Privacy Notice

Babcock Training Limited

Privacy Notice for Learners / Apprentices

© Babcock

Issue Date: 25.05.18

D714/1

As part of our ongoing commitment to keeping you informed, here is our Privacy Notice which sets out how we store and use your information. We encourage you to read the Privacy Notice in full.

OVERVIEW

Babcock Training Limited (“Babcock Training”)’s mission is to be recognised as providing first class quality training, support and development to employers and learners across a wide range of sectors.

Through high quality delivery of training and working in partnership with employers and Government bodies, Babcock Training aims to support employers to develop their businesses and improve the work skills of young people and adults across the UK.

Babcock Training strives to influence positive change and ensure that all training, including Government funded provision, is employer-led and employer-focused.

Babcock Training is committed to protecting your personal information in accordance with applicable data protection law. This Privacy Notice applies to all learners and/or apprentices who receive or are due to receive training, learning support and developmental support from Babcock Training. Such learners and/or apprentices are referred to in this Notice as “learners” or “you”.

This Privacy Notice describes how your personal information is collected, processed and used by Babcock Training, during and after your relationship with us, and for what purposes your information is held.

This is a policy document and does not have contractual effect. We may update or amend this notice at any time.

WHY AND HOW DO WE COLLECT YOUR INFORMATION?

Babcock Training is one of the UK’s largest private sector apprenticeship providers, delivering approximately 20,000 apprenticeships to young people and adults across a wide range of sectors.

We collect personal information about learners through contacting employers of potential learners, contacting potential learners themselves, advertising and filling vacancies, and enrolling learners on apprenticeships. We therefore receive personal information, either directly from learners or from their employer.

We may also collect personal information about you in the course of training and apprenticeship support and learning activities.

Collecting your information and recording your progress allows us to support learners to achieve their chosen qualifications, and enables us to manage the funding of the apprenticeships. The personal information below is collected by us for the purposes described in more detail below.

LEGAL BASIS FOR PROCESSING YOUR DATA

Babcock Training may collect, store, use and share information about you in order to carry out our activities and obligations as a learner and apprentice training provider.

In particular, we will process personal data for the purposes of complying with legal obligations, performing the contract we have entered into with you or your employer, pursuing our legitimate interests (or those of a third party), where you have consented to it or where the law otherwise permits or requires it.

Babcock Training processes the information of employers and learners in pursuit of its legitimate interests including in:

• supporting learners to achieve their chosen qualifications;

• carrying on our business as a provider of training and related services; and

• managing the funding of the apprenticeships.

We may also use your personal information where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest, but this is likely to be rare.

Where we process data in order to perform contracts with our customers (e.g. your employer), we will generally process data as a data processor. In other circumstances, we may process some data as a data controller.

WHAT INFORMATION DO WE HOLD?

In order to fulfil the purposes outlined above, we have a database, which holds password protected personal data collected by Babcock Training during the course of its relationship with employers and learners. The database is hosted in a secure data centre, and held on servers that are administered by Babcock Information Services.

Personal information may include:

• Personal identifiers and biographic information consisting of your learner number, name, date of birth, title, gender;

• Family, spouse and partner details;

• Your contact details including postal addresses, e-mail addresses and telephone numbers;

• Information about your time at school, college, university;

• Your employment details;

• Your current interests;

• Records of communications sent to you by Babcock Training or received from you;

• Your communication preferences;

• Records of your attendance at Babcock Training events;

• Notes of meetings that you have had with Babcock Training staff; and/or

• Education and training records (including attendance records).

Please note, Babcock Training does not collect or store credit/debit card details.

Special categories of personal data (e.g. relating to health records or learning disabilities) will only be held or processed:

• where you have consented to it;

• if necessary for the purposes of performing or exercising obligations or rights which are imposed on an employer or employee in connection with employment (e.g. to determine the level of educational support required);

• if necessary for the establishment, exercise or defence of legal claims;

• If necessary for the purposes of preventive or occupational medicine, and/or for the assessment of working capacity; or

• to ensure compliance with our legal obligations.

We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

We will usually only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally permitted to do so.

HOW DO WE USE YOUR DATA?

We use your data for a number of training activities including:

• providing services, including access to a number of third party hosted learning support platforms;

• conducting surveys, including research on the support we provide;

• internal record keeping, including the management of feedback or complaints;

• requesting funding from the relevant funding body; and

• administrative purposes and operational support (e.g. in order to process apprenticeships, traineeships, qualifications).

• unless otherwise identified, to contact you to offer services linked to apprenticeships we understand may be of interest. This may include contacting employers to offer apprenticeship recruitment services for new and existing staff and contacting individuals who have registered their details with us to discuss apprenticeship opportunities.

We will only share your personal information with the following third parties for the purposes of providing training and apprenticeship support and learning activities: your employer, the relevant funding body (and other relevant government bodies), our suppliers and their sub-contractors.

We may share your personal information with other entities in our group, for example for system maintenance support and for hosting of data.

We may also share your personal information with other third parties, for example if a business transfer or change of business ownership takes place or is envisaged or if the provision of services is transferred to a third party service provider. In addition, we may need to share your personal information with a regulator or otherwise to comply with the law.

DATA RETENTION

We will hold your data on our systems for as long as is necessary for the relevant activity. If you exercise a right to erasure, we will retain a core set of personal data where permitted by applicable data protection law which will include your name, email and unique identification number so that we do not contact you inadvertently in future.

We will always respect a request by you to stop contact by any or all methods of communication, or for any specific purpose, unless we have another legal justification to continue doing so under applicable data protection law.

The only exception to the data retention periods mentioned above is where the law requires us to hold your personal information for a longer period or delete it sooner, or where we need to retain it in order to defend or exercise legal claims.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

YOUR RIGHTS AND CHANGES TO THIS POLICY

You have the right in certain circumstances and subject to certain conditions to:

• access the personal data held about you;

• have your personal data rectified if it is inaccurate or incomplete;

• request that we remove your personal data;

• restrict the processing of your personal data, for example, ask us not to contact you;

• object to the processing of your data for specific purposes such as communications or direct marketing;

• ask for the transfer of your data electronically to a third party (known as the data portability right); and

• lodge a complaint with the Information Commissioner’s Office.

Under data protection legislation these rights generally apply in relation to the relevant data controller. To make a request for your personal information or to exercise any other of the rights referred to above, please contact the Data Protection Officer of the relevant data controller, which in your case is likely to be your employer.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Babcock Training will not sell your data, except as envisaged by this Privacy Notice or as we otherwise tell you at the time. We will also not share your data with anyone to use for their own purposes unless disclosure is permitted or required by law.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

CHANGES TO THIS POLICY

This Privacy Notice was updated in May 2018. It will be reviewed periodically and we will communicate any changes we made to this Privacy Notice.

We reserve the right to update this Privacy Notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

CONTACT

If you have any questions about this Privacy Notice or wish to amend the information we hold about you, please do get in touch and we will be happy to help:

The Data Protection Officer, Babcock Training Limited, 1000 Lakeside North Harbour, Western Road, Portsmouth, Hampshire, PO6 3EN.

© Babcock 25.05.18