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Contents
1. Who we are & what we do
The Building Block specialise in designing, delivering and occasionally gaining approval from Awarding Organisations (AOs) for bespoke courses, in the vocational & technical learning programmes and qualifications within the Buildings Services Engineering (BSE) sector.
Note: In this notice the use of; we, our, us is to be read as meaning The Building Block. We are;
A Training Organisation recognised by the following AOs to design, develop and deliver training, examinations and assessments within the scope of their recognition of us;
(i). Logic Certification Limited (LCL) who are themselves recognised by: The Office of the Qualifications and Examinations Regulator (Ofqual) in England, Qualifications Wales (QW) and The Council for Curriculum, Examinations and Assessment (CCEA) Regulation in Northern Ireland.
(ii). City and Guilds (C&G)
We also deliver training of non regulated qualifications which are designed and approved by us and delivered at our centre. Details of all courses 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 training for which learners have applied 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.
We do not send unsolicited information by electronic or other means to individuals to advertise or promote our products and services.
2. 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 policy sets out how we use and protect any data and information that is provided to us via an online registration form, examination and assessment paperwork or that our AOs provide to us regarding managed learning programme or qualification examination and assessment documentation and/or results, or where otherwise 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 **https://worcestercommunitytrust.arlo.co/w/privacypolicy/ ** 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. Our manager responsible for GDPR compliance can be contacted at **data@worcestercommunitytrust.org.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 we are bound by from our AOs 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 at the Building Block where learners are registered for their managed learning programme and/or training course.
Paper records containing personal data and information are securely stored in suitable facilities within the offices at the centre or with the relevant AO.
Electronic records containing personal data and information will be securely stored in the UK either on:
The Building Block database(s)
The AO’s database(s)
The Logic Accreditation web-based learner management system (Parnassus) operated and owned by Gordon Associates
The City and Guilds Secure Assess Servers and database
3. How we may collect personal information
• When you give it to us directly, for example personal information that you give to us when you communicate with us by email or phone, or register on our subscription list and/or courses.
• When we obtain it indirectly, for example your personal information may be shared with us by your employer or other person arranging training for you.
• When it is available to us from external publicly available sources, for example, depending on your privacy settings for social media services.
• When you visit our website or the Worcester Community Trust website in general, we may combine personal information from these different sources set out above, for the purposes set out in this Policy. 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.
4. Specific personal information we may collect and use
We may collect, store and otherwise process the following personal information:
• Learner name and contact details including postal address, telephone number, email address and emergency contact details and, where applicable:
• Learner date of birth and gender
• Learner image (photograph)
• Learner financial information, such as bank details and or credit/debit card details
• Information about your computer and or mobile device and your visits to and use of our website
• Unique learner identifier/unique learner number
• National insurance number
• Details of learner qualifications and feedback
• Documents containing evidence of learner identity, for example passport, driving licence and/or UK Home Office Work Permit
• Sensitive personal data of learners, for example data relating to health, learning ability, ethnic grouping
• Tutor, assessor or verifier 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 EU General Data Protection Regulation (GDPR) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about learner health and ethnicity.
In certain situations, we 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. We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows.
5. How and why we will use personal information
Personal information, however provided to us, will be used for the purposes specified in this Policy. In particular, we may use personal information:
• to register you as a learner and allow you to take examinations and assessments
• for examination and assessment administration purposes
• to conduct examinations and assessments
• to issue examination and assessment results and certificates
• to carry out any reviews or appeals
• to otherwise provide you with services, products or information you have requested
• to communicate as necessary with AOs
• to provide further information about our work, services or activities
• to answer your questions or requests and communicate with you in general
• to manage relationships with our AOs
• to analyse and improve our work, services, activities, or information, (including our websites), or for our internal records
• to keep our facilities safe and secure
• to run and or administer our activities, including our website, and ensure that content is presented in the most effective manner for you and for your device
• to audit and or administer our accounts
• to satisfy legal obligations which are binding on us, for example in relation to regulatory, government or law enforcement bodies with whom we may work
• for the prevention of fraud or misuse of services
• for the establishment, defence or enforcement of legal claims; to keep a record of personnel who have carried out teaching, examination, assessment and/or verification of qualifications
6. Sharing of personal data
The organisations with which we share personal data, or may provide or permit access to personal data include but is not limited to:
(i) Logic Certification Limited (LCL) who are themselves recognised by:
The Office of the Qualifications and Examinations Regulator (Ofqual) in England, Qualifications Wales (QW) and The Council for Curriculum, Examinations and Assessment (CCEA) Regulation in Northern Ireland.
(ii) City and Guilds (C&G)
And, via the above, to the following Qualification Regulators:
Ofqual in England
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.
And, via the above, to the following Registration/Statutory Bodies:
UK Government Departments
Department of Education
Department for Environment Food & Rural Affairs
Deparment for Business, Energy & Industrial Strategy
Law Enforcement Agencies
Police
Health & Safety Executive
Crown Prosecution Service
The Courts
Employers
Local Authorities
7. Transfer of Data
The transfer of paper based personal data and information between us and our AOs 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 us and our AOs is by either email 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.
If requested, we can advise you of the personal data we hold about you and rectify any incorrect personal data about you or erase your personal information. The erasure of your personal information may be subject to contractual or legal restrictions, and we may therefore 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.
8. 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:
• 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
• 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
• 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
• 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 The Building Block as a commercial entity and ensuring that appropriate levels of courses are delivered to learners in line with our legitimate business goals.
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.
9. Lawful Basis
The lawful basis for us collecting and 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.
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 - legitimate interest of you and us
• Learners to seek confirmation of the certificates which have been issued to them by us - legitimate interest of you and us
• Us to issue a replacement managed learning programme or qualification certificate to a learner - legitimate interest of you and us
• Us to keep a permanent record of persons to whom we have issued a managed learning programme or qualification certificate - legitimate interest of you and us
• Us to keep a permanent record of persons, who have taught, examined and or assessed learners registered for our managed learning programmes and or qualifications - legitimate interest of you and us
• Us to keep a permanent record of persons who have conducted internal and or external quality assurance of our managed learning programmes and or qualifications - legitimate interest of you and us
• Us to assist an investigation to an incident or complaint or where there is pending litigation - legitimate interest of you and us
• 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 managed learning programme or qualification - legitimate interest of you and us
• Us to remind individuals of any pending expiry of qualifications - legitimate interest of you and us
The purpose of us keeping learner personal data and the legal basis for doing so for a limited time is to enable us:
1.Where required contractedly or legally to provide data to:
• Qualification Regulators
• Registration Bodies
• Industry Bodies
• UK Government Departments
• Law Enforcement Agencies.
Legitimate interest of you and us.
2.Personal Data of Tutors, Assessors and Internal Verifiers (Employees of Approved Centre) which maybe held by us at our centre.
The purpose of us keeping personal data and the legal basis for doing so of Tutors, 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 our managed learning programmes and or qualifications - legitimate interest of us and them.
• Us to keep a permanent record of persons who have conducted internal and or external quality assurance of our managed learning programmes and/or qualifications - legitimate interest of us and them.
The purpose of us keeping personal data and the legal basis for doing so of Tutors, Assessors and Internal Verifiers for a limited time is to enable:
• Us to remind individuals of any pending expiry of relevant qualifications - legitimate interest of us and them
• Us where required to contractedly or legally provide data to:
Qualification Regulators
Registration Bodies
Government Deparments
Law Enforcement Agencies
Legitimate interest of us and them.
10. 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.
11. 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.
12. 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 you do not want us to delete it
• It is not relevant anymore, 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, please contact us via email data@worcestercommunitytrust.org.uk
13. 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 (data@worcestercommunitytrust.org.uk) or post (The Building Block, Shap Drive, Worcester WR4 9NX).
Our complaints policy and procedure is available upon request and if you remain dissatisfied with our response to you, you have the right to make a complaint to the Information Commissioner’s Office.