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GDPR: Data Privacy Policy

Introduction

Essential 6 Ltd (“We”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

Essential 6 Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 1 Marble Court Business Park, Lymington Road, Torquay, TQ1 4FB, 0845 272 3558, info@essential6.co.uk  For all data matters contact Sarah Sharrock on sarah.sharrock@essential6.co.uk

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

• Confirming identity for qualifications
• Providing certificates
• Confirmation of attendance on training
• Providing training details

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

• Personal data: Home Address, Private email address, date of birth

We have obtained your personal data from yourself.

5. What is our legal basis for processing your personal data?
6. Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

 

• Processing necessary for compliance with a legal obligation – For accredited training, we are regulated through OFQUAL via our awarding bodies and stipulations are set out regarding what data is required to be processed.
• Processing necessary to protect the vital interests of a data subject or another person – If you have provided us with your personal data in order to attend a course, we will use this data to provide your certificate.

 

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with our trainers and Awarding Bodies i.e Qualsafe Awards, Highfield Awarding Body for Compliance and Construction Industry Training Board and only where relevant to do so.

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary for a period of 7 years in order to provide replacement certificates where training is still in date, provide training records and satisfy OFQUAL requirements and in compliance with HMRC.

8. Providing us with your personal data

You are under an obligation to provide your personal data to us as an attendee of our training as this is a requirement in order to provide you with a certificate.

If you fail to adhere the consequences will be inability to claim a certificate for training attended.

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad

We do not transfer personal data outside the EEA.

11. Automated Decision Making

We do not use any kind of automated decision making in our business.

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Cookies

Information about our use of cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

14. Call Recording

We operate a call recording process meaning all of our calls are recorded. If you are transferred to another team member, the call will continue to be recorded.

The purpose of the call recording is to identify staff training needs and in turn improve the service provided by our staff by improving performance. This also helps us to establish facts in the event of a customer complaint as well as provide protection for our staff against abuse.

All of our calls are recorded however call recording will be switched off in the event of any payment card details being taking in accordance with the Data Protect Act 1998 and General Data Protection Regulation (GDPR).

If you prefer not to have your call recorded then you may request this but this must be stated at the beginning of the call. The switching off of the call recording system is then at the discretion of the staff member, if the staff member wishes to switch the call recording system back on, they must advise the caller of this. If a member of staff does not wish to switch off the call recording after a request is made from the caller, they must state their reasoning for this. If the caller does not accept the explanation, the decision will be referred to the line manager, whose decision will be final. Should the decision be made to continue with recording the phone call and this is not accepted by the caller, the caller must terminate the call.

Storage of call recordings

The record calls will be stored for a maximum of 12 months on a secure server. The only exception to this will be in the unlikely event that a call needs to be retaining as evidence for an unresolved issue or for use in a criminal investigation. In this instance, deletion of the call will be at the discretion of the line manager concerned and the business director. All other calls over 12 months will be deleted from the system.

The system can only be accessed by the business director and by appropriate managers. The system cannot be accessed by other staff members. Calls are not to be downloaded and browsing the recorded calls without valid business reason is not allowed and anyone found doing so may be subject to disciplinary action.

Under the Data Protection Act 1998 and GDPR, individuals have a right to access data held relating to them and the right to make Subject Access Requests to obtain copies of such data. Callers may therefore request copies of any phone conversations involving them which are held on file. For more information, please contact info@essential6.co.uk 

15. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

16. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer, Sarah Sharrock on sarah.sharrock@essential6.co.uk

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.