Financial Services Training Partners LLP Privacy Notice

This privacy notice is published on 25/4/2018.

Amended 03/02/2022.

Who are we?

Financial Services Training Partners (FSTP) provides apprenticeship training. Our registered office address is:

Acorn House
393 Midsummer Boulevard
Milton Keynes
England
MK93HP

Our Registered No: OC372081.

Philippa Grocott is the Data Controller and can be contacted by emailing: philippagrocott@fstp.co.uk.

Aged 18 or under

We are concerned with protecting the privacy of children and young adults aged 18 or under.

If you are aged 18 or under‚ please obtain your parent/guardian’s permission before providing your personal information.

Who is this privacy Notice for?

This Privacy Notice is primarily for:

• Potential apprentices.
• Apprentices.
• Employers of apprentices.
• Potential customers.
• Users of this website.

It sets out how your personal data will be used, shared and stored.

What personal data do we collect and process?

Apprentices:

• Identity data
• Unique Learner Numbers
• CVs
• Job descriptions
• Identity information
• Contact details
• Dates of birth
• Gender
• Ethnicity
• National Insurance Numbers
• Employment details
• Health information
• Next of kin details
• Emergency contact information
• Educational history
• Nationality
• Eligibility to work in the UK
• Social information
• Economic data
• Apprenticeship eligibility data
• Equal opportunities data
• Progress records
• Achievement records
• Technical information
• Usage data
• Profile data
• Communication records
• Marketing information
  
  

Employers:

• Identity data
• Name
• Address
• Contact details
• Financial data
• Transaction data
• Technical information
• Usage data
• Profile data
• Communication records
• Marketing information

All potential and actual customers:

• Identity data
• Contact details
• Technical information
• Usage data.
• Profile data.
• Communication records
• Marketing information

When do we collect your personal data?

• When you register for or enquire about any service provided by FSTP.
• When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
• When you enroll an employee onto an FSTP apprenticeship programme. (Employers Only)
• When you are enrolling (by your employer) onto an FSTP apprenticeship programme. (Apprentices Only)

We may also collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests.

Before data is collected, we make sure an assessment is made, ensuring that there is an established mutual interest between you and FSTP.

Why do we collect personal data?

We collect and use personal data:

• To facilitate the effective delivery of our apprenticeship programmes.
• For the purposes of skills development.
• To facilitate awarding qualifications.
• To facilitate the exams process.
• To maintain educational standards.
• For internal and external audit purposes.
• To ensure that we are accurately claiming ESFA (Education and Skills Funding Agency) funding.
• To meet our legal obligations (such as collecting eligibility to work in the UK data).
• To perform direct marketing, sales and customer service.

We also collect data about suppliers, partners and persons seeking employment with our company.

How do we collect personal data?

We collect your data when you:

• Initiate contact through chat, a contact form, a telephone call or other means of direct communication.
• Enroll an employee onto an FSTP apprenticeship programme.
• Are enrolled, by your employer, onto an FSTP apprenticeship programme.

What we use your personal data for?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, that we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override these interests.
• Where we need to comply with a legal obligation.

When will we share your personal data with third parties?

The information shared with us will be held and may be passed to:

• Bud Learning Platform. (Employers and Apprentices Only)
• The Education and Skills Funding Agency (ESFA). (Employers and Apprentices Only)
• Awarding Organisations. (Apprentices Only)
• End Point Assessment Organisations. (Employers and Apprentices Only)
• Ofsted. (Employers and Apprentices Only)

We have identified all the ways we may use your personal data, and which of the legal bases we rely on to do so.

We have also identified what our legitimate interests are, where appropriate.

Note: we may process your personal data on more than one lawful ground, depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal grounds we are relying on to process your personal data, where more than one ground has been set out in the table below.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving this marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any third party, for marketing purposes.

Opting out

You can ask us, or third parties, to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

What type of personal data is collected?

We collect the following information name, phone number, title and email address, in addition to your job title, company’s name and contact information. For apprentices we are legally obliged to collect additional personal data (as identified above).

When a service is purchased, we will collect payment details from either the company or the individual.

We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails.

From our website we may collect IP-address and actions taken on the site.

If you upload photos or videos, add posts or comments, etc. on our website, the information can be read by anyone with access to the site and used for purposes over which we or you have no control. Therefore, FSTP is not responsible for any information you submit to the website in the public domain.

If you apply for a job at FSTP, we will collect the data you provide during the application process.

FSTP collects and processes special categories of personal data (this includes details about your race or ethnicity and information about your health) for apprentices. We also collect information about criminal convictions and offences (as part of our Safer Recruitment Process).

How will your data be stored?

Your data will be stored electronically.

We will only make your data available to those who have a right to see it. Examples of our data security measures are:

• Staff training.
• Encrypting electronic data.
• Controlling access to our systems.
• Regular auditing and testing of our systems.

How long do we keep your personal data?

In line with ESFA, Awarding Body, Awarding Organisation and End Point Assessment requirements, we must retain all data pertaining to an apprentice, their apprenticeship training, their achievements and their employers for 7 years.

We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes. This means that we may retain your personal data for a reasonable period of time after your last interaction with us.

When the personal data that we have collected is no longer required, we will delete it in a secure manner.

We may process data for statistical purposes, but in such cases, data will be anonymised.

International transfers of data

We do not normally share your data outside of the UK. However, should we engage any external third parties (as set out below) in the future, that are based outside of the UK, their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government.
• Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioners Office which give personal data the same protection it has in the UK.
• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you, and any applicable regulator, of a breach where we are legally required to do so.

Your rights to your personal data

You have the following rights with respect to your personal data:

• The right to request a copy of the personal data that FSTP holds about you.
• You can request this information by sending a request to philippagrocott@fstp.co.uk.
• The right to request that FSTP corrects your personal data if inaccurate or out of date.
• You can request this change by sending a request to philippagrocott@fstp.co.uk.
• The right to request that your personal data is deleted when it is no longer necessary for FSTP to retain such data.
• You can request this deletion by sending a request to philippagrocott@fstp.co.uk.
• The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications.
• If you want to withdraw your consent to e-marketing, please make use of the unsubscribe link included in our communication. Please note that you may still receive system messages and administrative communications from us, such as notifications about your account activities.
• The right to request that FSTP provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
• You can send this query to philippagrocott@fstp.co.uk.
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
• The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
• You can send this query to philippagrocott@fstp.co.uk.

Any query about your Privacy Rights should be sent to philippagrocott@fstp.co.uk.

The use of cookies and beacons

We use cookies and web beacons (‘Website Navigational Information’) to collect information as you navigate the company’s website. Website Navigational Information includes standard information from your web browser such as, browser type and browser language, your Internet Protocol (“IP”) address, and the actions you take on the company’s websites, such as the web pages viewed and the links clicked.

This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.

When you first access our site, you will be asked to set your preferences using the cookie preference centre. You can use the preference centre to amend and update your preferences at any time.

For further information visit http://www.aboutcookies.org or http://www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Name:	Philippa Grocott
Job title:	Head of Regulated Sales and Apprenticeships
Date approved:	23/03/22
Signature: