General Data Protection Regulation (GDPR) 2018
Privacy Notice LPG Training
LPG Training is committed to data security and the fair and transparent processing of personal data and we have produced thisPrivacy Policy for you to download.This privacy policy (Policy) sets out how we will treat the personal data which you provide to us incompliance with applicable data protection law, in particular the United Kingdom General Data Protection Regulation (UK GDPR).
Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and sharepersonal data, your rights in relation to your personal data, how to contact us and supervisory authorities in the event that you wouldlike to report a concern about the way in which we process your data.
This Privacy Policy should be read in conjunction with our websitecookies policy.
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General Data Protection Regulation (GDPR) 2018 Privacy Notice LPG Training
- Who we are, what we do:
- What we don’t do
- Protection of Data and Information
- We collect personal information
- Personal information we collect and use
- How and why will we use personal information?
- Sharing of personal data
- Transfer of Data
- Our Website
- Personal Data and Information
- Lawful Basis
- Letting us know if your personal information is incorrect
- What if you want us to stop using your personal information?
- Individuals can ask us to restrict the use of their personal information
- How to complain
- Learner personal data which maybe held by us and or at an Approved Centre on our behalf
- Personal Data of Teachers, Assessors and Internal Verifiers (Employees of Approved Centre) which maybe held by us and or Approved Centre on our behalf
1. Who we are, what we do:
LPG Training specialise in designing, delivering vocational & technical managed learning programmes and qualifications.
Note: In this notice the use of; we, our, us is to be read as meaning LPG Training. We design, develop and deliver examinations and
assessments and award qualifications to learners.
We also award non regulated qualifications which are designed and approved by us and delivered by us and our Approved Partners. Details of all qualifications are published on our website.
To comply with qualification regulatory or accreditation requirements and for our own legitimate business interests we collect and
retain personal data and information relating to the managed learning programme or qualification for which learners have applied for
and been registered to undertake.
We also collect and retain personal data relating to those persons who have taught, examined, assessed or quality assured the
learning and qualification processes.
We collect and retain personal data and information on the people we employ
2. What we don’t do
We do not send unsolicited information by electronic or other means to individuals to advertise or promote our products and services.
3. Protection of Data and Information
We are committed to providing the highest standards of protecting personal data and information in accordance with the
requirements of the GDPR.
This privacy notice sets out how we use and protect any data and information that is provided to us via an Application Form or that
our Approved Partner provides to us regarding managed learning programme or qualification examination and assessment
documentation and or results or where provided by the learner directly.
Any personal data provided to us will only be used by us in accordance with this privacy notice and Data Privacy Law.
We may change this notice from time to time by updating this page on our website
We advise checking that page from time to time to review any changes we may have made.
We are a Data Controller in accordance with the GDPR.
The person responsible for GDPR compliance can be contacted at mail@lpgtraining.co.uk We will hold personal data and information
securely and only designated staff will have access to it.
We will not retain personal data where it is no longer needed by us, at which time it will be securely destroyed. We will securely
destroy personal data in accordance with the data retention periods as soon as is practicable after the data retention period has
expired.
Personal data will be stored securely either in paper or electronic formats by us.
Paper records containing personal data and information is securely stored in suitable facilities within the offices of LPG Training.
Electronic records containing personal data and information will be securely stored in the UK in an electronic database under the sole
control of LPG Training.
4. We collect personal information:
a. When you give it to us directly
For example, personal information that you give to us when you communicate with us by email,
phone or letter.
b. When we obtain it indirectly
For example, your personal information will be shared with us by our Approved Partners after you register for a qualification in relation
to which we provide the relevant learning programme and or qualification certification.
c. When it is available publicly
Your personal information may be available to us from external publicly available sources. For example, depending on your privacy
settings for social media services, we may access information from those accounts or services or from registration or licensing bodies
e.g. Gas Safe Register (GSR).
d. When you visit our website
In general, we may combine personal information from these different sources set out in a-d above, for the purposes set out in this
Notice.
When you visit our website, we automatically collect the following types of personal information:
• Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and
version, time zone setting, browser plug-in types and versions and operating systems and platforms.
• Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the
website (including date and time), services you viewed or searched for, page response times, download errors, length of visits
to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away
from the page.
5. Personal information we collect and use?
We may collect, store and otherwise process the following personal information:
a. Learner name and contact details including postal address, telephone number, email address and emergency contact details
and, where applicable;
b. Learner date of birth and gender;
c. Learner image (photograph)
d. Learner financial information, such as bank details and or credit and or debit card details;
e. Information about your computer and or mobile device and your visits to and use of our website, including, for example, your
IP address and geographical location;
f. Unique learner identifiers and or unique learner numbers;
g. National insurance number
h. Details of learner qualifications and or experience;
i. Documents containing evidence of learner identity, including for example passport, driving licence, UK Home Office Work
Permit;
j. Sensitive personal data of learners, including for example relating to health, learning ability, ethnic grouping;
k. Teacher, examiner, assessor or verifier of qualifications, name, gender, contact details including postal address, telephone
number, email address, national insurance number, Curriculum Vitae, qualifications and experience.
We may process special categories of data
The UK General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore
requiring more protection, for example information about learner health, ethnicity and religious beliefs.
In certain situations, LPG Training may collect and or use these special categories of data (for example, information on learners
medical conditions so that we can make arrangements for reasonable adjustments and or special considerations). We will only process
these special categories of data if there is a valid reason for doing so and where the GDPR allows.
7. Sharing of personal data
The organisations with which we share personal data with or may provide or permit access to personal data include but is not limited
to:
Approved Partners
The Qualification Regulators:
Ofqual in England
Qualifications Wales in Wales
CCEA Regulation in Northern Ireland
United Kingdom Accreditation Service (UKAS)
Learning Records Service (LRS)
LRS is the organisation which issues Unique Learner Number (ULN) to learners when registering with an approved centre to take a
regulated qualification. LRS also maintains a record of the regulated qualifications held by learners
Registration Bodies:
Gas Safe Register – Gas utilisation qualifications
UK Government Departments
Department for Education (DfE)
Department for Environment Food and Rural Affairs (Defra) Department for Business, Energy & Industrial Strategy (BEIS)
Law Enforcement Agencies
Police
Health and Safety Executive
Crown Prosecution Service
The Courts
Her Majesty’s Revenue and Customs (HMRC)
Others
Employers
Local Authorities
8. Transfer of Data
The transfer of paper based personal data and information between our Approved Partners and us takes place using the postal
system i.e. Royal Mail or private courier service using standard or registered postage.
The transfer of electronic data and information between our approved centres and us is by either electronic mail or a secure share
filing system.
Personal data will not be shared with, sold to or used by any other organisations or for any other purpose than for which it was
provided.
Our compliance manager can advise you of the personal data we hold about you, receive requests to rectify any incorrect personal
data about you or request that we erase your personal information. The erasure of your personal information may be subject to
contractual or legal restrictions and we may not be able to comply with this request. Where we are unable to comply with a request to
erase your personal information we will provide you the reason why we are unable to do so.
9. Our Website
The only time we ask you to provide personal data on our website is if you complete the enquiry form. We ask for your name, email
address and telephone number. We also ask you to tell us which training course or subject your enquiry concerns. This information is
only used by us to fulfil your enquiry to us.
10. Personal Data and Information
The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to
be relevant:
a. Where you have provided your consent for us to use your personal information in a certain way (for example, we may ask for
your consent to collect special categories of your personal information so that you may sit an exam with reasonable
adjustments and/or special considerations).
b. Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to
share your personal information with regulatory bodies which govern our work and services).
c. Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a
contract (for example, to provide you with a certified award after sitting an examination).
d. Where there is a legitimate interest in us doing so.
The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate
interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual).
In broad terms, our “legitimate interests” means the interests of running of LPG Training as a commercial entity and ensuring that
appropriate levels of certified awards are granted to learners in line with our standards.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on
you (both positive and negative), and on your rights under data protection laws. We will not use your personal information for
activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for
instance, we are otherwise required or permitted to by law).
11. Lawful basis
The lawful basis for us collecting holding personal data and information is either one of a legitimate interest, a contract between us or
we have a legal duty to collect and retain the data.
1.0 Learner personal data which maybe held by us and or at an Approved Partner on our behalf.
The purpose of us keeping learner personal data and the legal basis for doing so for an unlimited time is to enable:
- Learners to claim a replacement for lost or damaged training and or qualification certificates issued by us. Ours and learner
legitimate interest. - Learners to seek confirmation of the certificates which have been issued to them by us. Ours and learner legitimate interest.
- Us to issue a replacement qualification certificate to a learner. Ours and learner legitimate interest.
- Us to keep a permanent record of persons to whom we have issued a qualification certificate. Ours and learner legitimate
interest. - Us to keep a permanent record of persons, who we have taught, examined and or assessed learners registered for managed
learning programmes and or our qualifications. Ours and learner legitimate interest. - Us to keep a permanent record of persons who have conducted internal quality assurance of managed learning programmes
and or our qualifications. Ours and learner legitimate interest. - Us to assist an investigation to an incident or complaint or where there is pending litigation.
- Us to keep a record of the means of the verification used to confirm the identity of the learner at the time of application for a
qualification. Ours and learner legitimate interest. - Us to remind individuals of any pending expiry of qualifications. Ours and learner legitimate interest.
The purpose of us keeping learner personal data and the legal basis for doing so for a limited time is to enable us:
Where required contractually or legally to provide data to:
• Approved Partners
• Qualification Regulators
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• Registration Bodies
• Industry Bodies
• Members of the public with a legitimate interest
• UK Government Departments
• Law Enforcement Agencies.
Legitimate interest.
2.0 Personal Data of Trainers, Assessors and Internal Verifiers which maybe held by us and or Approved Partner on our behalf
The purpose of us keeping personal data and the legal basis for doing so of Trainers, Assessors and Internal Verifiers for an unlimited
time is to enable:
Us to keep a permanent record of persons, who have taught, examined and or assessed learners registered for managed
learning programmes and or our qualifications.
Legitimate interest.
Us to keep a permanent record of persons who have conducted internal quality assurance of our qualifications.
Legitimate interest.
The purpose of us keeping personal data and the legal basis for doing so of Trainers, Assessors and Internal Verifiers for a limited time
is to enable:
Us to remind individuals of any pending expiry of qualifications. Our legitimate interest.
Us where required to contractually or legally provide data to:
• Qualification Regulators
• Registration Bodies
• Government Departments
• Law Enforcement Agencies.
Legitimate interest.
12. Letting us know if your personal information is incorrect
You have the right to ask us to rectify any wrong or incomplete personal data we hold about you. If you do, we will take reasonable
steps to check its accuracy and correct it.
13. What if you want us to stop using your personal information?
Individuals have the right to object to our use of their personal data, or to ask us to delete, remove, or stop using personal data if
there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use personal data. But please tell us if you think that we should
not be using it.
We may sometimes be able to restrict the use of personal data. This means that it can only be used for certain things, such as legal
claims or to exercise legal rights. In this situation, we would not use or share personal data in other ways while it is restricted.
14. Individuals can ask us to restrict the use of their personal information
Individuals can ask us to restrict the use of their personal information if:
• It is not accurate.
• It has been used unlawfully but do not want us to delete it.
• It is not relevant any more, but you want us to keep it for use in legal claims.
• You have already requested that we stop using your data but you are waiting for us to tell you if we are allowed to keep on
using it.
If you want to object to how we use personal data, or request that we delete it or restrict how we use it or, please contact us.
15. How to complain
Please let us know if you are dissatisfied with how we have used your personal data. You can contact us by email or post at the
address published in the Contact Us section of the website
Our complaints procedure is available on request from our office. If you remain dissatisfied with our response to you, you have the
right to make a complaint to the Information Commissioner’s Office. https://ico.org.uk/
Privacy Notice reviewed 02.02.2020 by I Oultram due to UK withdrawal from EU Changed GDPR reference from EU – UK in Section 5
