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Well Privacy Notice - May 2018

This Privacy Notice describes what WELL Associates does with the personal information you provide it with.

It applies to information the WELL Associates collects about:

  • People who use or may use the organisation's services. This includes for example:

- individuals who undertake a course of study through WELL Associates
- employers who take a student on work experience or placement
- employers who employ an Apprentice
- WELL Associates employees

  • Individuals who request information from WELL Associates

If you are asked to provide personal information to us, it will only be used in the ways described in this Privacy Notice. If you have any questions about this policy, please contact the Data Protection Officer jackie@welltraining.co.uk

The categories of the information that WELL Associates collects, holds and shares includes, but is not limited to:

  • Personal information (such as name, ULN number address, date of birth, national insurance number)
  • Contact information (which may include phone number, email and postal address)
  • Educational Information (including qualifications, predicted grades, learning support needs, attendance information – number of absences and reasons and individual achievements)
  • Characteristics (such as gender and if the same as at birth, age, ethnicity, first language, nationality, country of birth and free school meal eligibility)
  • Financial information (bank details)
  • Information about personal preferences and interests
  • Company information, (financial, staff, professional development records)
  • Staff contract information (start dates, hours worked, post, roles and salary information, annual leave entitlement, employment history and professional development).
How we use this data

Your personal information will be used for purposes relating to education, training, employment, general advice services, well-being and research. The organisation may share non-sensitive personal information about you with other organisations as follows:

Most of the information is passed to Government agencies (including but not limited to the Education and Skills Funding Agency) to meet funding arrangements. Where necessary it is also shared with the Department for Education (DFE).

The information is used for the exercise of functions of these Government departments and to meet statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009. It is also used, in collaboration with the appropriate organisations, to create and maintain a unique learner number (ULN) and a Personal Learning Record (PLR)

It is used by WELL Associates to:

  • process applications, enrolments and workforce development programmes and contracts
  • for the organisation's own internal records so that it can provide you with a high quality service
  • to contact individuals in response to a specific enquiry
  • to customise the organisation's services so they work better for individuals
  • to contact individuals about services, products, offers and other things provided by the organisation which it thinks may be relevant
  • to contact individuals via e-mail telephone or mail for research purposes
  • At no time will WELL Associates assume permission to use information that is provided for anything other than the reasons stated here.

The information provided may be shared with other organisations for purposes of administration, the provision of career and other guidance and statistical and research purposes, relating to education, training, employment and safeguarding for example safeguarding). This will only take place where the sharing is in compliance with the General Data Protection Regulations 2018.

Individuals may be contacted after they have completed their programme of learning to establish whether they have entered employment or gone onto further training or education. Following that initial contact and information gathering exercise.

Individuals may be contacted by the European Social Fund (ESF) Managing Authority, or its agents, to carry out research and evaluation to inform the effectiveness of the programme. Information may be passed to the ESF for this purpose.

Further information about use of and access to personal data, and details of organisations with whom the data is regularly shared are available at:

  • process applications, enrolments and workforce development programmes and contracts
  • for the organisation's own internal records so that it can provide you with a high quality service
  • to contact individuals in response to a specific enquiry
  • to customise the organisation's services so they work better for individuals
  • to contact individuals about services, products, offers and other things provided by the organisation which it thinks may be relevant
  • to contact individuals via e-mail telephone or mail for research purposes
  • At no time will WELL Associates assume permission to use information that is provided for anything other than the reasons stated here.

The information provided may be shared with other organisations for purposes of administration, the provision of career and other guidance and statistical and research purposes, relating to education, training, employment and safeguarding for example safeguarding). This will only take place where the sharing is in compliance with the General Data Protection Regulations 2018.

Individuals may be contacted after they have completed their programme of learning to establish whether they have entered employment or gone onto further training or education. Following that initial contact and information gathering exercise.

Individuals may be contacted by the European Social Fund (ESF) Managing Authority, or its agents, to carry out research and evaluation to inform the effectiveness of the programme. Information may be passed to the ESF for this purpose.

Further information about use of and access to personal data, and details of organisations with whom the data is regularly shared are available at:

WELL Associates has identified that it meets a number of lawful basis for processing (as set out in Article 6 of the GDPR). In summary:

  • For processing enquiries and applications to the organisation the lawful basis is legitimate interest.
  • For processing information relating to and individuals programme of study the lawful basis is legitimate interest and may also be linked to a contract.
  • For gathering information about the destination of an individual once they have left WELL Associates the lawful basis is legitimate interest.
  • For contact individual who have completed a course at the organisation the lawful basis is consent.
Security

WELL Associates will hold personal information securely.

WTo prevent unauthorised disclosure or access to personal information, it has strong organisational and technical security safeguards. If information is shared with another organisation (reasons for this are given in the section below) it will ensure an Information Sharing Agreement is in place.

WELL Associates follows stringent procedures to ensure it processes all personal information in line with the General Data Protection Regulations 2018.

Information Sharing and Disclosure

WELL Associates does not sell or rent personal information.

Information may by necessity be disclosed to appropriate staff members of WELL Associates and to government bodies (as previously outlined).

Organisations that WELL Associates may share personal information with includes:

  • Awarding Bodies (learners)
  • Education and Skills Funding Agency (learners)
  • Employers (learners)
  • HMRC (employees)
  • Local authorities
  • Ofsted (learners)
  • Pension Service (employees)
  • Police (depending upon circumstances learners and/or employees)
  • Social Care (depending upon circumstances predominantly learners)
  • Sub-contractors (learners and/or employees)

Information may be shared with third parties if it is in connection with the service being provided to individuals, for example, the organisation might share information with market research companies contracted to undertake work on its behalf to assess satisfaction with the organisation's service. When WELL Training does this it will always ensure an Information Sharing Agreement is in place.

If, as part of the entry requirements for a course or if an individual is applying for a job with WELL Training, the organisation needs to take up a reference or obtain 'disclosure' from the Disclosure and Barring Service, it will inform you beforehand.

Learners are asked for their consent for sharing information with parents/others on the ata consent form. Learners may withdraw their consent the same way which they gave it.

Controlling Information about Individuals

When individuals fill in a form or provide their details on WELL Training's website, there may be one or more tick boxes allowing them to:

  • opt in to receive marketing communications from the organisation by e-mail, telephone, text message or post.

Any individual can request that WELL Training delete their personal data. This request for erasure can be made by e-mailing the Data Protection Officer at jackie@welltraining.co.uk

Whilst the General Data Protection Regulations 2018 doesn't provide an absolute right to have your personal information deleted by an organisation (for example they do not need to delete personal information if they are obliged to keep it by law or have another legitimate reason to keep it) WELL Associates will review each request for erasure will be assessed on a case by case basis.

People who request information from WELL Training

If an individual requests information from the organisation by letter, telephone, email, submitting an enquiry card or from a sales appointment, the organisation will make a record of that enquiry and will use the information to provide the individual with a response. It will only use the information for these purposes and to provide a follow up service to ensure that it provided the individual with what they asked for.

Accessing Your Own Personal Information

Individuals have the right to ask for a copy of any of their personal information held by WELL Training They can make a 'subject access request' under the General Data Protection Regulations 2018.

A hard copy of this form is available on request from the organisation. Alternatively, a request can be made directly to the Data Protection Officer at jackie@welltraining.co.uk

Requests to delete personal data

One of the key principles which underpins the GDPR is the right of an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing. This is also known as the right to be forgotten.

A hard copy of this form is available on request from WELL Training via Data Protection Officer at jackie@welltraining.co.uk

Any requests from individuals to:

  • have inaccurate personal data rectified (right to rectification),
  • restrict or suppress of their personal data (right to restrict processing),
  • obtain and reuse their personal data for their own purposes across different services (right to data portability),
  • object to how their personal data is used, should be made directly to the Data Protection Officer at jackie@welltraining.co.uk
Complaints or Queries

If there are any questions about the organisation's collection and use of personal data, please contact the Data Protection Officer at jackie@welltraining.co.uk who will be happy to provide additional information if it is required.

If you have a concern about the way WELL Training has handled or is handling your personal information, or you wish to make a complaint because we have not complied with our obligations, you can make a complaint to the Information Commissioners Office (ICO).

You should raise your concerns with within three months of your last meaningful contact with the organisation. Details of how to do this are on the Information Commissioners Office website: https://ico.org.uk/concerns/handling

By post: If your supporting evidence is in hard copy, you can print out the form and post it to the ICO (with your supporting evidence) to:
Customer Contact Information
Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Changes to This Privacy Notice

The organisation 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 the website.