Privacy Policy
Data Protection & Management Policy
1. Introduction
This policy sets out what rights our stakeholders and others
have with regards to how we handle their personal data and how we ensure that
we manage their rights.
2. Collection of Personal Data
Essentially we receive personal information via the
following routes: Website data entry; our website is a UK based website and is
hosted in server farm in Hillington, Glasgow.
Employer Standard Terms of Business, is a contract document
which is sent out to our clients and returned to us using a password protected
format. This data is then entered onto our online learning management platform
called ‘the learning portal’ which will automatically send you details of what
data we holed and direct you to our GDPR Policy statement
Once we have been advised of your intention to complete a
training/assessment event via Competence Matters Ltd we will arrange to meet
with you to complete a formal induction. At this induction, we will seek your
permission to gather your personal data. You will at this point be provided
with a copy of our GDPR policy statement and advised on how we will manage your
data and what your rights under the new GDPR regulations are. Your data will
then be entered onto our online learning management system provided you have
provide your permission for us to do so.
Your personal data could also be gathered by telephone,
through LifeChat and through any related social media applications. Again this
data will be subject to our GDPR policy and will be handled accordingly.
3. Purpose of Collecting Personal Data
We collect personal data from you for one or more of the
following purposes:
- To provide you with
information that you have requested or which we think may be relevant to a
subject in which you have demonstrated an interest;
- To initiate and complete
commercial transactions with you, or the entity that you represent, for
the purchase of products and/or services;
- To fulfill a contract that
we have entered into with you or with the entity that you represent;
- To ensure the security and
safe operation of our websites and underlying business infrastructure, and
- To manage any
communication between you and us.
The table in Section 4 below provides more detail about the
data that we collect for each of these purposes, the lawful basis for doing so,
and the period for which we will retain each type of data.
Technical information
In addition, and in order to ensure that each visitor to any
of our websites can use and navigate the site effectively, we collect the
following:
a)
Technical information, including the Internet
Protocol (IP) address used to connect your device to the Internet;
b)
Your login information, browser type and
version, time zone setting, browser plug-in types and versions.
c)
Operating system and platform; Information about
your visit, including the Uniform Resource Locators (URL) clickstream to,
through, and from our site.
In Section 7 below, we identify your rights in respect of the
personal data that we collect and describe how you can exercise those rights.
4. Lawful basis for the processing of personal data
The table below describes the various forms of personal data
we collect and the lawful basis for processing this data. Our business
architecture, accounting and systems infrastructure and compliance organisation
means that all personal data is processed on common, Group-wide platforms. We
have processes in place to make sure that only those people in our organisation
who need to access your data can do so. A number of data elements are collected
for multiple purposes, as the table below shows. Some data may be shared with
third parties and, where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest,
we apply the following test to determine whether it is appropriate:
a)
The purpose test – is there a legitimate
interest behind the processing?
b)
Necessity test – is the processing
necessary for that purpose?
c)
Balancing test – is the legitimate interest
overridden, or not, by the individual’s interests, rights or freedoms?
5.
|
Purpose of
collection
|
Information category
|
Data collected
|
Purpose for collection
|
Lawful basis for
processing
|
Data shared with?
|
Retention period
|
|
1. To provide you with
information
|
Subject matter
information
|
Name, company name,
geographic location, email address, business sector.
|
To provide appropriate
online or email information about products and services that you have
requested
|
Contractual fulfilment
|
Internally only
|
Maximum 8 years from
the data the information is collected.
6 months if a marketing
email is left unopened
|
|
To provide further,
related, online or email information and ongoing news updates in relation to
the identified area of interest.
|
Legitimate interest
|
Internally only
|
|
Telephone number
|
Follow-up to ensure
requested information meets needs and identify further requirements
|
Legitimate interest
|
Internally only
|
|
Personal contact
information as provided through website forms or at trade shows or any other
means.
|
General mailing list
|
Consent
|
Internally only
|
|
2. Transactional
information
|
Transaction details
|
Name, physical address,
email address, telephone number, bank account details (for credit accounts),
other medium of content delivery
|
To process purchase
transactions for products and services with customers, and to ensure any
transaction issues can be dealt with.
|
Contractual performance
|
Internally only
|
Maximum 8 years from
the date of the performance of the contract.
6 months from the data
the data subject has input personal information but has not proceeded with a
transaction.
8 years for VAT records
from the performance of the contract
|
|
For accounting and
taxation purposes
|
Statutory obligation
|
Internally and
professional advisers
|
|
Documentation should
any contractual legal claim arise
|
Legitimate Interest
|
Internally and
professional advisers
|
|
Payment card data
|
Primary account number
(PAN), cardholder name, service code, expiration date
|
To fulfil purchase
requests using payment cards
|
Contractual performance
|
Payment card companies,
all in line with PCI DSS
|
Only retained whist
authorisation is pending.
|
|
3. Fulfilment
information
|
Fulfilment data
|
Name, dietary
requirements
|
Appropriate catering
arrangements for training courses
|
Contractual performance
|
Internally and training
venues
|
Maximum 6 years from
the date of the performance of the contract.
|
|
Name, contact and
identification details
|
Access to training
courses, attendance registers
|
Contractual performance
|
Internally and training
venues
|
|
Name, contact and
identification details
|
Exam attendance, exam
results and certifications
|
Contractual performance
|
Internally and external
examiners, proctors and certification bodies
|
|
Name, contact details
|
Licensing details
necessary for allocation and maintenance of a licence purchased for use of
software and related products, distance and e-learning.
|
Contractual performance
|
Internally and any
third parties whose products or services you may have purchased from us.
|
|
Name, address(es),
email address, contact details
|
Actual delivery of
products or services, in physical or digital form, that you may have
purchased from us.
|
Contractual performance
|
Internally and any
third party logistics or supplier companies with whom we contract in order to
fulfil these requirements.
|
|
|
|
Name, Address, NI
Number, Gender, SCN Number, Employment status, Employer address, Email
address, Telephone number, Previous Skills and Competencies, TNA
|
Public authorities
concerned with economic and/or skills
Awarding bodies for vocational
qualifications: and/or
c. Training or demonstration to other
learners
|
Contractual Performance
|
Internally and any
third party logistics or supplier companies with whom we contract in order to
fulfil these requirements.
|
Maximum 6 years from
the date of the performance of the contract
|
|
4. Security
|
Security information
|
Technical information,
as described above, plus any other information that may be required for this
purpose
|
To protect our websites
and infrastructure from cyber attach or other threats and to report and deal
with any illegal acts.
|
Legitimate interest
|
Internally, forensic
and other organisations with whom we might contract for this purpose.
|
Relevant statutes of
limitation
|
|
5. Communications
|
Contact information
|
Names, contact details,
identification details
|
To communicate with you
about any issue that you raise with us or which follows from an interaction
between us.
|
Legitimate interest
|
Internally and, as
necessary, with professional advisers.
|
Relevant statutes of
limitation.
|
6. Storage of personal data
Competence Matters Ltd is a UK-domiciled organisation whose
primary offices are in the Cumbernauld, Scotland and Warrington, England.
Our website and web applications are hosted in Hillington,
Glasgow, Scotland and are accessed only by our UK based staff.
Our customer relationship management, marketing and
accounting systems are all hosted in Hillington Glasgow, Scotland.
We use a wide range of Cloud Service Providers (CSPs) as
part of our processing environment. Unless we specifically state otherwise, we
are, in respect of all these CSPs, the data controller.
Unless we specifically state otherwise all of the CSPs that
we use utilise EU/US located processing facilities.
Our payment processors and banking arrangements are based in
the UK.
We operate a data retention policy in respect of all data,
whether paper-based or digital and those aspects of it which relate to personal
data are contained in the table 5, above.
7. Security measures
We are currently actively working towards ISO/IEC 27001 for
our information security management system (ISMS). All our payment card
processing is in compliance with PCI DSS.
We have what we believe are appropriate security controls in
place to protect personal data. Risk assessment, including assessing risks to
the rights and freedoms of data subjects, is at the heart of our ISMS.
We do not, however, have any control over what happens
between your device and the boundary of our information infrastructure. You
should be aware of the many information security risks that exist and take
appropriate steps to safeguard your own information. We accept no liability in
respect of breaches that occur beyond our sphere of control.
8. Your rights as a data
subject
As a data subject whose personal information we hold, you
have certain rights. If you wish to exercise any of these rights, please email privacy@competencematters.co.uk.
In order to process your request, we will ask you to provide
two valid forms of identification for verification purposes. Your rights are as
follows:
- The right
to be informed - As a data controller, we are obliged to provide clear and
transparent information about our data processing activities. This is
provided by this privacy policy and any related communications we may send
you.
- The right
of access - You may request a copy of the personal data we hold about you
free of charge. Once we have verified your identity and, if relevant, the
authority of any third-party requestor, we will provide access to the
personal data we hold about you as well as the following information:
a)
The purposes of the processing
b)
The categories of personal data concerned
c)
The recipients to whom the personal data has
been disclosed
d)
The retention period or envisioned retention period
for that personal data
e)
When personal data has been collected from a
third party, the source of the personal data
If there are exceptional circumstances that mean we can
refuse to provide the information, we will explain them. If requests are
frivolous or vexatious, we reserve the right to refuse them.
If answering requests is likely to require additional time
or occasions unreasonable expense (which you may have to meet), we will inform
you.
The right to
rectification - When you believe we hold inaccurate or incomplete personal
information about you, you may exercise your right to correct or complete this
data. This may be used with the right to restrict processing to make sure that
incorrect/incomplete information is not processed until it is corrected.
The right to erasure (the
‘right to be forgotten - Where no overriding legal basis or legitimate reason
continues to exist for processing personal data, you may request that we delete
the personal data. This includes personal data that may have been unlawfully
processed. We will take all reasonable steps to ensure erasure.
The right to restrict
processing - You may ask us to stop processing your personal data. We will
still hold the data, but will not process it any further. This right is an
alternative to the right to erasure. If one of the following conditions applies
you may exercise the right to restrict processing:
a) The
accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing but the personal data is
required for part of a legal process
d) The right to object has been exercised and processing is restricted pending
a decision on the status of the processing
The right to data
portability - You may request your set of personal data be transferred to
another controller or processor, provided in a commonly used and
machine-readable format. This right is only available if the original
processing was on the basis of consent, the processing is by automated means
and if the processing is based on the fulfilment of a contractual obligation.
The right to object - You
have the right to object to our processing of your data where:
a)
Processing is based on legitimate interest;
b)
Processing is for the purpose of direct
marketing;
c)
Processing is for the purposes of scientific or
historic research;
d)
Processing involves automated decision-making
and profiling.
9. Contact us
Any comments, questions or suggestions about this privacy
policy or to request your personal data / ask to be forgotten please email privacy@competencematters.co.uk
Alternatively, you can contact us at
GDPR Compliance Manager
Competence Matters Ltd
56 Deersdyke View
Wesfield Park
Cumbernauld
Scotland
Telephone: +44
(0)141 630 4150
10. Complaints
Should you wish to discuss a complaint, please feel free to
contact us using the details provided above. All complaints will be treated in
a confidential manner.
Should you feel unsatisfied with our handling of your data,
or about any complaint that you have made to us about our handling of your
data, you are entitled to escalate your complaint to the Information
Commissioner’s Office (ICO), who is also our lead supervisory authority. Its
contact information can be found at https://ico.org.uk/global/contact-us/.