Learning Plus

CHALLENGE_TRG SKILLS LIMITED

LEARNING PLUS LMS  

DATA PROCESSING NOTICE

(LEGITIMATE BASIS PROCESSING)

 

 What is the purpose of this document?

This privacy notice applies to Challenge-trg Skills Limited and affiliated companies. A reference to “we”, “us” or “ours'' in this notice is a reference to the specific company in the Challenge-trg Skills Limited which employs or engages you.

This privacy notice describes how we collect and use personal information about you while using the Challenge-trg Skills Limited Learning Plus Platform, in accordance with the UK General Data Protection Regulation and any other applicable privacy laws (referred to as “GDPR” in this notice).

This notice applies to all learners on the Challenge-trg Skills Limited Learning Plus Platform

Challengetrg Skills Limited 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.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read 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.

 

Where can you find a copy of this privacy notice?

THIS NOTICE WILL BE PUBLISHED IN THE FOLLOWING PLACES, AND MAY BE UPDATED FROM TIME TO TIME. THE PUBLISHED VERSION WILL BE THE CORRECT VERSION

 

Challengetrg Skills Limited Learning Plus Platform:

A COPY OF THE CURRENT PRIVACY NOTICE IS AVAILABLE ON REQUEST FROM THE DATA PROTECTION OFFICER VIA EMAIL (thedpo@ctrg.co.uk)

Data protection principles

We will comply with UK GDPR. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected for valid purposes that we have clearly explained to you and not used in a way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited 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.

 

The kind of information we hold about 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 or made inaccessible (anonymous data or pseudonymised data).

There are "special categories" of more sensitive personal data which require a higher level of protection.

 

Specific categories of personal data that we could hold about you.

We will collect, store, and use some or all of the following categories of personal information about you. 

●       First name

●       Surname

●       Business or personal email address.

 

We will only collect, store, and use personal data or special categories of data where this is required in connection with you using the learning platform.

No special Categories of data is required to be collected for the use of the Challenge-trg Skills Limited Learning Plus Platform

How is your personal information collected?

We collect this personal information to:

·        Register and manage your user account

·        Communicate important updates and support information

·        Comply with our legal obligations as an educational provider  

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract, we have entered into with you or your employer.

2. Where we need to comply with a legal obligation (this includes sharing information with customers and educational providers to validate your training) for example.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, although these are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest or for official purposes.

 

Situations in which we will use your personal information

We need the types of information in the list above to allow us to perform our contract with you or your employer and to enable us to comply with our legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

●       In connection with education, training and development requirements..

●       To comply with our legal obligations.

●       To prevent or investigate fraud, theft or other wrongdoing.

●       To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide the personal information requested above, then we will be unable to give you access to the Learning Plus Platform and you will not be able to complete your training.

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 usually notify you. The exception to this is where the change is made in respect of one or more categories of a learner (e.g., due to a change in law) in which case such changes will be notified through the publication of a revised privacy notice. We will always endeavour to tell you about these types of changes, and we will explain the legal basis which allows us to undertake this new processing.

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.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the Challenge-trg Skill Limited.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, or where it is necessary to administer the working or training relationship with you, or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" includes the following types of third-party service providers (including their contractors and designated agents):  

1.      Law enforcement or regulatory bodies.

2.      The Courts.

3.      Insurance companies.

4.      Training providers or Companies (e.g., in connection with training) .

5.      Auditors (including customer/educational auditors).

6.      Providers of apps we use (e.g., Moodle).

7.      Other companies within the Challenge-trg Skills Limited.

8.      Companies that host or provide our IT systems, platforms, or apps.

9.      Document or data archiving companies we use to store records in line with our legal data retention obligations

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes unless they obtain permission from you directly to do so. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance. for system maintenance support and hosting of data, through our shared support functions in order to perform our contract with you.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information.

 

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 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. We keep security measures under review and update our procedures and processes as necessary. We limit access to your personal information to those employees and other third parties who have a business need to see it. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

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. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise or pseudonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and where possible securely destroy or delete your personal information in accordance with our data retention policy and applicable law.

Where it is not possible to destroy or delete personal information, we may instead move the data to a location which makes it inaccessible.  This would have the effect of stopping any processing. 

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 educational relationship with us.

Your rights in connection with personal information

Under certain circumstances, and in accordance with applicable GDPR or other law you have the right to:

●       Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

●       Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

●       Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

●       Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

●       Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

●       Request the transfer of your personal information to another party.

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 the Data Protection Officer in writing via email thedpo@ctrg.co.uk.

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, unless prevented by law, 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 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.

Right to withdraw consent

In those very limited 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 email thedpo@ctrg.co.uk, making it clear which consent you are seeking to withdraw. 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. 

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO (thedpo@ctrg.co.uk).

You have the right to make a complaint at any time to the supervisory authority with responsibility for the country in which we have employed or engaged you to work.  For further details of the relevant authority, please see this link:

 

●       UK: https://ico.org.uk/

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.
**ends**