Learner Personal Data Policy

Learner Personal Data Policy

Introduction

Goodman Wilkinson Associates Ltd (GWA) is committed to data security and the fair and transparent processing of personal data. This Learner Personal Data (Policy) sets out how GWA treats data, including learner personal data. Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

Who are we?

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), Goodman Wilkinson Associates is the ‘controller’ of learner personal data. Goodman Wilkinson Associates Limited is a limited company, with registered company number 3041178. Our registered address is 189 Queens Road, Leicester, LE2 3FN

GWA Ltd is and Approved ILM Centre providing management consultancy, qualifications, facilitation of learning and development, assessment and certification products and services. (GWA, we, us or our)

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Officer by sending an email to jmw@gwa.co.uk or writing to Privacy Officer, Goodman Wilkinson Associates Ltd, 189 Queens Road, Leicester, LE2 3FN.

What personal data do we collect?

We collect your name, gender, and date of birth. We may also collect other categories of personal data if required in relation to a specific qualification or programme, and personal data if required to carry our quality assurance processes, investigations, complaints and appeals.

In exceptional circumstances, we may collect sensitive personal data, such as information about your health, to enable us to administer requests for reasonable adjustments, or sensitive personal data relating to an investigation, complaint, or appeal. Such information will only be collected and used by us if you have given your explicit consent to us to do this.

The Institute of Leadership and Management (ILM) assign a unique learner number to each learner at the point of learner enrolment which we also use in relation to your learning, assessment, and certification.

How do we use your personal data?

We may use your personal data where this is necessary to pursue our legitimate interests as a provider of training, assessment, and certification products and/or services, including to:

  • provide you with products and/or services for which you have registered;
  • undertake administration in relation to products and/or services for which you have registered;
  • provide you with a certificate, credential or other record of learning;
  • contact you directly in relation to our quality assurance processes, investigations, appeals, and complaints;
  • contact you directly in relation to new and existing products, services, news, awards and events offered by GWA, ILM or a member of the City & Guilds Group;
  • assess and provide reasonable adjustments in relation to your learning or assessment where requested.

We may also process your personal data if required by law, including to respond to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

Who do we share your personal data with?

We may share your personal data with associate consultants who are members of the GWA ILM team and members of the City & Guilds Group. Please read the GWA Our People document, available on request from GWA, or visit the Our People page of our website gwa.co.uk/ourpeople  for information on our associate consultants. You can read more about the City and Guilds Group of companies at cityandguildsgroup.com

We may share your personal data with relevant third parties, where necessary, in relation to your learning, assessment, or certification, including:

  • regulatory authorities, sector skills councils, professional bodies, and similar industry bodies;
  • consortiums, authorised representatives, and partners; and
  • centres, providers, awarding bodies and similar third parties.

We may share your personal data with The Institute of Leadership & Management (TILM) to enable TILM to offer you student membership in relation to leadership and management. You can find out more about TILM at www.institutelm.com

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share your personal data with trusted third parties including:

  • legal and other professional advisers, consultants, and professional experts;
  • service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our Website.

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

ILM requires Centres to retain learner record, including supporting documentation, as as soon as a learner is registered and then for a minimum of three years following certification, in case any issues arise.

We will retain personal data relating to your learning, assessment, and certification to enable us to provide information about your learning or a replacement certificate.

We will retain personal data relating to our quality assurance processes, appeals, or investigations for a period of 7 years to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

Where do we store your personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Where you have a username or password (or other identification information) which enables you to access certain services or parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website or sent to us via email or the; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

Under the GDPR, you have various rights with respect to our use of your personal data:

Right to Access

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 30 days of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.

Right to rectification

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 30 days of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to restrict processing

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to data portability

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Unsubscribing

You may unsubscribe from marketing communications at any time by contacting us at jmw@gwa.co.uk or by using the ‘unsubscribe’ functionality on the footer of any marketing communications sent to you.

Contact

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Officer by sending an email jmw@gwa.co.uk or writing to Privacy Officer, Goodman Wilkinson Associates Limited, 189 Queens Road, Leicester, LE2 3FN

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit ico.org.uk/concerns  for more information on how to report a concern to the UK Information Commissioner’s Office.

Changes to our Policy

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