PRIVACY POLICY FOR WEST BERKSHIRE TRAINING CONSORTIUM (WBTC) CUSTOMERS

How we collect and use personal information 

WBTC is an approved training provider and contracts directly with the Education & Skills Funding Agency which is an agency of the Department for Education. This means WBTC is instructed by the government on the personal or company data that we must collect and store when we use public funding to provide services to our customers. WBTC also has a legitimate business purpose for the collection of personal data in order to:

1. 1.    Broaden its charitable objectives in the promotion of apprenticeships, work experience and work-based learning.
2. 2.    Facilitate the delivery of formal qualifications in conjunction with awarding bodies.
3. 3.    Meet the legal requirements of Government and its agencies.

Any personal information that you give to WBTC will be handled confidentially by WBTC in line with the requirements of the Data Protection Act 1998 and the General Data Protection Regulations. If you would like information about this legislation, this can be obtained from the Information Commissioner’s Office through their website www.ico.org.uk or advice line 0303 123 1113.

WBTC has a range of policy and procedural instruction concerning: Compliance with the Data Protection and GDPR law; Protocols for collecting and storing data; Security and related requirements in the operation and use of all IT (electronic systems). These policy and procedures are available on request.

Consent for information to be collected and used

WBTC is provided with a statement by the Department for Education and it’s agencies that informs employers and individuals of the legal basis for collecting personal/company information. This statement appears on every enrolment/application form where personal information is required. Without consent to collect and store this information we are unable to proceed with any publically funded service.

Employers will be asked to provide consent at the time of registering a vacancy or other details with WBTC and at the time of contracting with WBTC. Without this consent WBTC is unable to proceed with any publically funded service.

What information does WBTC collect about you?

WBTC collects personal information that is supplied to WBTC in it’s role as an approved training provider. The legal basis for the collection/storage of this data arises from the Department for Education. Without this information WBTC is unable to apply for the necessary public funding for apprenticeship programmes or other publically funded services and will not be permitted by the Department for Education to act as an approved provider. You can find more information on the Education & Skills Funding Agency website here https://www.gov.uk/government/publications/esfa-privacy-notice . 

The type of information WBTC may hold about you or a company will include (but is not restricted to) any or all of the following:

• •    Your name, address, email and telephone numbers.
• •    Proof of eligibility for public funding for example visa details or proof of ID.
• •    Details of parents/guardians where the individual is under 18.
• •    Ethnicity.
• •    Declared disability or special educational needs.
• •    Date of birth.
• •    Gender.
• •    Bank details (for the purposes of paying allowances/bursary/invoicing).
• •    Education history for example evidence of prior achievements and qualifications.
• •    Employer details – for example company name, size, location, bank details for payment of enhancements, email addresses, telephone numbers.

This information is held securely on a password-protected database which is maintained and secured by an IT provider called Virtual IT. We also store information on a remotely hosted database called PICS which is provided by a company called Pellcomp.

Personal Information is stored for periods either required by the contract for public funding or to conduct business. Stored information on paper or electronically is kept in secure locations and protected.

Safeguarding & Prevent Duty

WBTC is legally obliged to undertake training and support to enable safeguarding and our responsibilities under the Prevent Duty. WBTC will collect personal data when dealing with safeguarding issues raised either by individuals, their employers or other professionals. This extends to any incident relating to the Prevent Duty and the prevention of extremism.

Personal data collected as part of a safeguarding and/or Prevent case may include:

• •    Details of specific safeguarding cases.
• •    Feedback from safeguarding agencies.
• •    Responses to questions or queries from parents/employers.

Data will be shared by multi-agency stakeholders charged with duties under safeguarding and prevent e.g. social services.

Third parties we share information with 

WBTC requires evidence of compliance with the Data Protection and GDPR requirements with all organisations with which we share or transfer personal data.

Information will only be passed to the following third party organisations:

1. 1.    Awarding body organisations for the purpose of qualifications and exams.
2. 2.    The Department for Education and its agents for the purpose of funding programmes.
3. 3.    Approved colleges or providers directly involved in the delivery of an apprenticeship or other learning programme.
4. 4.    Employers to whom applicant apprentices are applying. This is only passed with the permission of applicants and will be limited to information relevant for a job application.
5. 5.    Safeguarding agencies in the case of an incident that WBTC professionals believe constitutes a safeguarding or Prevent case.
6. 6.    Providers of our e-learning and e-portfolio services.

If we need to share or transfer personal data to an organisation not mentioned above we will ensure the individual expresses their consent.

How WBTC will use the information about you

WBTC is legally obliged to collect information for the following programmes

• •    Apprenticeships.
• •    Study Programmes.
• •    ESF funded programmes.
• •    Other funded programmes for example funded by a local authority.

The legal basis stems from the Department of Education under current Acts of Parliament that govern funded training. The information is used to ensure that the programme can be funded, that qualifications can be applied for and that learners/employers are kept safe.

For commercial programmes not funded by the government WBTC will collect and store the minimum data needed in order to deliver the programme and or qualification.

WBTC news and events

WBTC employers and learners are ‘Members of WBTC’. In order to keep members updated about courses, events and enrichments, WBTC would like to send out information. This would be limited to the following activities:

• •    Important changes in the world of apprenticeships and other qualifications that could have a material impact upon employers and learners.
• •    Upcoming added-value courses that are offered for free to members.
• •    Upcoming enrichment activities that are offered for free to members.
• •    Information that will aid in keeping young people safe.
• •    Information that employers will find useful in the execution of their legal obligations around health & safety.
• •    Achievements and awards of learners/employers.

In general this information is sent on a monthly basis through a newsletter called The Earwig. It is sent to existing members and former members on the basis that both have a legitimate interest in the services WBTC is providing. The Earwig will be supplemented from time to time by email-messages via Mailchimp. The service offered by Mailchimp provides the opportunity for recipients to withdraw consent and to unsubscribe at any time. You can also contact WBTC via matt@wbtc-uk.com if you wish to be excluded from such correspondence.

Imagery

WBTC celebrates the success of employers and learners throughout the year. This is done on a voluntary basis. WBTC takes and stores images of apprentices, learners and employers when they have achieved a programme or won an award. Case studies are sometimes created and used for promotional purposes with the consent of those involved. Consent is required before we take or use imagery and where a learner is under 18 consent is also required from a parent or guardian.

Access to your information, correction and deletion 

You can ask to see any information that we hold about you by emailing WBTC at matt@wbtc-uk.com and we will respond within one month. Any updates or inaccuracies will be promptly corrected on request. You have the right to ask for your information to be removed or ‘forgotten’ at any time by WBTC. However, please keep in mind that data collection and storage is governed by specific laws when it comes to funded learning programmes.

Subject access requests will be responded to within one month. This will normally be free of charge. However, if requests to WBTC are ‘excessive’ or ‘repetitive’ we reserve the right according to GDPR rules to charge a ‘reasonable’ fee.

Cookies 

Technology may be used to collect statistics on activity on this website. This can include using a ‘cookie’ which will then be stored on your browser. The information collected in this way can be used to identify you unless you modify your browser settings to disable cookies. You can read more here .

Other websites 

This privacy notice only applies to information on the WBTC website and does not apply to information contained on other websites that are linked from this one.

 Changes to WBTC privacy policy 

This privacy policy was last updated on 18^th May 2018.

 How to contact WBTC

Please contact WBTC if you have any queries regarding this privacy policy or how we handle your information, by email to Matt Garvey the Managing Director or matt@wbtc-uk.com or by post to Matt Garvey, WBTC, 7 Cheap Street, Newbury, RG14 5DD.