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Privacy and Data Protection Policy; Training Courses
1. Introduction; General Policy and Scope
This Policy sets out our commitment to complying with the EU General Data Protection and domestic Data Protection Regulations. It specifically covers the training activities of the RedCat Partnership Ltd, i.e. the marketing, booking, administration and updating of the training courses we deliver.
Other Policies will cover our other principal trading activities;
• Business consultancy services
• Our activities as an employer
• Our activities through trading as No8 Thorpe Road (co working space,
meeting/training space provision, etc).
We recognise and respect the value of data we hold, and what it means to our customers, clients, colleagues and staff. We respect the legal requirements and will actively seek to fully comply with the requirements, in a suitable and proportionate manner.
This revision has been made to accommodate the EU GDP Regulations Signed;
  Sarah Daniels, Director 1st May 2018
Date for next review; 1st January 2019
Richard Mills, Director 1st May 2018
Privacy and Data Protection Policy Rev1 May18
8 Thorpe Road, Norwich, NR1 1 RY Registered Company No. 4306733
Page 1 of 5 ww.redcatpartnership.co.uk Registered Office; 8 Thorpe Road, Norwich NR1 1RY
2. Data We May Hold, the Processes We Undertake, its Purpose and Legitimacy
   What Data Will We Hold?
       Processing
      Why Is This Data Necessary? The lawfulness of the data retention is highlighted in BOLD
   Name, address, telephone number and email address of an enquirer
    Enquiries about or training courses, and our follow-up
    So we can answer customer’s enquiries regarding training courses, send information and booking details.
This data is provided with the customer’s CONSENT
    Name, address, telephone number and email address the delegate
 Booking onto training courses; a booking form is retained, and information from this is transferred to a Course Summary Sheet
 So we can complete our CONTRACT to provide the training services.
Our contractual obligations will include;
• Providing joining instructions
• Providing training material
• Sending certificates, etc to you, either
electronically or by post.
• Contacting the delegate urgently, e.g. a training
course has been cancelled or moved at the last
minute.
• Invoicing
    Date of birth
     So we can complete our CONTRACTUAL OBLIGATIONS and LEGAL OBLIGATIONS to some of the Awarding Organisations. These AOs require this data for security, as the issue of RQF qualification certificates is known to be affected by “black market” criminal activities
    Emergency contact details
       If the delegate is taken ill during a course, we will need to contact whoever the delegate requires us to. We consider this to be in the data subject’s VITAL INTERESTS.
     Dietary requirements
    Refreshments are available at all times in our training facilities, and we need to be aware of any allergies, intolerances or religious requirements that affect delegates’ choice of refreshments. We consider this to be in the data subject’s VITAL INTERESTS.
     Learning needs
  In order to make our training relevant and as accessible as possible to delegates, it helps us make the necessary adjustments to our training delivery and secure the best learning outcome for the delegate. We consider this to be necessary to meet out LEGAL OBLIGATIONS under the Equality Act.
   Financial information; payment card details
       Payment
      To complete our CONTRACT, we take card payments through iZettle; the card machine is either contactless or the customer inserts their card and personally enters details such as PIN. We do not at any point hold or retain any of the card or Pin details. We do not ourselves actually directly hold or process data.
  Privacy and Data Protection Policy Rev1 May18
8 Thorpe Road, Norwich, NR1 1 RY Registered Company No. 4306733
Page 2 of 5 ww.redcatpartnership.co.uk Registered Office; 8 Thorpe Road, Norwich NR1 1RY
   Financial Information; payee details on our invoices (name, address, email, organisation/ employer)
       Accountancy
      So we can complete our LEGAL OBLIGATIONS, we retain Invoices in our accountancy system, Xero, as required by UK financial and taxation law.
   Name and email address the delegate
   Updating
  In the delegates’ LEGITIMATE INTERESTS, we will use periodic bulletins to inform them of;
• Events, legal cases or other changes that may affect the delegates’ abilities to comply with their legal requirements (i.e. keeping them up to date with compliance issues)
• To notify delegates of the expiry of their certificate, or the AOs recommended intervals for refresher training
 3. Data Retention
a. Enquiries; if the enquiry does not convert to a booking, then data will be deleted after 1 month maximum
b. For Highfield Awarding Body courses; we are obliged to keep data for three years
c. For IOSH courses; we are obliged to keep data for 1 year
d. For updating purposes; data retention is ongoing
4. Data Security and Storage by The RedCat Partnership
Our data is primarily stored on our Microsoft One Drive for Business cloud-based storage, and the reader is referred to Microsoft’s security provisions.
Some data is mirrored onto local computer drives, for when we are delivering training off-site and without internet access to the Cloud storage. All devices through which the data is accessed, are password-protected. Computers include anti-virus programs, either commercial level Avast (formerly AVG) or Microsoft Windows 10 proprietary protection. Devices are allocated to individuals, who are made clearly responsible for their security.
Privacy and Data Protection Policy Rev1 May18
8 Thorpe Road, Norwich, NR1 1 RY Registered Company No. 4306733
Page 3 of 5 ww.redcatpartnership.co.uk Registered Office; 8 Thorpe Road, Norwich NR1 1RY
5. Sharing Data
    Data We Share
   Shared With Whom, and How.....
     Why?
    Name, date of birth, gender, ULN, email, telephone
Highfield Awarding Body (HAB). Uploaded to HAB website on an MS Excel Spreadsheet for Workbook assessed courses
  Highfield requirement, as part of RQF regulation for security
    Name, date of birth, gender, ULN,
   Highfield Awarding Body. Provided on paper examination Answer Information Sheet, and posted to HAB
     Highfield requirement, as part of RQF regulation for security
    Name
Institute of Occupational Safety and Health (IOSH)
Emailed in a Course Results MS Excel Spreadsheet to IOSH
  IOSH contractual requirement (they are not an RQF accredited AO)
    Name, email address
 Smart Messenger
Uploaded to their secure server
    To send out update information using Smart Messenger message templates
    Invoice details
    Xero accountancy services
     Financial records
  6. Date Subjects’ Rights
a. The right to be informed. Each individual has the right to be given information about how their data is being processed and why. RedCat has provided this policy to show how we handle your data.
b. The right of access. RedCat has a duty to comply with the requirements of Subject Access Requests (SAR)
c. The right to rectification. The GDPR includes a right for individuals to have inaccurate personal data rectified or completed if it is incomplete.
d. The right to be forgotten. You have the right to ask RedCat to remove your data.
e. The right to restrict processing. You may restrict processing for a legitimate reason, we would still have the right to hold that information, e.g. as required by Awarding Organisations or financial regulations
f. The right to data portability. You may be able to obtain the information we hold about you and use it for your own purposes. Conditions apply.
Privacy and Data Protection Policy Rev1 May18
8 Thorpe Road, Norwich, NR1 1 RY Registered Company No. 4306733
Page 4 of 5 ww.redcatpartnership.co.uk Registered Office; 8 Thorpe Road, Norwich NR1 1RY
Should you wish to exercise any of your rights above, please email enquiries@redcatpartnership.co.uk stating the following information:
• Name
• Contact details
• Relationship to Subject
• Full details of information relating to your request Reason for request and the right
being exercised.
You will be asked to verify your identity if you are the subject alternatively you will be asked to provide consent from the subject if you are a representative.
Should we require further information we will contact you.
Your request will be dealt within one month of receipt of your request.
7. Review
This policy will be reviewed annually, or upon any significant change to our data collection, processing or sharing activities.
 Privacy and Data Protection Policy Rev1 May18
8 Thorpe Road, Norwich, NR1 1 RY Registered Company No. 4306733
Page 5 of 5 ww.redcatpartnership.co.uk Registered Office; 8 Thorpe Road, Norwich NR1 1RY