambertraining.co.uk if you are a learner or HR if you are a member of staff providing the correct information, and CWCCT should update it within one month.

All students, staff and any other relevant individual who handles personal information of which CWCCT is responsible for must follow the requirements of the Data Protection Policy.

Personal Data Rights

Under the DPA you have the following rights to:

  • Obtain access to, and copies of, the personal data that we hold about you
    Require that we cease processing your personal data if the processing is causing you damage or distress
    Require us not to send you marketing communications
  • Under GDPR you have the following additional rights to:
    Require us to correct the personal data we hold about you if it is incorrect
    Require us to erase your personal data
    Require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal)
    Receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller
    Object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have given your consent and you wish to withdraw it, please contact us using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

Individuals accessing apprenticeships and other government funded services are legal bound to provide personal data as part of the service access.


PRIVACY POLICY
April 2018 7

An individual has the right to ask CWCCT what personal data we hold about them, and to ask for a copy of that information. Any request should be submitted in writing to the nominated data point of contact or in hard copy to the postal address provided. CWCCT reserves the right to ask for proof of identification and for further clarification of the request if it is unclear in the first instance. You will receive a reply no longer than 30 calendar days from the date you make the request in writing.

If you are unhappy with the initial response you can ask CWCCT to undertake a further search if there is specific information you have good reason to believe exists but that hasn’t been provided.

You also have the right to complain to the UK Regulator the Information Commissioner’s Office (ICO’s) if you believe you request has not been dealt with properly or you have a complaint to raise against CWCCT for any other data protection related issue. A complaint can be raised via the ICO’s website. You also have the right to withdraw consent from the processing of your personal data by CWCCT at any time, if your consent was sought initially to use your personal data.

Access Rights

If you have any queries about this privacy notice or how we process your personal data, you can contact us by email:

enquiries@cw-chambertraining.co.uk; by telephone on 02476 231122

or by post to Coventry and Warwickshire, Chamber of Commerce Training, Commerce House, 123 St.Nicholas Street, Coventry, CV1 4FD.

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk