The following Privacy Notice is to let you know how we promise to look after your personal data, your privacy rights, and how the law protects you. We hope that the information is clear and easy to understand, however, if this is not the case, or you require any further clarity, please contact our Data Protection Officer Roger Guy on 0191 386 2634 or email email@example.com
Our Privacy Promise to you:
- To keep your data safe and private
- To never sell your data
- To give you ways to manage and review the data which we hold
How the law protects you
As well as our privacy promise to you, your privacy is protected by law. The law itself is currently under review.
The Data Protection Act 1998 (DPA) governs all organisations who hold personal data on individuals. On 25 May 2018 the General Data Protection Regulation (GDPR) comes into force. Our interpretation of this regulation is that the GDPR takes many of the core principles of the DPA, and modernises them in view of the shift in digital technologies and digital communication/storage. The GDPR aims to hold organisations more accountable for the protection of your personal data, and provide you with more rights as to how this is collected, used, retained and destroyed.
The law says that we are allowed to collect and use your personal data only if we have a reason to do so:
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it
In terms of the information we hold for you as a training provider, this is no different to that held for example by a school or college.
WHY WE HOLD PERSONAL DATA
We hold personal data on learners and employers for the following reasons:
- Information we are required to collect by law or to claim funding.
- Additional information that will allow us to personalise our support to meet your individual needs.
- Information we use for marketing, communications and advice. At no time will your personal data be passed to other organisations for marketing or sales purposes.
The personal data we hold includes:
- Personal information (such as name, date of birth, national insurance number, address, emergency contact information).
- Special categories of data including characteristics information such as gender, age, ethnic group.
- Progression information, individual learning plans, records of discussion, support requirements).
Where we collect personal information from
We initially collect information on you at the point in which you engage with Finchale Group. We may also collect personal information:
- During telephone conversations
- During 1-1 meetings with you
- When you visit our website
- Through surveys
- Through third parties:
- Awarding Bodies
- Government Agencies and Departments
- Public information sources, for example Companies House
- Market Researchers
We will hold your information securely.
To prevent unauthorised disclosure or access to your information, we have implemented strong organisational and technical security safeguards.
If information is shared with another organisation (possible reasons for this are given in the section below) we will ensure an Information Sharing Agreement is in place.
Who we share your personal information with
Finchale Group will never sell your data we will only ever share your data with the required organisations to fulfil our legal contractual duties.
A list of those agencies/organisations that we currently share limited information is shown below:
- The Education & Skills Funding Agency (ESFA):
- The Department for Work and Pensions
- Ofsted: https://www.gov.uk/government/organisations/ofsted
- Local Authorities
Sending data outside of EEA
The General Data Protection Regulation is a European regulation and as such only offers protection to your data within the European Economic Area (EEA). Finchale Group does not need to send your data outside of the EEA as part of its day to day business. In view of this we have taken the decision to only release data to you, on your request, and not at the request of another organisation outside of the EEA.
If you choose not to give us personal information
We may need to collect personal information by law, or under the terms of our legal and contractual obligations. If you choose not to give us this personal information, it may prevent us from meeting our obligations. This may result in us being unable to support you.
If you have any concerns about the personal information we are asking you to share with us, or have any concerns regarding our intent, please contact our Data Protection Officer, Roger Guy on 0191 386 2634 or email firstname.lastname@example.org
Finchale Group will only share your personal data with bodies or organisations who fully comply with the GDPR framework. Any data collection that is optional would be made clear at the point of collection.
We may use your personal information to tell you about relevant opportunities, this is what we mean by ‘Marketing’. For clients this may be a vacancy with an employer that may be suitable, or a training programme opportunity.
The personal information we have is made up of what you tell us, the data we may have collected, or from third parties we work with. We study this to form a view of what we think you may want or need, or what may be of interest to you.
We can only use your personal information to contact you if we have either your consent, or a ‘legitimate interest’. This is when we have a valid reason to do so, and it must not go against what is right and best for you.
You can ask us to stop contacting or update your choices at any time by contacting us.
Visitors to our website
When you visit www.finchale.org we collect standard internet log information and visitor details of behaviour patterns. We do this to find out such things as the number of visitors to different parts of the site. We collect the information in a way which does not identify anyone. If we want to collect personally identifiable information through our website we will be upfront about this and will make the purpose clear
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. These also enable us to see information like how many people use the website and what pages they tend to visit. Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us. You can choose to change your browser settings if you do not want us to store cookies on your computer. Please be aware that cookies may be required to complete certain functions on our website.
Links from our Website
How long we keep your personal information
We will keep your personal information as long as you are engaged with Finchale Group as a client
After you stop being a client, we may keep your personal information for up to 10 years for one of these reasons:
- To respond to any questions or complaints
- To show that we treated you fairly
- To retain records according to the rules that apply to us.
Finchale Group is primarily funded through public funds, and as such we are required to keep data for a variety of legal, regulatory or technical reasons. In some cases, records must be maintained for auditory purposes by funding bodies. We will make sure that your privacy is protected and only use it for those purposes.
How to get a copy of your personal INFORMATION
You can access your personal information we hold by writing to us at this address:
FAO Roger Guy
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think may be wrong or incomplete. Please contact us if you want to do this and we will take reasonable steps to check its accuracy and correct where necessary.
What if you want us to stop using your personal information?
You have various rights to object to our use of your personal information, these are officially known as the; ‘right to object’, ‘right to erasure’ and ‘right to be forgotten’.
There may be legal or other regulatory reasons why we need to keep or use your data, but please contact us if you think that we should not be using it.
We may sometimes be able to ‘restrict’ the use of your data. This means that it can only be used for legal or regulatory reasons, but not for other reasons while it is restricted.
If you want to object to how we use your data, or ask us to delete or restrict how we use it, please contact us.
You have the right to ‘change your mind’. We may have collected information at a point in time where you consented to us using it in a certain way, for example to market new opportunities to you. If you have since changed your mind, you can withdraw that consent. Please contact us if you wish to do so.
SENSITIVE PERSONAL DATA
Some of your personal data is deemed to be sensitive, examples of this may include:
- Details of any health problems, disabilities or individual learning needs
- Information around gender reassignment
We would only share sensitive personal data with your express written permission, or if there are special legal reasons (such as a request for information by a court).
How to complain
Please let us know if you are unhappy with how we have used your personal information. Contact our Data Protection Officer, Roger Guy on 0191 386 2634 or email email@example.com
You also have the right to complain to the Information Commissioners Office.
Formats for sharing data
You have the right to obtain your personal information in a format that can easily be re-used. You can also ask us to pass your personal information to other organisations in this format. We are happy to work with you to provide your information in an acceptable format, these may include:
- Large Print or Braille Format
- Text Documents .doc .docx .rtf
- Data Formats .xls .xlsx .csv .dbs .dbsx .html .xml
- Image Formats .pdf .jpeg .gif
Changes to this privacy notice
We will keep this Privacy Notice under regular review and reserve the right to change it as necessary from time-to-time or if required by law. Any changes will be immediately posted on our website.