Privacy Policy
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Introduction
AGL Training Ltd has created this document to demonstrate its commitment to data privacy and its alignment to the requirements of the Data Protection Act 1998 and, in substitution from 25 May 2018, the General Data Protection Regulation 2018 (“GDPR”) in respect of handling and processing personal data.
AGL Training is registered with the UK Information Commissioner’s Office as a Data Controller and Data Processor.
Learner Data
We will capture personal data about learners when they apply for apprenticeships and details to courses, work-based learning awards or exams. We will collect this as a Data Controller in our role as an approved training provider. The personal data is usually limited to the details required for us to undertake the basic functions to upload to Awarding Body’s called Highfield, EAL, to an eportfolio called One File and to Worcester College. These details will include (but may not be limited to) a learner’s name, date of birth, Address, gender, telephone number and qualification awarded..
In line with our regulatory requirements and requirements to deliver future services such as certificate re-prints and the confirmation of awards, this basic learner-level data will be held by Highfield, EAL, One file, AGL Training and Worcester college indefinitely.
Information processed as part of a learner’s qualification, such as physical exam papers, will be held for a maximum of 6 months. Personal data captured as part of a quality visit (such as video evidence of training) will be used for the purpose and outcomes of the visit, and then destroyed or deleted.
Learners may also contact Highfield, EAL to request certificate replacements. In these circumstances, a record of a learner’s address is taken so that the certificate can be sent. This is held on file for a maximum of 6 months before it is destroyed or deleted.
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Tutors, assessors and internal quality assurance (IQA) staff
Tutors, assessors and quality assurance staff provide AGL Training with information about their experience and qualifications that confirm their ability to teach Highfield and EAL qualifications. As such, we may hold a substantial set of personal details about a tutor, assessor and other staff. These may include:
· names, email addresses, telephone numbers and other contact information;
· teaching and training qualification certificates;
· proof of professional qualifications;
· employment history and training experience; and
· references
This data is required for regulatory purposes to ensure that we meet the necessary conditions of the Awarding Body. We collect this information in the capacity of a Data Controller.
It is important that our staff seek permission from learners before providing us with their personal data.
· This data remains on Highfield’s, EAL, Worcester college, One File and AGL Training Ltd systems for as long as the individuals continue to be a tutor, assessor or IQA for. If a tutor, assessor or IQA requires their personal data to be removed from all systems because they are no longer fulfilling the role, they need to inform AGL Training Ltd so that relevant data can be removed from the systems.
Data sharing
Other than as set out in the next paragraph and even where we collect personal data in the capacity of a Data Controller, we will never distribute or share personal data that is held on our system with any third parties other than Highfield, EAL, One File, Worcester College.
Through AGL Training Ltd our awarding bodies Highfield and EAL provides a certificate verification service that allows members of the public to check that a certificate presented to them is valid and has been produced by Highfield or EAL.
Marketing
AGL Training Ltd maintains a marketing database that contains the basic details of individuals each marketing email that is sent provides you with the ability to unsubscribe from receiving marketing emails at any time. Alternatively, you can opt-out by sending a request specifying your new choice to aaron@agltraining.com
Employees
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AGL Training Ltd will only process and hold staff data for the legitimate purpose of employment.
Personal data including name, address, contact details, NI number, date of birth, bank details, employment history, medical history, next of kin contact details is stored and processed on the Highfield HR drive and Sage payroll system and will be held for the duration of the employment.
On leaving the company all data will be removed from systems and personnel files and be archived for a period of 3 years before being securely destroyed. PAYE information will be held on our system for 6 years after as required by HMRC.
CV’s and interview notes will be held for 6 months after the recruitment of a role before being securely destroyed or deleted. Data for successful candidates will be stored with employment data.
Prospective CV’s will be considered on receipt, shared with internal staff and destroyed should no suitable vacancies be available. AGL Training Ltd does not store prospective CV’s.
References will be requested from former employers as part of employment terms. Factual references for former staff will only be provided on request from future employers, AGL Training Ltd will only state dates of employment and final role. On receipt of financial reference requests, HR staff will seek consent before providing information.
Personal data will be shared with relevant agencies for the appropriate performance of pensions schemes, tax affairs, benefit schemes, illness cover. Staff participation in such services will indicate consent to share required data for the performance of the service.
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Security
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AGL Training online systems have security measures in place to help protect against the loss or misuse of any data under our control.
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Where we store data
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All data in AGL Training Ltd systems is stored on a secure server. The servers reside in the United Kingdom. Data is frequently backed up and stored in the provider’s backup / disaster recovery facility, which is also in the UK.
This is in a secure server which is locked in a safe and technical controls in place to ensure unapproved access is prevented.
Destruction of physical data
AGL Training Ltd employees are trained to destroy all personal data securely using our shredder.
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Data breach incidents
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In line with our regulatory requirements, AGL Training Ltd has a set of processes for issue and incident management, including data breaches. These processes include the required notifications to be sent to the Information Commissioners Office and to Learners, Highfield, EAL. OneFile, Worcester college. This is reviewed annually and may be subject to change.
General Data Protection Regulation 2018
AGL Training Ltd has adapted its policies and procedures to ensure it is compliant with the GDPR. This document has been produced to represent our status and will be reviewed annually and updated as processes are developed.
Under GDPR, individuals have certain rights when it comes to the control of personal data:
The right to be informed. Each individual has the right to be given information about how their data is being processed and why. AGL Training Ltd can provided this policy to show how we handle your data.
The right of access. AGL Training Ltd have a duty to comply with the requirements of Subject Access Requests (SAR)
The right to rectification. The GDPR includes a right for individuals to have inaccurate personal data rectified or completed if it is incomplete.
The right to be forgotten. You have the right to ask AGL Training to remove your data.
The right to restrict processing. You may restrict processing for a legitimate reason, we would still have the right to hold that information.
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.
Should you wish to exercise any of your rights above, please email gary@agltraining.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.
Under the GDPR you have further rights in relation to automated decision making and profiling. AGL Training Ltd currently do not use any automated profiling. Should any further automated processes be implemented, the policy will be reviewed and updated.