We collect personal information from you:
through the use of forms, which may be on paper or on our Websites, such as when you login to access our Services, signup to receive our newsletters, register for information, make a purchase or commence a course of study;
- when you create an account on our Websites and provide us with information about any special requirements, such as dietary requirements that you may have;
- if you choose to provide us with information when you use any of our Website or access our Services;
- when you communicate with us for any reason, including by email, postal mail or telephone, and when you use our Services.
- We may also process your data in relation to COVID-19 or within other crisis management activities.
- Some of the personal information that you provide may include sensitive personal information, such as health-related information to ensure that we can provide the necessary duty of care or information about your race or ethnicity, which we need for statutory registration/reporting purposes. Health information may also be required to process reasonable adjustments within examinations.
Information we obtain from third party sources
We may receive personal information about you from third party sources (such as your employer if they enrol you on a course), or agencies if you apply for study or employment, but only where we believe that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We collect only the minimum amount of information required from these third parties to enable us to provide the requested service or process any application you send to us (for example, your educational or employment history). We only use the information we receive from these third parties as set out in this Privacy Notice.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What are your Rights?
Under the GDPR, you have the following rights, which We will always work to uphold:
- The right to access the personal data We hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
Date of birth
Information about your preferences and interests
How do we use your personal data?
The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:
- to provide you with information or Services you request from us;
- to provide information on other Smart Move Education Group products and Services which we feel may be of interest to you, in accordance with your communications and consent preferences;
- to meet our contractual commitments to you;
- to act on your behalf where third party involvement is available and appropriate – for example through a third party specialist training provider or certification/awarding body;
- To comply with the applicable legislation surrounding COVID-19 test and trace or other crisis management schemes;
- to obtain additional personal information to secure funding or satisfy statutory legal or Government scheme requirements – for example through an Apprenticeship scheme;
- to monitor and analyse trends, usage and activities in connection with our Websites/Services; and
- as necessary to prevent or detect crime.
We may also monitor or record telephone calls for training, customer service and quality assurance purposes, and to detect or prevent crime. These recordings will be retained for a maximum of 30 days.
In general, we will use any of the information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect such information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.
If you do not want us to use your data for any marketing purposes, you will have the opportunity to withhold your consent to this when you provide your details to us.
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will OR may be used for one of the following purposes:
Providing and managing your Account
Providing and managing your access to our Site
Personalising and tailoring your experience on our Site
Supplying our products AND services to you. Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring our products AND services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking unsubscribe button in our email or contacting us via email.
Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that We take on the basis of this or wish to request ‘human intervention’ (i.e., have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
How long will we keep your Personal data and store?
We will not keep your personal data for any longer than is necessary for the light of the reason(s) for which it was first collected. Your personal data will, therefore, be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept. We keep your personal data in our personal server and we use it with your concern.
How and where do we Store or transfer your personal data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We share your data within the group of companies of which we are OR I am a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are OR are applied to such transfers:
We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Where We transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
Do we share your Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are OR I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for our marketing purposes. This includes subsidiaries AND/OR our holding company and its subsidiaries.
We may sometimes contract with the following third parties to supply certain products AND/OR services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that We hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are OR I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority
Disclosing your information
We may disclose your personal information to any company within our corporate group. This includes, where applicable, our subsidiaries, our holding company and its subsidiaries. This will only be done where lawful bases exists.
We will also disclose, where required, your personal information with:
- third party service providers and partners who provide data processing services to us (for example, to support the delivery of Services), or who otherwise process personal information for purposes that are described in this Privacy Notice;
- your employer, where they have instructed us or funded the goods or services provided to you. This may include progression, assessment, attainment or exam results as well as other personal data as and when required.
- With exam certification bodies where reasonable adjustments are required on health grounds
- a third party where they have funded the services that we deliver to you or your organisation.
- any product evaluation or feedback comments you provide may be shared with the purchasing organisation or course vendor.
- NHS or other authorised government agencies in connection with COVID-19 containment or other crisis management scenarios;
- government agencies, where required by the scheme or education path you elect to follow;
- partners with whom we work to provide Services (such as course vendors, examination bodies, customer suppliers and trainers);
- other commercial organisations with regards to potential work placements or provision of, or attendance at, employment fairs;
- any third party in connection with, or during negotiations of, any merger, sales of company assets, financing or acquisition of all or a portion of our business by another company;
- any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation (and may not be able to inform you so as not to compromise any investigation or other proceedings), or otherwise to protect our rights or the rights of any third party; and to
- any other person with your consent to the disclosure.
Where you are a customer or prospective customer, we may disclose your data to third parties for our marketing purposes so that we can identify products and services we think you will be interested in. Personal data used in this way may include contact details such as name, address, phone number, and email address. When sharing with third party marketing organisations, your data may be processed in countries inside or outside of the European Economic Area (EEA).
Third party links
You might find links to third party websites on our Websites or within documentation we provide.
If you access other websites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their own Privacy Notices which you should review.
We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
The Website may offer you the opportunity to share or follow information about us (or the Website or our Services) using third party social networking functionality (such as through “share this”, “like” or “follow” buttons).
We offer this functionality in order to generate interest in us, the Website and our Services among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through Internet search engines.
Please note that we do not exercise, endorse, secure or control the policies or practices of any third party social network whose functionality you may access through the Website.
You should always carefully read the Privacy Notice of any social network through which you share information in order to understand their specific privacy and information usage practices.
Smart Move Education Group, 25-27 Nile Business Centre, 56-60 Nelson street, London E1 2DE