General Principles

• Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) values individual rights to privacy and actively seeks to protect personal data
• We will only collect and use personal data for the purposes we tell you about

Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) will never:

• sell your personal details to anyone
• give your personal details to any third party without your express agreement

What is Personal Data?

Personal data relates to any information about a natural person (the Data Subject) that makes you identifiable and may include, but is not limited to:

• Names and contact information i.e. email addresses and telephone numbers
• Personal information such as date of birth, national insurance number
• Educational information (including qualifications, grades, learning needs)
• Characteristics such as gender, ethnicity, nationality
• Financial information such as bank details
• Information about personal preferences and interests
• Company information, financial and staff details
• Website usage data
• Staff contract information

What is Sensitive Personal Data?

Sensitive personal data includes, but may not be limited to:

• Medical conditions
• Religious and philosophical beliefs
• Political opinions
• Racial or ethnic origin
• Criminal Offences/Convictions
• Genetic and Biometric data
• Trade Union Activities
• Sexual Orientation

Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) is the Data Controller for the personal data we collect and hold. If you have any queries about any aspect of data collection, data processing or access requests please contact us.

Individual Rights

Individuals/Data Subjects have the right to:

• Object to the processing of personal data that is likely to cause or is causing damage or distress
• Prevent processing for the purpose of direct marketing
• Object to decisions being taken by automatic means
• Request that incorrect or out-of-date information is updated or amended
• Request personal data to be blocked, erased or destroyed
• Claim compensation for damages caused by a breach of the General Data Protection Regulations

We do not use automated processes to make decisions and do not store data outside the EU.

Why We Collect Personal Information

We only collect personal information where we have a legal basis for doing so

• To comply with employment law and other statutory responsibilities.
• To enable us to provide goods, services and / or information.
• To update those people who want to receive information about our work.
• To ensure the safety and security of staff and other individuals using our premises, and to prevent or address the misuse of our premises and property.

We have a Data Protection Policy you are welcome to peruse.

This Privacy Notice is in 4 main sections:

• Learners/Delegates
• Employees
• Governors
• Other College Users

Section 1 - Learners/Delegates

Enquiries/Applications

When you enquire or apply for a programme/course we may collect the following information, depending on the course/programme you enquire about/apply for:

• Details about you including name, date of birth, National Insurance number and gender
• Contact details including address, telephone number and email
• Details of previous qualifications, employment and education
• Information about your nationality, residency and previous address
• Information about medical or health conditions, including a learning difficulty or disability.
• Ethnicity

If you do not enrol on a course with us, your details will be removed after 2 years, to ensure we have adequate information to deal with complaints and enquiries. This will also allow us to advise you of any new provision you may be interested in.

Enrolment/Induction

At enrolment/induction we may collect the following additional information.

• Start and planned end dates of any programme/course you are following.
• Employment status.
• Household information.
• Financial details if you are paying a fee
• Employer details if you are an apprentice or your employer is sponsoring you for the programme/course

For Government funded programmes

Most of the information collected at application or enrolment/induction is required by us to deliver your programme/course and prove you are studying with us. We use this information to create an Individual Learning Record (ILR) and create or update a Personal Learning Record (PLR). We are required to do this by our funding body the Education Skills Funding Agency (ESFA) under the terms of the Apprenticeships, Skills Children and Learning Act 2009.

You do not have to give information about next of kin, although if you do not we won’t be able to contact anyone in the event of an emergency.

We share information with the ESFA, Department for Education and local authorities.

During your time studying with Independent Training Services Ltd./SmartStyle Training Ltd. (ITS)

We may record information about attendance, progress and achievement together with any work experience and placements you have undertaken.

Your data will be shared with other members of staff. We will use your personal data to help you with any issues arising from your programme of study.

Where we use external agencies to process data on our behalf, we require them to use a written agreement which guarantees confidentiality.

A list of these organisations and the reasons we share data is attached at Appendix A.

We may also collect details about your sexuality, religion, marital status and any gender change. We do this to ensure everyone has the same chance to succeed.

We will keep your personal details, qualifications, student ID number and outcomes indefinitely. This will allow us to confirm your attendance and achievement at Independent Training Services Ltd./SmartStyle Training Ltd. (ITS).

Photos/videos

We may wish to use images of you at Independent Training Services Ltd./SmartStyle Training Ltd. (ITS);

• to generate evidence towards your qualification(s)
• for use in Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) publications, publicity and other marketing materials, including social media sites

We will obtain and record your consent to do this. You are free to withdraw your consent at any time.

For Non-Government funded programmes

Most of the information collected at enrolment is required by us to deliver your programme/course. We use this information to create a delegate record.  

During your programme/course

We will record information about attendance and obtain your feedback post-programme/course.

During your programme/course your data will be shared with other members of staff. We will use your personal data to help you with any issues arising from your programme/course.

Where we use external agencies to process data on our behalf, we require them to use a written agreement which guarantees confidentiality.

We will keep your personal details and outcomes indefinitely. This will allow us to confirm your attendance and achievement with Independent Training Services Ltd./SmartStyle Training Ltd. (ITS).

Photos/videos

We may wish to use images of you at Independent Training Services Ltd./SmartStyle Training Ltd. (ITS);

• for use in publications, publicity and other marketing materials, including social media sites

We will obtain and record your consent to do this. You are free to withdraw your consent at any time.

Full details regarding how long we keep information is contained within our Data Protection Policy.

Section 2 - Employees

We hold the following data on staff and those who apply for roles with Independent Training Services Ltd./SmartStyle Training Ltd. (ITS):

• Personal data such as name, address, National Insurance number, employee number, phone number, next of kin and email address
• Special categories such as gender, age, disability, sexuality and ethnic group
• Contract information such as start date of employment, end date of employment, hours worked, post, roles and salary information
• Qualifications
• Previous employment
• References

Before making an offer of employment we will share information with the Government’s Disclosure and Barring Service (DBS) so that they can check whether you have any previous convictions which would make you unsuitable for working with children and young people. 

During your record of employment we will also keep:

• Bank Details
• Work absence information - such as number of days absent and reason
• Details of any professional development undertaken
• Disciplinary record

We use this information to:

• Enable you to be paid and the correct amount of deductions to be made
• Inform the development of recruitment and retention policies
• Obtain details on criminal convictions from the Disclosure and Barring Service
• Ensure the continued sustainability for your post

The lawful basis for collecting this information is derived from Article 6 of the General Data Protection Regulations, to allow us to meet contractual obligations and Article 9, allowing us to hold and process health data. There is also a legal basis under employment law.

If you apply for a post and are unsuccessful we will hold your information for 6 months after the closing date. This is to allow us to deal with any complaints or challenges.

If you are employed by Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) we will hold details of name, National Insurance number, start date of employment, end date of employment, role, and salary indefinitely to allow us to answer any tax or pension queries.

A fuller list of information retention periods is available in our Data Protection Policy

Sharing of Data

Your personal data will be shared with;

• Shorts Accountants - who are the Processor for the organisation’s payroll
• Westfield Health - for employees who join the Healthcare scheme
• Aviva – for pension purposes

Section 3 - Governors

We will collect the following information from you, which we need in order to carry out governance functions

Governors and Directors

Your full name, title, home address, contact telephone numbers, occupation, date of birth, date of appointment, whether you are a Governor or a Director of a subsidiary are required for the Statutory Registers for Governors and Directors. This information will be held securely and not made public.

Your home and mobile phone numbers will be held so that we can contact you regarding meetings and other relevant events. Your email address will also be held, however, other Governors and Directors will be able to see your email address when group emails are sent.

Disclosure and Barring Scheme (DBS)

Your name, current and previous addresses and date of birth. We will share this information with the Government’s Disclosure and Barring Service (DBS) so that they can check whether you have any previous convictions which would make you unsuitable for working with children and young people.

Register of Interests

Your current employment; appointments (voluntary or otherwise); membership of professional bodies, groups or organisations; conflict of interest details; any other interests not covered by the above.

We collect this information so that we can identify possible conflicts of interest, i.e. situations where your interests may (or may appear to) influence your decision making.

Photos/videos

Images of you (photos or videos) may be used in publicity material, such as adverts, information leaflets, newsletters, press releases or on the internet/social media (websites), to raise awareness of the services provided by Independent Training Services Ltd./SmartStyle Training Ltd. (ITS). These images will be stored in a database and may be used for publication (as described above) and will be viewed by the public.

Directors

Your name, title, role, date of appointment, your nationality, your date of birth, the number of appointments you hold, your address (which will be the company’s registered office address, i.e. Independent Training Services Ltd./SmartStyle Training Ltd. (ITS), not your home address) and your country of residence. This information will be shared with Companies House for the Company Register and published on the Companies House website. 

Legal framework

Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) is the Data Controller as defined in the Data Protection Act 1998.

Section 4 - Other Independent Training Services Ltd./SmartStyle Training Ltd. (ITS) Users

Visitors to our website

When you visit www.independenttrainingservices.co.uk we collect standard internet log information and visitor details. We do this to find out the number of visitors to different parts of the site.

We use Google Analytics to analyse the performance of our website and selected behaviours of our visitors.

You cannot be identified from the information we collect.

Complaints and Queries

We do our best to meet the highest standards in the collection and use of personal data. For this reason, we take complaints seriously and would encourage individuals to contact us where they believe that the collection or use of their information is unfair, misleading or inappropriate.

Please use these contact details for related correspondence.

Amendments

We keep our privacy arrangements under regular review and advise that you check our website from time to time.

For more information about your information rights, you may want to visit www.ico.org.uk

Appendix A

External Organisations we share learner/client data with