Privacy Policy Ascentis

Summary

In this privacy policy, we explain how we collect and use your personal information. ‘We’/’Ascentis’ means Ascentis, Office 4 Lancaster Business Park, Mannin Way Caton Road, Lancaster, Lancashire, LA1 3SW. We are the data controller for the purposes of the Data Protection Act 1998 (as may be updated, amended and superseded from time time) and the EU General Data Protection Regulation (together the “Data Protection Legislation”).

Ascentis is committed to protecting your privacy and safeguarding your personal information. We’ll use your personal information in accordance with the Data Protection Legislation.

Ascentis will collect and process personal information about you to enable us to administer products and services, provide you with other related services and manage our relationship with you.

This privacy policy sets out the ways in which we may collect and use your information. By submitting your personal information by: email, telephone, at an event or on a form, or other interactions with us e.g. use of our website or other systems. This includes anyone who contacts us in connection with the delivery or receipt of any products or services we provide or otherwise interacts with us such as:

• Learners;

• Contacts at our approved centres;

• Users of our website;

• Third parties that provide services to us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

Ascentis will occasionally update this Privacy Policy to reflect company and customer feedback and changes to law and regulations. Ascentis encourages you to periodically review this policy to be informed of how Ascentis is protecting your information and reserves the right to update or make changes to this Privacy Policy at any time.

Equally, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This policy was last updated in April 2018.

Who is responsible for your information?

Ascentis acts as a Data Controller for information that is collected by us about you and determines the purposes of its use. If you have any questions or comments regarding this Privacy policy, please contact us in one of the following ways:

Email: data@ascentis.co.uk

Writing: Ascentis, Office 4, Lancaster Business Park, 8 Mannin Way, Caton Rd, Lancaster, LA1 3SW marked for the attention of the Data Lead. If your enquiry is in relation to accessing your personal information please also state; ‘Subject Access Request’.

Website: we have a “Contact Us” section on our website www.ascentis.co.uk

We may share your personal information with other organisations, including those who provide us with assistance in delivering our products or services or, where applicable, regulate our provision of such products or services. Further information is available in section 3 below.

Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1. Collecting Data

Information you provide to us

We may receive personal information about you whenever you contact us. For example, by doing the following:

• information that you provide by filling in forms for us, including those on our website;

• when enrolled on a qualification we collect personal information to process and complete your enrolment and or certification;

• information contained in and records of communications between us including: e-mails, letters, surveys, reports, feedback forms, photos and booking or recording any training;

• information about your usage of our website, for the purposes of enhancing and personalising your experience on the website and optimising it;

• details of your visits to our website, for example traffic data, location data and the resources that you access, including the pages of our website that you view;

• CCTV footage in which you feature when you visit our premises;

• data concerning your marketing preferences;

• enquiring about, or applying for, job vacancies; and

• enquiring about our products or services

This information may include the following:

• normal identification information, such as your full name, date of birth, age, gender, username or similar identifier;

• contact information, such as your postal address, email address and telephone number;

• additional information relevant to your use of our website and services, such as your marketing preferences, survey responses and feedback;

• [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website]; and

• in respect of job applications, your CV including details of your education and employment history (and any other information which you may choose to provide to us with your CV) 

Information we collect about you from other sources

We may collect information about you from other sources. This may include the following:

• information from the learning centre that you have enrolled with provide us with all the personal information we may require in order to process and complete your enrolment and or certification;

• Publicly available information, from sources such as Companies House, County Court Judgements and repossessions this may include details about your home, vehicles, financial situation and debts; and

• Information from third party databases or data suppliers, such as credit reference agencies, including details about your home, belongings and creditworthiness.

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.

Information we receive about you from other sources

When you engage to enter into a course at a learning centre for which we are the relevant qualification awarding body they will share your personal data with us in order than we can award your qualification and certify that you have met the relevant criteria. We may process you data in order to assess the learning centre that you are enrolled in and bench mark them against other learning centres.

Sometimes you will have given your consent for other websites, services or third parties to provide information to us.

This could include information we receive about you if you use any of the other websites we operate or the other services we provide, in which case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.

It could also include information from third parties that we work with to provide our products and services, such as payment processors, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.

Information we collect about you on our website

We collect information using Cookies and other similar technologies to help distinguish you from other users of our website. These can streamline your online experience by saving you from re-inputting some information and also allow us to make improvements to our website. For more information about how and why we use Cookies please section 5 below.

When you visit our website we may collect the following information:

• Which pages you view and which links you follow

• Your IP address and general location

• Details of the hardware and software that you are using to access the site

• Any passwords that you use on our website

Our Website is not intended for children and we do not knowingly collect data relating to children.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate data to calculate the percentage of learners achieving a particular qualification. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may process Special Categories of Personal Data about you in particular we may process:

• details of your race or ethnicity; and

• information about your health.

However, we only do so where you have provided such in formation to your learning centre or to us and you have given your express consent for it to be processed for the purposes made clear to you when it is collected.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to award your qualification or provide you with copies of any certificates you request). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2. Using Personal Data

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 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 those interests; and

• Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to the collection and use of Special Category Personal Data and in sending third party direct marketing communications to you via email, phone or letter. You have the right to withdraw consent at any time by contacting us.

Purposes for which we will use your personal data

Ascentis only use personal information for the purposes outlined above and data will only be held for the timeframe necessary to support these purposes. In particular, we may use your personal information:

• in connection with any contracts between you and a learning centre which you are employed by or are attending as a learner;

• to carry out our obligations arising from any contracts entered into between you and us including in connection with providing products or services;

• to manage and administer the relationships, such as those with a learning centre;

• to comply with our legal obligations and with instructions from 3rd parties or regulators such as Ofqual, court orders or protect our legal interests.

• to notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us;

• to train our staff to continuously improve our services; and

• to analyse our products, services and marketing activity and to carry out market research.

If you tell us we can, we may also use your personal information to provide you with information about services, promotions and offers that may be of interest to you. We may use your personal information to identify additional products and or services that are likely to be of particular interest to you.

Supplying our products and providing our services

It is necessary for us to use personal information about you to enter into and perform the contracts that we make with you, such as when you become a customer. Using your information in this context is necessary so that we can:

• Administer online and paper examinations; reasonable adjustments and special considerations

• Support learning centres and tutors

• Provide certificates

• Provide services to learning centres

• Comply with regulatory requirements

• Process payments

• Provide you with information about your contract with us

• Provide you with information about our products and services

• Verify your identity

• Deal with any complaints or appeals you may have

• Contact you about any changes that we make to our products or services

• Administer our website, including troubleshooting problems, analysing statistics, conducting research and tests and keeping the site secure

If you enquire about, or apply for, a job vacancy, it is necessary for us to use your personal information as part of the recruitment process, in order to assess your suitability for a particular role.

Telling you about events or other products or services that we think may be of interest to you

We may use your information to identify and tell you about events and our other products or services that we think may be of interest to you. We will only do this where you have informed us that you would like to receive marketing communications.

We may also use your information to invite you to participate in market-research. If we do contact you about market-research, you do not have to participate. If you tell us that you do not want to receive market-research communications, we will respect this.

Whether you choose to receive marketing communications, or market-research communications is entirely up to you. You can choose to receive both, none, or just one or the other. Your choice will not affect any products or services that you have received from us, nor will it affect any products or services you receive from us in the future.

You can update your preferences by using the links in any of our emails to you, or by getting in touch using the Contact Us section of the website.

Telling you about products or services that are similar to ones that you have already bought

If you have already bought a product or service from us, or you have already obtained a quote from us, we may contact you with some information about products or services that are similar.

We will only contact you by email, phone or letter and you can choose not to receive these messages at any time. Simply follow the instructions in the message, or get in touch using the Contact Us section of the website.

Making our business better

We may also notify you about important updates or changes to our products or services. In some instances we may be required to release personal data to meet legal obligations placed upon us.

We always want to offer the best products, services and experience that we can. Sometimes this means we may use your information to find ways that we can improve what we do, or how we do it.

In this context, we will only use you information where it is necessary so that we can:

• Review and improve our existing products and services and develop new ones

• Review and improve the performance of our systems, processes and staff (including training)

• Improve our site to ensure that content is presented in the most effective manner for you and for your computer

• measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you

Contacting you

We want to stay in touch with you! Sometimes we may need to use the information that we have about you in order to respond to your questions or let you know about important changes.

We will only use your information in this respect where it is necessary so that we can:

• Interact and respond to any communications you send us, including where you use the Contact Us section, and any social media posts that you tag us in

• Let you know about any important changes to our business or policies

Verifying your identity

We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes.

Protecting you and others from harm

We may use your information where it is necessary to protect your interests, or the interests of others. This may include in the event of criminality such as identity theft, piracy or fraud.

We need all the categories of information listed above to allow us to enter into and perform our contract with you*, to enable us to comply with legal obligations**, and in order to pursue legitimate interests of our own or those of third parties*** (provided your interests and fundamental rights do not override those interests). The situations in which we will process your personal data are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information.

• Administer online and paper examinations, reasonable adjustments and special considerations (*,***)

• Support learning centres and tutors (*, ***)

• Provide certificates (*, ***)

• Provide products and services to learning centres (*, **, ***)

• Assess the performance of learning centres (**, ***)

• Interact with 3rd party organisations that require data relating to exam results such as UCAS

• Comply with regulations

• Verifying your identity (*, **, ***)

• Making a decision to supply our products and services. (*)

• Administering the contract we have entered into with you. (*)

• Dealing with any complaints you may have (*, ***)

• Logistics management and planning, including accounting and auditing. (**, ***)

• Making arrangements for the termination of our contract. (*, ***)

• Making alterations and improvements to the products or services supplied (*, **, ***)

• Dealing with legal disputes involving you (**, ***)

• To detect and prevent fraud, money-laundering and other crimes. (**)

• To review and improve the performance of our systems, processes and staff (including training). (***)

• To interact and respond to any communications you send us, including social media posts that you tag us in. (***)

• To let you know about any important changes to our business or policies. (***)

• To ensure that the information that we hold about you is accurate and up to date. (*,***)

• To protect your interests, or the interests of others (such as in the event of criminality such as identity theft, piracy or fraud). (**, ***)

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. Sharing personal data

Sharing your information within our company and group

We share the information that you provide to us with our staff so that we can provide our products and services to you.

We may share the information that you provide to us with International Dyslexia Learning Solutions Limited (IDLS) or any other companies within the group companies and other websites that we operate.

Personal Learner data will be shared between the recognised exam centre that registers the learner(s) onto any qualification(s) and Ascentis, according to the Centre Agreement.

Sharing your information with third parties

We may share your data with selected third parties. For example, we may pass your personal information to:

• third party organisations that provide services to us (including providing IT services and assisting us with carrying out marketing activities):

o Moore and Smalley – Auditors and Payroll (P)

o Hilton Baird – Debt Collectors (P)

o Lawyers (various) (C/P)

o Royal Bank of Scotland – payments to suppliers (P)

o Microsoft – (P)

o Portico – learner systems (P)

o Amazon Web Services (P)

o Fantastic Cloud Services (P)

o Eventbrite (P)

o Mailchimp (P)

o Paypal (P)

o RBS Credit card services (P)

o TNT (P)

o Royal Mail (P)

• third party organisations that collect data relating to examination results:

o Quality Assurance Agency for Higher Education (QAA),

o UCAS,

o Bath Data (SERAP),

o Learning Records Service (LRS)

• third party organisations that collect data relating to training and CPD

o We provide personal data to the CPD Certification Service for attendees to gain recognised CPD certificates for many of our training events.

We may share your personal data including name, email address and phone number with Eventbrite and Mailchimp for the purposes of administering training, CPD, communicating with you for sales and marketing activities. Both organisation use servers based in the USA and, as such, your personal information may be processed outside the EEA. However, both companies are registered under the EU-US privacy shield which is a system that has been recognised to provide adequate protection of your data such that it will be handled with the same degree of protection as that offered under the GDPR. Having carried out a legitimate interests assessment we believe that we have a legitimate interest in continuing to use the services and having them process your personal information on our behalf.

There are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

• Police, law enforcement agencies and regulatory bodies for the purpose of preventing and detecting fraud, crime and criminal activity.

• Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings

• Necessary to protect the safety of our employees, our property or the public

• Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction.

• Proportionate as part of a merger, business or asset purchase or sale, in the event that this happens we will share your information with the prospective seller or buyer involved

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Ascentis will not sell, rent or lease your personal data to any third party.

4. How long do we keep your personal information?

We will only store your personal information for as long as we need it for the purposes for which it was collected. Where we provide you with any service, we will retain any information you provide to us at least for as long as we continue to provide that service to you.

If you apply for a job vacancy (or otherwise send us your CV) we will retain your CV for a period of 3 months while we process your application and appoint an individual. If we are considering you for a different role, we may retain this information for longer than that period with your consent.

In all other circumstances, we will keep your information until it is clear the data is no longer required, accurate or otherwise inappropriate under GDPR. This can require us to maintain some limited learner data for between 6 and 99 years in relation to identifying the learner (e.g names and DOB) and creating a replacement certificate (e.g unit(s)/qualification(s) gained). If you require further details of how long we will hold your particular data please contact us at this email address: internalqualityassurance@ascentis.co.uk and we will provide you with the further information.

5. Protecting personal data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. We try to ensure that all information you provide to us is transferred securely via the website. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All information you provide to us is stored on our/third party secure servers. [Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.]

Ascentis has a range of other technical and organisational measures in place to protect your personal data.

Ascentis keeps track of the websites and pages our customers visit within Ascentis, in order to determine what are the most popular. This data may be used to deliver customised content and advertising within Ascentis to customers whose behaviour indicates that they are interested in a particular subject area.

The Ascentis website uses "cookies" to help you personalise your online experience:

A cookie is a piece of information that is held on the hard drive of your computer which records how you have used a website. Cookies allow website operators to accumulate useful information, such as whether the computer (and sometimes its user) has visited the site before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit.

We use cookies to monitor how people use our website including estimating audience size and patterns of use in order to help us to provide you with a better service. Cookies make it easier for you to log on and use the website during future visits. They also allow us to personalise the content of the website for you by storing information about your preferences. We use the following cookies:

Strictly necessary cookies

. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies

. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies

. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this in formation to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

In order to store cookies on your device, website owners must now have your consent. Therefore, you agree to our use of cookies when confirming your agreement on our home page. You can withdraw your consent for us to use cookies at any time. However please bear in mind that failing to consent to our use of cookies may prevent you from accessing our website or result in a loss of functionality which degrades your experience of the website.

6. Accessing or amending your personal data

If you think the personal information we hold about you is inaccurate or incorrect, you can request that we correct this information (including your marketing preferences).

You can choose to stop receiving: marketing communications from us by using the ‘unsubscribe’ functionality in the footer of email communications sent to you, or contacting us at unsubscribe@ascentis.co.uk describing your preferences. You can also contact the Ascentis Data Lead (see above) if needed.

Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any courses you register on or deliver.

Even if we already hold your personal data, you still have various rights in relation to it. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

What rights do you have in respect of your personal information?

You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch using Contact Us section of the website.

You have the right to access your personal data

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

• Why we have been using your information

• What categories of information we were using

• Who we have shared the information with

• How long we envisage holding your information

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.

The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.

You have the right to correct any inaccurate or incomplete personal data

Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This could be if:

• The information is no longer needed for the original purpose that we collected it for

• You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)

• You object to us using your information and we have no overriding reason to keep using it

• We have used your information unlawfully

We are subject to a legal requirement to delete your information

In those situations you have the right to have your personal data deleted. If you believe one of these situations applies to you, please get in touch using the Contact Us section of the website.

You have the right to have a copy of your data transferred to you or a third party in a compatible format

Also known as Data Portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.

If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please contact us. There is no charge for you exercising this right.

You have the right to object to direct marketing

You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links provided in any of our marketing communications, and we will stop sending direct marketing immediately.

You have the right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:

• When we tell you about products or services that are similar to ones that you have already bought

• When we use you information to help us make our business better

• When we contact you to interact, communicate or let you know about changes we are making

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.

In order to exercise your right to object to our use of your data for the purposes above, please contact us.

You have the right to restrict how we use your personal data

You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

• You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this

• You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection

• We have used your information in an unlawful way,but you do not want us to delete your data

• We no longer need to use the information, but you need it for a legal claim

If you believe any of these situations apply, please contact us.

You have rights related to automated-decision making and profiling

Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. We will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us.

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