Cuckmere Training Privacy Policy & GDPR Notice 1.1 - February 2024

 

We are committed to protecting every customer's personal information. We are also committed to being transparent about what information we hold and for what purpose. This privacy policy will explain how our Cuckmere Training uses the personal data we collect from you when you use our website and our services. All learners must sign the GDPR declaration in the learner handbook.

 

 

This policy explains:

 

1. Data Protection

2. Data Collection

3. How We Use Your Data

4. Data Security

5. Data Breach Response

6. Access To Records

7. Rights Of Individuals

8. Children's Data

9. Consent for Data Processing and Marketing

10. Marketing Communications

11. Website Cookies & Tracking Technologies

12. Notification of Changes in Personal Information

13. Revisions and Updates

14. How to Contact Us

15. How to Contact the Appropriate Authority

 

 

Policy Language

'You or Your' - The Customer, Party or Individual using or accessing our Services.

'We or Us' - Cuckmere Training

 

 

The terms of this policy may change occasionally, and it is your (the customer's) responsibility to check back and read the updated terms and conditions.

The current update for this policy is February 2024.

 

 

This policy is written in accordance with the General Data Protection Regulation (GDPR) guidelines. We are registered with the Information Commissioner's Office (ICO) as a data controller under the name and number Emma Chapman - ZB593899, registered on 8th September 2023.

 

 

1. Data Protection:

In accordance with both the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), Cuckmere Training is committed to ensuring the accuracy and up-to-date personal data held about Learners and Staff Members. This commitment reflects our understanding of the vital role accurate data plays in the effective and efficient functioning of our organisation.

 

1.1. Specific Measures:

 

1.1.1. Cuckmere Training utilises various methods to facilitate data accuracy,

including requiring individuals to provide accurate and complete information upon data collection.

 

1.1.2. Enabling individuals to review and update their personal data through designated channels.

 

1.1.3. Implementing automated or manual processes to verify and update data based on reliable sources periodically.

 

1.1.4. Cuckmere Training shall take reasonable steps to erase or rectify inaccurate personal data without undue delay upon notification or discovery.

 

1.2. Benefits of Accurate Data:

Maintaining accurate and up-to-date personal data empowers Cuckmere Training to:

 

1.2.1. Provide efficient and personalised services to Learners and Staff Members.

 

1.2.2. Fulfil legal and regulatory obligations concerning data protection.

 

1.2.3. Make informed decisions based on reliable and accurate information.

 

 

2. Data Collection

 

2.1. Categories of Personal Data Collected:

Cuckmere Training collects various categories of personal data depending on your interaction with our services. This data may include:

 

2.1.1. Identity and Contact Information: Name, email address, postal address, and phone number.

 

2.1.2. Financial Information: Payment details used for transactions and services.

 

2.1.3. Technical Information: IP address, browser information, and device data from website usage (when collected through cookies).

 

2.1.4. Interaction and Feedback Data: Information provided through online forms, surveys, product reviews, or direct communication via email or social media platforms like Facebook and LinkedIn.

 

 

2.2. Methods of Data Collection:

Cuckmere Training collects personal data through the following means:

 

2.2.1. Direct Provision: You provide data directly when you Register for services online.

 

2.2.2. Subscribe to our newsletter.

 

2.2.3. Complete online forms or surveys.

 

2.2.4. Submit feedback or reviews on our website or social media platforms.

 

2.2.5. Automated Collection: Information about your website usage may be collected through cookies (More information can be found in section 11 of this policy)

 

 

3. How do we use your data?

Cuckmere Training collects your data so that we can:

 

3.1. Purposes of Personal Data Processing:

Cuckmere Training processes your personal data for legitimate purposes that comply with applicable data protection regulations. These purposes include:

 

3.1.1. Service Fulfilment: Primarily, we process your data to fulfil your orders for any of our services. This may involve tasks such as:

 

3.1.1.1. Processing payment information.

 

3.1.1.2. Creating and managing your account.

 

3.1.1.3. Providing customer support and product updates.

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3.1.2. Marketing and Promotional Communications: 

With your explicit consent, we may use your data to send you marketing communications about products and services that we believe might be of interest to you. This may include:

 

3.1.2.1. Personalised email marketing campaigns.

 

3.1.2.2. Targeted advertising on other websites or platforms.

 

 

4. Data Security & Compliance

Cuckmere Training is committed to complying with the Data Protection Act 2018 and any other relevant data protection regulations. We undertake the following measures to ensure the security and integrity of personal data:

 

4.1. Data Controller:

The Centre Manager is designated as the data controller responsible for processing personal data with the support of the Lead IQA when necessary.

 

4.2. Lawful Processing and Transparency:

We collect and process personal data only for legitimate purposes specified at the point of collection, such as learner induction, service fulfilment, and regulatory compliance. Individuals are informed about the data collected, the purposes of processing, and their data protection rights during induction and through accessible policy documents.

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4.3. Data Accuracy and Retention:

Data is kept accurate and up to date through regular reviews and verification procedures. We retain personal data only for the minimum period necessary for the identified purposes, considering legal and regulatory requirements. For example, learner records are kept for at least three years after qualification completion.

 

4.4. Data Security Measures:

Cuckmere Training implements appropriate technical and organisational safeguards to protect personal data from unauthorised access, use, disclosure, alteration, or destruction. These measures include:

 

4.4.1. Electronic data storage with password protection and encryption when applicable.

 

4.4.2. Physical security measures for paper records in locked cabinets/cupboards.

 

4.4.3. Staff training on data security best practices, including secure handling of files and preventing unauthorised access.

 

4.4.4. Utilisation of OneFile e-portfolio system with secure data storage and backup capabilities.

 

4.4.5. Implementation of screen blanking/lock to prevent unauthorised access to data on unattended devices.

 

4.4.6. Secure storage and disposal of confidential printouts.

 

4.5. Access Control and Sharing:

Access to personal data is restricted to authorised staff and third-party processors with a legitimate need to access the data. We have data-sharing agreements in place with third-party processors, ensuring they uphold similar data security standards.

 

4.6. Individual Rights:

We respect and uphold individuals' data protection rights under the Data Protection Act 2018, including the right to access, rectify, erase, and restrict the processing of their personal data.

 

 

5.Data Breach Prevention & Response

Cuckmere Training recognises the importance of data protection. It is committed to safeguarding the personal information of its Learners, Staff Members, and other individuals and actively implements comprehensive procedures to prevent, detect, report, and investigate any data breaches in strict compliance with the General Data Protection Regulation (GDPR). In the event of a confirmed personal data breach involving the data of individuals, Cuckmere Training and the appointed Data Protection Officer shall undertake the following actions:

 

5.1. Immediate Risk Mitigation:

Upon detection of a data breach, Cuckmere Training will prioritise immediate actions to mitigate potential risks to the rights and freedoms of individuals whose data may be compromised. These actions may include:

 

5.1.1. Containment: Swiftly isolating the affected systems or data to prevent further unauthorised access or dissemination.

 

5.1.2. Data restoration: Restoring affected data from secure backups where possible.

 

5.1.3. Password resets: Promptly requiring password resets for any potentially compromised accounts.

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5.2. Thorough Investigation:

Cuckmere Training will conduct a comprehensive investigation into the data breach to determine the following:

 

5.2.1. The origin and nature of the breach: Identifying the root cause and vulnerability exploited.

 

5.2.2. The scope and extent of the breach: Assessing the volume and types of personal data affected.

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5.2.3. The potential impact on individuals: Evaluating the risks posed to the rights and freedoms of affected individuals.

 

5.3. Supervisory Authority Notification:

Cuckmere Training will notify the relevant data protection supervisory authority within 72 hours of becoming aware of a personal data breach unless the breach is unlikely to result in a high risk to the rights and freedoms of individuals. This notification will include:

 

5.3.1. Details of the breach: Nature of the incident, affected data, and estimated number of individuals involved.

 

5.3.2. Measures taken to address the breach: Mitigation efforts implemented and planned further actions.

 

5.3.3. Contact information for further inquiries: A designated point of contact for the supervisory authority.

 

5.4. Individual Notification:

Cuckmere Training will promptly notify affected individuals without undue delay when a data breach is likely to result in a high risk to their rights and freedoms. This notification will:

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5.4.1. Explain the nature of the breach: Clearly describe the incident and the type of personal data affected.

 

5.4.2. Inform them of potential risks: Outline the potential consequences for the individuals involved.

 

5.4.3. Provide recommendations for mitigation: Advise individuals on steps they can take to protect themselves.

 

5.4.4. Offer contact information for support: Provide a dedicated contact point for questions and concerns.

 

 

5.5. The Data Protection Officer (DPO) Role and Responsibilities:

 

5.5.1. Advising Cuckmere Training on its data protection obligations and compliance with relevant regulations (GDPR, Data Protection Act 2018).

 

5.5.2. Implementing and monitoring internal data protection policies and procedures.

 

5.5.3. Handling data subject requests (right to access, rectify, erase, restrict processing).

 

5.5.4. Responding to inquiries and complaints about data protection practices.

 

5.5.5. Liaising with the supervisory authority (Information Commissioner's Office) on data protection matters.

 

5.5.6. Raising awareness and providing training on data protection within Cuckmere Training.

 

 

DPO Contact Information:

Name: Jonathan Relf

Email: dpo@purepublishing.net

Email Subject Line: Cuckmere Training

 

 

Individuals with questions or concerns about their personal data or Cuckmere Training's data protection practices can contact the DPO directly using the information provided above.

 

 

6. Access to Records

All records or information held about Learners and Assessors will remain confidential and held securely.

 

6.1. Upon request, all Learners and Assessors have the right to access their retained records and information under the Access to Health Records Act 1990. They will also be informed about the reasons for their retention.

 

6.2. All individuals will have the right to see the information held about them and check for inaccuracies.

 

6.3. Access to all records will be limited to 'those who need to know'.

 

6.4. No personal information about an individual shall be disclosed to any third party without the prior written consent of the Learner or Associate Assessor/IQA, as applicable. Such consent shall be specific, informed, and unambiguous.

 

6.5. All learner qualification evidence shall be uploaded and stored electronically on OneFile unless a written request for a paper-based portfolio is submitted. In the case of a paper-based portfolio, the physical signatures and initials of the learner, assessor, Internal Quality Assurance (IQA), and External Quality Assurance (EQA) shall be obtained and securely stored within the front of the portfolio. The IQA shall employ red ink to visibly sample and date any selected work. Learners shall also be required to sign and date their submitted evidence, thereby acknowledging its authenticity as their own work.

 

 

7. Rights of Individuals

Cuckmere Training recognises and respects the rights of individuals under the General Data Protection Regulation (GDPR). These rights include:

 

7.1. Right of Access: In accordance with data protection legislation, individuals have the right to access their data held by Cuckmere Training. Subject Access Requests (SARs) must be submitted in writing to the Data Protection Officer (DPO).

  

7.2. Right to Rectification: Individuals can request the correction of inaccurate or incomplete personal data held by Cuckmere Training.

 

7.3. Right to Erasure (Right to be Forgotten): In accordance with applicable data protection legislation, individuals have the right to request the erasure of their data held by Cuckmere Training under certain circumstances specified in the legislation. Such circumstances may include but are not limited to where the data is no longer necessary to the purposes for which it was initially collected or processed or where the individual withdraws their consent, and there is no other legal basis for processing.

 

7.3.1. Upon receiving a valid request and subject to applicable legal and regulatory requirements, Cuckmere Training will erase all personal data associated with your account, including any course details that have been attended along with any certificates issued. Please note that exercising your right to erasure will permanently delete your certificates and course details, rendering them inaccessible. Cuckmere Training will no longer retain this information once the erasure is complete.

  

7.4. Right to Restriction of Processing: In accordance with applicable data protection legislation, individuals have the right to request the restriction of processing of their data held by Cuckmere Training under certain circumstances. Such circumstances may include but are not limited to where the accuracy of the data is contested pending verification and where the processing is unlawful. However, the individual opposes erasure, where the data is no longer necessary for the purposes for which it was collected but is required by the individual for the establishment, exercise, or defence of legal claims or where the individual has objected to processing pending the verification of legitimate grounds overriding their interests.

  

7.5. Right to Data Portability: In accordance with applicable data protection legislation, individuals have the right to receive their data held by Cuckmere Training in a structured, commonly used, and machine-readable format, such as CSV, JSON, or when available, PDF, and to transmit that data to another data controller where technically feasible. This right applies where the processing is based on consent, or a contract and the data is processed by automated means.

  

7.6. Right to Object: In accordance with applicable data protection legislation, individuals have the right to object at any time to the processing of their data for specific purposes, including where the processing is based on legitimate interests or for direct marketing purposes. In the case of direct marketing, individuals have the absolute right to object, and their data shall no longer be processed for these purposes. Cuckmere Training will provide precise opt-out mechanisms so individuals can easily exercise their right to object.

 

 

Requests to exercise these rights may be submitted in writing to the Data Protection Officer by addressing them to:

 

Jonathan Relf

dpo@purepublishing.net

Email Subject Line: Cuckmere Training

 

Cuckmere Training will acknowledge receipt of the request within three working days and respond to valid requests within one month of receipt unless a longer extension is permitted under applicable data protection legislation.

 

 

8. Children's Data

Cuckmere Training recognises the heightened importance of protecting the privacy of children under the age of 18 and adheres to applicable data protection legislation regarding their data. We only process the personal data of children with verifiable parental consent obtained in accordance with relevant legal requirements.

 

8.1. Parental Consent:

 

8.1.1. Cuckmere Training will clearly explain the intended use of a child's personal data before obtaining parental consent.

 

8.1.2. Consent mechanisms will be age-appropriate and designed to facilitate understanding by the parent or guardian.

 

8.1.3. We will implement reasonable measures to verify the parent or guardian's identity by providing consent, such as requesting unique identifiers or contacting them through established communication channels.

 

8.1.4. Parental consent can be withdrawn anytime by contacting the Data Protection Officer.

 

 

8.2. Data Use and Protection:

 

8.2.1. Cuckmere Training will treat children's data with enhanced care and security, considering their vulnerability and the potential risks associated with data processing.

 

8.2.2. Children's personal data will only be used for the specific purposes outlined in the consent form and not for any additional unrelated purposes.

 

8.2.3. We will implement appropriate technical and organisational measures to ensure the data's security and confidentiality.

 

8.2.4. Parents or guardians have the right to access, rectify, erase, or restrict the processing of their child's personal data by contacting the Data Protection Officer.

 

 

9. Consent for Data Processing and Marketing:

Cuckmere Training complies with applicable data protection legislation, including GDPR, and obtains individuals' freely given, specific, informed, and unambiguous consent before processing their personal data or using it for marketing purposes, online or printed.

 

9.1. Consent for Marketing:

 

9.1.1. A separate consent form will be presented outlining the specific use of your data or images for marketing materials, online or printed.

 

9.1.2. You will have the option to consent to or decline this explicit use of your data.

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9.2. General Consent Requirements:

 

9.2.1. Consent will be obtained through clear and accessible language, avoiding pre-ticked boxes or misleading practices.

 

9.2.2. We will provide sufficient information about the purposes of data processing, the types of data collected, and your data protection rights.

 

9.2.3. You have the right to withdraw your consent at any time for any specific purpose, including marketing, by contacting the Data Protection Officer.

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10. Marketing Communications:

Cuckmere Training would like to inform you about relevant products and services that might interest you. However, we respect your right to choose how you receive information from us.

 

10.1. Opt-in and Opt-out:

 

10.1.1. You can choose to receive marketing communications from Cuckmere Training by opting in through our 'Subscribers Form' displayed at the bottom of our website.

 

10.1.2. You have the absolute right to opt out of receiving marketing communications at any time. You can easily exercise this right by clicking the "unsubscribe" link at the bottom of any marketing email we send you.

 

10.1.3. or by contacting the Data Protection Officer at dpo@purepublishing.net

 

10.2. Respecting Your Preferences:

 

10.2.1. We will never share your personal data with third parties for marketing purposes without your explicit consent.

 

10.2.2. We strive to make our marketing communications relevant and valuable to you. You can manage your communication preferences and update your interests to receive more relevant updates.

 

10.3. Data Retention for Marketing Purposes:

Cuckmere Training retains your email marketing address information until you unsubscribe from marketing communications. We may also retain anonymised or pseudonymised data related to your marketing interactions for analytical purposes, but this data will not be used to identify you individually.

 

 

11. Website Cookies & Tracking Technologies:

Cuckmere Training, in accordance with applicable data protection regulations, utilises cookies and similar tracking technologies on its website(s) to collect information from users automatically. This information primarily consists of standard internet log data and user behaviour details to enhance your experience and website functionality.

 

11.1. How do we use cookies?

Cuckmere Training uses cookies for legitimate purposes such as:

 

11.1.1. Maintaining user login sessions

 

11.1.2. Analysing user website interactions and usage patterns

 

11.1.3. Enabling third-party analytics (e.g., Google, Facebook) for advertising purposes based on browsing activity (device type, browser, location, etc.)

 

11.2. What types of cookies do we use?

There are several different types of cookies; however, our website uses the following:

 

11.2.1. Functionality Cookies: These first- and third-party cookies facilitate user recognition and recall of previously selected preferences (language, location) for enhanced website navigation and experience.

 

11.2.2. Advertising Cookies: These cookies collect browsing data such as visited pages, clicked links, device information, and IP addresses. Cuckmere Training may share limited data with third-party advertising partners (e.g., Google, Facebook) for targeted advertising across other websites based on your browsing behaviour.

 

11.3. How to manage cookies

Users possess the right to manage and consent to cookie usage through their browser settings. Disabling cookies may impact website functionality. Please refer to allboutcookies.org for further details.

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12. Notification of Changes in Personal Information:

Cuckmere Training requires Learners and Staff Members to promptly notify the designated Manager about any changes to their personal information. This includes, but is not limited to, changes in:

 

12.1. Contact Information: Primary residence address, phone number, and email address.

 

12.2. Personal Details: Legal name, marital status, and other information relevant to your position or training program.

 

12.3. Reporting Process:

 

12.3.1. Address changes: Should your address change, please submit a written notification to the Manager via email to: info@cuckmeretraining.co.uk

 

12.3.2. Name changes: For legal name changes, such as due to marriage, please provide a copy of the relevant legal document (e.g., marriage certificate) to the Manager via email to info@cuckmeretraining.co.uk

 

 

13. Revisions and Updates to this Privacy Policy:

Cuckmere Training maintains its Privacy Policy under regular review to ensure continued alignment with evolving data protection regulations and best practices. We will promptly update this policy to reflect significant changes in data collection, processing, and disclosure practices.

 

 

13.1. Effective Date and Revisions:

 

13.1.1. This Privacy Policy became effective on 21st February 2024.

 

13.1.2. The following scheduled review of this Policy is February 2025. However, Cuckmere Training reserves the right to revise this Policy at any time and will post any updated versions on this webpage.

 

13.2. User Acknowledgement:

Your continued use of our website following the posting of revisions to this Policy constitutes your acknowledgement and acceptance of those changes. We encourage you to review this Policy for updates periodically.

 

 

14. How to Contact Us

For any inquiries, questions, or requests regarding this Privacy Policy, your personal data held by Cuckmere Training, or to exercise your data protection rights, please contact us using the following methods:

 

• Cuckmere Training Centre Manager: Emma Chapman

• Email: info@cuckmeretraining.co.uk

• Phone: 07432442672

 

• Data Protection Officer (DPO): Jonathan Relf

• Email: dpo@purepublishing.net

• Email Subject Line: Cuckmere Training

 

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15. How to Contact the Appropriate Authority

Should you wish to report a complaint or if you feel that Cuckmere Training has not addressed your concern satisfactorily, you may contact the Information Commissioner's Office.

 

Wycliffe House

Water Lane

Wilmslow

SK9 5AF

Helpline: 0303 123 1113

From outside the UK: +44 1625 545 745

ico.org.uk

 

 

 

 

Company Statement:

Under no circumstance will any Customers details be sold, given out or traded to anyone to ensure maximum service quality and data protection.

No credit card, bank details or personal data are ever stored by Cuckmere Training and nor do we share those details with anyone or any 3rd parties.