Studyflex Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and suppliers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law
1. Information About Us
registered in England under company number 05141119
Registered address: 118 Pall Mall, London SW1Y 5ED
VAT number: 846406812
Data Protection Officer: Lisa Rust.
Email address: firstname.lastname@example.org
Telephone number: 0207 1010 720.
Postal Address: 118 Pall Mall, London SW1Y 5ED
We work with the Chartered Management Institute as the Awarding body who verify qualifications and award certificates, with OFQUAL as the regulatory body and receive funding from the Education and Skills Funding Agency
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. 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.The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) 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 11 to find out more.
d) 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 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) 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.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
i) 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 11.
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.
5. What Personal Data Do You Collect?
We may collect some of all of the following personal data, although this is not an exhaustive list, and may vary according to your relationship with us.
- Date of birth;
- Email Address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- National Insurance Number;
- Education History;
- History of previous purchases/services provided to you;
- Correspondence and communications with Studyflex
6. How Do You Use My Personal Data?
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 may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you and fulfil the delivery of that contract to you.
- Personalising and tailoring our 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 sending an email to email@example.com advising you wish to opt out.
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, telephone, or post with information, news, and offers on our 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.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in 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 will keep your details and the documents or files associated with your learning programme for the length of time dictated by the regulatory body and the Awarding Body, this may be increased by one year if files are selected by auditing by external quality assessors
- Any financial documentation relating to funding of your programme must be retained for the period set by the funding body e.g.Education and Skills Funding Agency – this is usually for 10 years after the financial year end in which the programme ends.
- If you have agreed to be sent information regarding our services and products those details will be retained until you opt-out of receiving the information. You can do this by contacting us as detailed in Part 11.
8. How and Where Do You Store or Transfer My Personal Data?
We are committed to keeping your personal data safe and secure. If we are informed of a data breach we will inform the Information Commissioners Office and yourself if your data is involved within 72 hours.
We transfer personal data to third party processors outside the European Economic Area only after taking such steps as are required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in the EEA. Where processors are located outside the EEA either they are certified as compliant with the EU-U.S. Privacy Shield Framework (where they are located in the USA) or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA
9. Do You Share My Personal Data?
We will need to share the information that we hold about you such as your personal details, education details, employment details, achievements with:
- Awarding Bodies who verify your qualification and award your certificate such as the Chartered Management Institute
- Funding agency’s such as the Education and Skills Funding Agency
- Delivery teams
There may be occasions where we are legally required to share information with statutory agencies such as the Police, Local authorities, Courts or HMRC – this may be in relation to Safeguarding risks, criminal, civil proceedings or fraud. Information can be shared without your consent in these circumstances.
There may be other occasions when we are requested to provide information we hold on you and we will seek your explicit consent to do this.
We will not sell, distribute or release your personal information to third parties unless we have your permission or are required by law to do so.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. You will need to provide your full name, date of birth and current address and a copy of identification e.g driving licence/passport or Birth Certificate.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Telephone number: 0207 1010720
Postal Address: 118 Pall Mall, London, SW1Y 5ED.
12. Changes to this Privacy Notice
Any changes will be made available via this notice at studyflex.com/privacy-notice
Website Access & Usage
Personal data information
Users may visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal data information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
How we use collected information
StudyFlex collects and uses Users personal information for the following purposes:
- To improve customer service – your information helps us to more effectively respond to your customer service requests and support needs.
- To administer a content, promotion, survey or other site feature – to send Users information they agreed to receive about topics we think will be of interest to them.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sharing your personal information
We do not sell, trade, or rent Users personal data to others. We may share generic aggregated demographic information not linked to any personal data regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
StudyFlex Limited, 118 Pall Mall, London, SW1Y 5ED
0207 1010 720
This document was last updated on May 20th, 2018