GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Facts Training SV Limited trading as The First Aid Team, J I Training, Facts Training and Driveline Training (“We”) are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”) and Data Protection Act 2018 (the “DPA”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third-party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
Facts Training SV Limited (a company registered in England and Wales with number 11590440) t/a The First Aid Team and or J I Training and or Facts Training and or Driveline Training is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:
Telephone: 0333 123 1160
Post: Tranquil Cottage, Broad Street, Sutton Valence, Kent, ME17 3AJ.
For all data, matters contact Jeremy Hinchliffe on 0333 123 1160
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To record, process and manage any enquiries from you
- To record, process and manage any course bookings, event bookings or sales of first aid and ancillary equipment
- To record, process and manage any accounts related information including, if necessary, debt management through third parties
- To record, process and manage the details of your attendance on a training course whether regulated or unregulated and irrespective of outcomes
- To advise the awarding body of your name and attendance on a training course as well as the outcome of that attendance. Where required by the awarding body we may also disclose your date of birth, driver number for CPC courses and, where it impacts on the assessment process, details of any learning, physical or health difficulties where you have disclosed these to us
- To send reminders about the expiry of First Aid and other qualifications both before and after the expiry date
- To enable us to verify your attendance on a First Aid or another course where requested by a third-party but only after we have your express written (including via email) permission.
- To send newsletters and updates about First Aid and CPC related matters.
- To send marketing materials about First Aid, CPC and related courses
- If we purchase goods and services from you
- From promotional purposes including, but not limited to, any written or verbal feedback about our courses; any video testimonials you make; any testimonials you leave on the Internet such as Google reviews.
- If you work for us in any capacity whether as an employee or external contractor, then we will record your details to ensure you remain fully and appropriately qualified for the role that you fulfil.
- If you become ill or injured either on a course or if you become ill or are injured at events where we are providing event cover.
- The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Date of birth
Address (both work and personal)
Email address or addresses
Your attendance on a course
The type of course
The outcome of your attendance including advising your employer of outcomes where you attend a course at their behest
The expiry dates of any certificates
Any restrictions on your ability to fully participate on a course
Details of any injuries or illnesses that occur on a course or where we provide treatment at an event where we are contracted to provide event cover
For CPC courses only we will also process and store:
Your driver number
Your driving entitlement categories
A copy (front and back) of your driving licence or DQC card or Digital Tachograph
We have obtained your personal data from a number of sources:
- You have given your information to us when purchasing goods or services from us
- You have given us your information when you contact us
- You give us your information when taking part in a course we’re running
- You give us your information when we provide first aid treatment or assistance, whether at an event where we are providing First Aid cover or on one of our courses.
- We also obtain information about your business contact details or role within a business from Kent Libraries which is publicly available information available to any business based within the Kent County Council Local Authority Area
- What is our legal basis for processing your personal data?
a. Personal data (article 6 of GDPR)
- Our lawful basis for processing your general personal data:
|Consent of the data subject
||You give us your express consent to contact you
|Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
||You purchase goods or services from us.
We purchase goods or services from you.
You attend a training course with us
|Processing necessary for compliance with a legal obligation
||We record and retain your details to meet our obligations under tax legislation
We record and retain your details to demonstrate your attendance on a course with us and the outcome of that course. We record and retain details of any injuries or illnesses you suffer and treatment or advice given whilst on a course or where we are contracted to provide First Aid cover at an event
|Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
|It is a legal requirement that all businesses have adequate and appropriate First Aid provision within their workplaces; this includes (as appropriate) trained First Aiders, First Aid kits and other equipment as required.
Owners and operators of commercial vehicles are required to ensure that all their Drivers and certain specified staff are in possession of a DQC card
As a First Aid & CPC Training Company and supplier of First Aid equipment we consider it in our legitimate interest to keep businesses aware, irrespective of size, of the training courses and products that we offer via email as this information may assist you in meeting your legal requirements.
If you work for us whether as an employee or a contractor we will retain your details on file including copies of any qualifications and their expiry dates to ensure you remain appropriately qualified for the role you are being asked to fulfil. This information will be retained for a period of 7 years after your last engagement with us to comply with both tax legislation and to allow for the possibility of any legal action being taken against us as a result of your work for us
- Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with:
- The awarding organisation, Qualsafe Awards, with whom we are registered for the purposes of issuing your First Aid Certificate. Normally, this is restricted to your first and last names but, occasionally, may include items such as your date of birth and details of any special assistance given to you, with reasons, to enable you to complete a First Aid course.
- The appropriate regulatory authorities for CPC courses, in particular, JAUPT and DVSA with whom we are registered for the provision of CPC courses. This is normally confined to your Driver Number.
- The person who booked a training course with us that you attend, typically your employer, to confirm your attendance on the course and outcomes. If you do not attain the required standard, then the reasons for not awarding the qualification will be disclosed as appropriate.
- Where we are required to so do either by law or after due process of law
- Where we use your details for marketing and promotional purposes, where you give us feedback, for instance, this will be anonymised unless you give us express permission to identify you or you publicly identify yourself. By anonymised we mean, for instance, Miss CP of Maidstone
Where we share your data with a third party we confirm that we have appropriate contracts and safeguards in place to ensure the security of your personal data.
- How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data:
1) If you purchase goods or services from us we will retain your data for no more than 7 years from the last date of purchase to confirm with our obligations under tax legislation and to promote the continued sale of further goods and services
2) If you attend a course with us we will retain your data for 6 years from the date of your last course so that we may notify you of the expiry date of any certificates we hold for you and, if requested and with your permission may confirm to an enquirer as to the type of course attended and when. We will also use your data to contact you about other courses and general First Aid & CPC information
3) If you work for us whether as an employee or as an external contractor your data is principally held so that we can ensure your relevant professional qualifications remain current including information about your right to work in the United Kingdom as required by the Immigration, Asylum & Nationality Act 2006. We also require and retain a copy of an Enhanced DBS check taken within the last 3 years. Your personal data will be retained for a period of 7 years to confirm to both tax legislation and to allow for the possibility of legal action being taken against us as a result of work undertaken by you on our behalf
4) If we hold your data purely for the purposes of direct marketing then this will be retained for no more than three years from our acquisition of the data unless you purchase goods or services from us in that time span in which event we will then continue to hold your data for the time spans detailed at 7.1 and/or 7.2 above
- Providing us with your personal data
If you attend a First Aid training course with us then you must provide us with your name, date of birth and proof of identity as a condition of your attending our course. This information is a requirement of our regulatory authority Qualsafe Awards and, ultimately, Ofqual and is designed to minimise the risk of impersonation. If you do not provide this information you will not be allowed to join the course. The provision of any additional information beyond this is at your discretion and failure to do so will have no impact on outcomes unless we notify you otherwise
If you attend a CPC training course with us then you must provide us with your name, proof of identity which (as specified by JAUPT and DVSA) must be either a current photocard driving licence or a current Driver’s Qualification Card or a current Digital Tachograph. We will take copies of the front and back of these and retain this information as required by the Regulatory Authorities
If you work for us whether as an employee or contractor, then we require appropriate documentation to confirm your entitlement to work in the UK. We also need copies of any relevant professional qualifications germane to your role with the Company, including copies of any professional insurances. If these are not provided or kept current, then you will not be able to work for us.
If purchasing goods and services from us, then we require sufficient information from you to enable us to provide and deliver these including information on payment methods. If paying by credit or debit card, no card information is stored by us once the transaction has been authorised by the card processing company.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time where consent was our lawful basis for processing your data except where we are obliged to retain this for legal purposes
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable, i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data where we rely on the Legitimate Interests, and we do not need to retain that information as required by Law
- Transfer of Data Abroad
We do not transfer personal data outside the EEA.
- Automated Decision Making
We do not use any form of automated decision making in our business.
- Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
- How to make a complaint
To exercise all relevant rights, queries, or complaints please in the first instance, contact Jeremy Hinchliffe by email to firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.