We are committed to protecting and respecting your privacy. This privacy statement explains what personal data we collect from applicants for apprenticeship and other training programmes (“Candidates”) and apprentices (“Apprentices”) and how we process it. Depending on the context, any reference to “you” and “your” refers to Candidates and/or Apprentices.
This privacy statement will be provided to Candidates and Apprentices. It may also be provided to employers of Apprentices (“Employers”) and prospective Employers, the Education and Skills Funding Agency (“ESFA”), the Office for Standards in Education, Children's Services and Skills (“Ofsted”), and any successor body to these organisations.
We are registered as a data controller with the Information Commissioner’s Office. We also collect and process personal data on behalf of Employers.
Our nominated data protection officer is Gordon MacLeod.
Candidates and Apprentices are under no obligation to provide us with personal information. However, we may be unable to assist the Employer with your application and subsequent in-work training if you do not provide us with sufficient information about you.
As we do not invite applications from Candidates directly, the initial information about a Candidate will come from the prospective Employer following which we may collect additional personal information from you. The information we receive from the prospective Employer or collect from you may include your title, name, date of birth, gender, how long you have been resident in the EU, ethnicity, learning and/or health problems, whether you have ever been in care, whether you have an education, health and care (also known as EHC) plan, qualifications, apprenticeship aims, functional skills and your prospective Employer’s details. We will also obtain your unique learner ID number for funding, either from you or, if you do not have it, from the UK Government Gateway.
We will also ask for your preferences for further communications (about courses or learning opportunities, surveys and research) and your preferred methods of contact (post, telephone, email, SMS).
We will also seek your consent for the use of images and video and sound recordings containing your personal data.
If you commence a training programme we work with we may also collect additional personal information about you, either directly from you or via your Employer, including the details of the address at which you work, your manager and workplace mentor, details of your placement, your employer record number (also known as ERN) and other learner information such as the details set out in the commitment statement which is provided to you at the start of your training, your individual learning plan (also known as ILP), progress reports and college reports.
Except as mentioned above, it is not our policy to seek special category personal data (previously known as “sensitive personal data”), for example information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, data concerning your physical or mental health, sex life or sexual orientation, information. We shall only collect this information from you with your express consent. We therefore suggest that you do not offer this information to us unless we specifically ask you to do so.
If you provide us with information about any criminal convictions we shall use it only in accordance with the laws governing the use of such information.
We will use the personal information we have collected to facilitate the recruitment and training services we provide.
If you are a Candidate we may use your personal information for the following purposes and on the basis that we have a legitimate interest in doing so, i.e. in order to provide recruitment services to your prospective Employer (or, in the case of any special category personal data, you have consented to us doing so:
We may also use such information for internal administration and reporting on the basis that this is compatible with these primary purposes.
If you have consented to us communicating with you (about courses or learning opportunities, surveys and research) and/or using of images and video and sound recordings containing your personal data, we will use your information for those purposes. You may withdraw your consent to such use of your information at any time by emailing us at firstname.lastname@example.org
If you are an Apprentice we may use your personal information to provide our services to your Employer (namely managing, administering and assessing your training and dealing with its funding) and to support you through your learning journey. This will include sharing your personal information with your mentor and Ofsted, so that Ofsted can review your prior attainment and the progress you make through your learning journey against its framework standards. We do so on the basis of our contractual obligations to your Employer and our legal obligations to the ESFA and Ofsted.
We may also use such information for internal administration and reporting on the basis that this is compatible with those primary purposes.
Whilst we will try to ensure that your personal information is maintained and up to date, please inform us if you become aware of any inaccuracies.
The personal information you provide us will be passed to the Department of Education (“DfE”) and the ESFA, both of which are based in the United Kingdom. The information is used by the DfE to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique learner number (ULN) and a personal learning record (also known as PLR). Your information will be securely destroyed after it is no longer required for these purposes.
Your information may be shared by the DfE with third parties for education, training, employment and well-being related purposes, including for research. This will only take place where the law allows it and the sharing is in compliance with data protection legislation. We may share your information with such third parties but only if have a legal obligation to do so (e.g. where instructed by the DfE).
The European Social Fund English Managing Authority (the Department for Work and Pensions (also known as DWP)), or agents acting on its behalf, may contact you in order for them to carry out research and evaluation to inform the effectiveness of training that you receive through your apprenticeship.
Further information about how the DfE and other government organisations use and access your personal data, please visit: https://www.gov.uk/government/publications/sfa-privacy-notice.
We may also disclose your personal information in the following circumstances and on the basis that we have a legal obligation or a legitimate interest to do so:
The personal information we hold about you is stored using the following means:
We will not transfer or store your personal information outside the European Economic Area.
We would remind you that the transmission of information via the internet is not completely secure and whilst we will do our best to protect your personal information, we cannot guarantee the security of any data which is transmitted to us, whether by email, mobile devices or via our website.
We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
The table below sets out further details:
|Circumstances in which personal data was provided||How long do we keep it?|
|If you are a Candidate||7 years|
|If you have consented to us communicating with you about courses or learning opportunities, surveys and research||Until you withdraw your consent or we deleted the data as part of our periodic data cleanse|
|If you have consented to us using of images and video and sound recordings containing your personal data||Until you withdraw your consent or we deleted the data as part of our periodic data cleanse|
|If you are an Apprentice||7 years|
You have the right to:
You have the right to complain to the Information Commissioner. You can do this by contacting the Information Commissioner’s Office directly about the way in which we collect and use your personal information. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.