Learner Personal Data

Introduction

The City & Guilds Group is committed to data security and the fair and transparent processing of personal data. This privacy policy (Policy) sets out how members of the City & Guilds Group, including ILM, treat learner personal data.

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

Who are we?

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), The City and Guilds of London Institute is the ‘controller’ of learner personal data. The City and Guilds of London Institute is a charity incorporated by Royal Charter, with registered charity number 312832 (England and Wales) and SC039576 (Scotland). Our registered address is 1 Giltspur Street, London EC1A 9DD.

ILM is a City & Guilds Group Business providing qualifications, training, assessment and certification products and services in relation to leadership and management (ILM, we, us, or our).

The City & Guilds Group includes The City and Guilds of London Institute, and its associated companies (including City & Guilds International Limited), and its Group Businesses (including ILM).

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Representative by sending an email to gdpr@cityandguilds.com or writing to Privacy Officer, City & Guilds, 1 Giltspur Street, London EC1A 9DD.

What personal data do we collect?

We collect your name, gender, and date of birth. We may also collect other categories of personal data if required in relation to a specific qualification or programme, and personal data if required to carry our quality assurance processes, investigations, complaints and appeals. This personal data is provided to us by Centres, Providers, awarding bodies, or other industry bodies you have registered with to receive learning, assessment, and/or certification products and/or services provided by us.

In exceptional circumstances, we may be provided with sensitive personal data, such as information about your health, to enable us to administer requests for reasonable adjustments, or sensitive personal data relating to an investigation, complaint, or appeal. Such information should only be provided to us by your Centre or Provider if you have given your explicit consent to your Centre or Provider.

We assign a unique learner number to each learner at the point of learner enrolment which we also use in relation to your learning, assessment, and certification.

How do we use your personal data?

We may use your personal data where this is necessary to pursue our legitimate interests as a provider of training, assessment, and certification products and/or services, including to:
  • provide you with products and/or services for which you have registered;
  • undertake administration in relation to products and/or services for which you have registered;
  • provide you with a certificate, credential or other record of learning;
  • contact you directly in relation to our quality assurance processes, investigations, appeals, and complaints;
  • contact you directly in relation to new and existing products, services, news, awards and events offered by ILM or a member of the City & Guilds Group;
  • assess and provide reasonable adjustments in relation to your learning or assessment where requested.

We may also process your personal data if required by law, including to respond to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

Who do we share your personal data with?

We may share your personal data with relevant third parties, where necessary, in relation to your learning, assessment, or certification, including:
  • regulatory authorities, sector skills councils, professional bodies, and similar industry bodies;
  • consortiums, authorised representatives, and partners; and
  • centres, providers, awarding bodies and similar third parties.
We may share your personal data with The Institute of Leadership & Management (TILM) to enable TILM to offer you student membership in relation to leadership and management. You can find out more about TILM at www.institutelm.com

We may also share your personal data with third party providers including:
  • legal and other professional advisers, consultants, and professional experts;
  • service providers contracted to us in connection with provision of learning, assessment, and training products and services such as markers, moderators, assessors, certification or credentialing providers, IT services and customer relationship management services; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will ensure there is a contract in place with such third parties which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data is protected by appropriate safeguards, including the use of model data protection clauses adopted or approved by the relevant authority where the data protection authority does not believe that the country has adequate data protection laws.

We may also share your personal data with members of the City & Guilds Group. You can read more about our group companies at www.cityandguildsgroup.com

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

We will retain personal data relating to your learning, assessment, and certification to enable us to provide information about your learning or a replacement certificate.

We will retain personal data relating to our quality assurance processes, appeals, or investigations for a period of 7 years to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

Where do we store your personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Your rights

Under the GDPR, you have various rights with respect to our use of your personal data:

Right to Access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if there is no basis for your request, or if it is excessive.

Right to rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Right to restrict processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.

Right to data portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request make such request, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Contact

If you have any queries about this Policy, the way in which City & Guilds processes personal data, or about exercising any of your rights, you can contact our Privacy Representative by sending an email to gdpr@cityandguilds.com or writing to Privacy Officer, City & Guilds, 1 Giltspur Street, London EC1A 9DD.

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.

Changes to our Policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.