1. Who we are
1.1 DLC Training, part of Network Three Sixty Ltd, is the data controller in relation to the processing activities as described below. This means that Network Three Sixty Ltd on behalf of DLC Training decides why and how your personal information is processed. Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it is referring to DLC Training, part of Network Three Sixty Ltd.
1.2 DLC will share the information you provide, together with other information, with our group companies. We will use this for administration, marketing, customer services and profiling your purchasing preferences. We will disclose your information to our service providers and agents for these purposes. We may keep your information for a reasonable period to contact you about our services.
1.3 You have the right to ask for a copy of your information and to correct any inaccuracies. We may record telephone calls for staff training and evidential purposes.
2. What information do we collect about you and how do we collect it?
Information that you give to us:
2.1 As soon as you contact us, we create a record on our database in your name. To that record we add the information that you give us when reserving, registering or enrolling and throughout your studies. We keep records of your participation in learning activities and your use of other services we offer, e.g. membership packages, career support, disability services and employability services. We may respond to your enquiry with an automated message. This message details our hours of work, contact information for our team and useful information relating to your enquiry.
2.2 We hold general information about you, such as your name, address, contact details, D.O.B, modules and qualifications studied and fee payments, as well as data relating to examinations, assessments, course results and current or previous job roles. You may give us information about “special categories” of data, including your racial or ethnic origin, religious beliefs, physical or mental health, or sexual orientation. You might also give us information about your criminal convictions. ELCAS funded students are required to provide us with their service number as described in 2.7.
2.3 It is likely that you will give us further personal information when you start to use some of our services, for example, our employability service. You will be given more information about what we do with your personal data when you start to use the service.
Information that we automatically collect:
2.4 We will automatically collect information about your participation in online learning and assessment activities, your use of module and related websites, and all forms of assessment activities (essays, assignments, evidence based work submissions, exams, etc.) We will also add to your record any activities that you carry out on our website. This might include self-test quizzes you complete, or additional resources you review.
2.5 We may automatically collect technical information when you browse our websites. Further information about this is given in our Privacy and Cookies Policy.
2.6 We record telephone calls and monitor other communications between you and DLC to make sure that we have carried out your instructions correctly and to help us improve our services through employee training. If you receive email marketing communications, we record if you open them.
2.7 If your fees are paid by another organisation, they may provide some information about you to us. Further information would be available to you in the relevant privacy notices and registration documents. We will contact the relevant organisation on your behalf and will share with them information provided to us during your registration. To qualify for ELCAS funding students are required to provide us with their service number. This information will only be shared with ELCAS at the time the funding request is submitted.
2.8 If you are not currently studying with DLC, we may enhance our records with data received from third parties, in order to ensure we have up to date contact details for you, and in order to offer you more relevant communications. We will only send you marketing communications if your communications preferences allow this.
By providing this information, you give us consent to use your sensitive personal data e.g. information about any physical disability, solely for the purposes for which you submit it.
Information you give us about other individuals
When you give us information about another person, you confirm that they have authorised you to act for them, to consent to the processing and use of their personal data in the manner described in this notice and to receive on their behalf any data protection notice or policy applicable.
3. How do we use your personal information?
3.1 We collect and process a broad range of personal data about you to enable us to deliver our services and support you, to manage our operations effectively, and to meet our legal requirements.
3.2 If at the time of registration you do not provide us with some of the information we require then we may not be able to effectively provide support or administration services to enable you to succeed in your study.
3.3 We use your “special categories” of data for activities including: equal opportunities monitoring, identifying if you need support (in conjunction with other learning analytics data), informing academic research, providing you with relevant opportunities, and ensuring that views of students with specific protected characteristics are represented.
3.4 Information about any disabilities and special requirements you have will also be used to inform the provision of reasonable adjustments and other provisions for your study.
3.4 You may submit additional “special category” information to us, for example medical evidence for funding, information about your religion relating to special circumstances for an examination, or information pertinent to an enquiry or complaint. We only use this information for the purpose for which it was provided and will reconfirm this at the time any such information is requested.
3.5 Detailed information on the purposes we use your information for is provided in Appendix 1. We are committed to the data protection principles of good practice for handling information. All personal information is held securely and we will only transfer data within Network Three Sixty Ltd on a ‘need-to-know’ basis so that we can support you with our academic, and other, services.
Managing unwanted communications:
3.7 We will contact you in connection with your studies or for administration or support purposes. We may also send you marketing information, or invite you to take part in research to improve our services. If you do not wish to receive these communications, you can change your communications preferences by using the information in Section 8.
4. Who do we share your information with?
4.1 We share data with a number of organisations for specific purposes. For example,
- When you register as a student, we will share some information with the Network 360 as you automatically become a member.
- We share data with other organisations where we have a legal or regulatory obligation to do this, for example with our regulating or awarding bodies and with government departments.
- We share data with organisations that provide funding, for example ELCAS
- We may disclose your information to our third-party service providers and agents for the purposes of providing services to us, or directly to you on our behalf. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
- If you are studying towards a qualification that leads to professional recognition we will share some of your information with the relevant professional body. More detailed information on who we share your personal information with is available in Appendix 2.
4.2 We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our enquirers, visitors and students. However, we will always aim to ensure that your privacy rights continue to be protected.
4.3 Information you provide to us is stored on our secure servers, or on our cloud based systems which are located within the EEA.
5. How long do we keep your personal information for?
5.1 If we collect your personal information the length of time we keep it for is determined by a number of factors including our purpose for using the information and our legal obligations.
5.2 We have a retention schedule for information and keep identifiable records only for as long as they have a legal or business purpose:
- We keep academic transcript data at least until student date of birth + 100 years, in order to provide references and verify your study with us.
- We keep some information relating to the module or qualification, and related queries and communications, until six years after you have completed the module or qualification, in order to inform our ongoing relationship with you, and in case it is necessary to establish, bring or defend legal claims.
- We destroy some information within three years, where it does not have a longer term impact, and is not required for business purposes. For example, we will destroy some data that is relevant to exams and assessment shortly after the result is decided, and we will only keep the result itself.
6. Your rights
6.1. You have a number of rights in relation to your personal information, which apply in certain circumstances. These rights are as detailed under the General Data Protection Regulation (GDPR) – 25 May 2018. In order to exercise any of these rights, please contact us using the details in Section 8 of this document.
6.2 You have the right to:
- access the personal information that we hold about you
- correct inaccuracies in the personal information that we hold about you
- request that we stop sending you direct marketing communications.
In certain circumstances, you have the right to
- have your details removed from systems that we use to process your personal data
- restrict the processing of your personal data in certain ways
- obtain a copy of your personal data in a structured electronic data file
- object to certain processing of your personal data by us
If you are concerned about the way we have processed your personal information, you can complain to the Information Commissioner’s Office (ICO). Please visit the ICO’s website (https://ico.org.uk/) for further details.
7. Contact us
7.1 Our Data Protection Officer is Kimberley Jayne. Please direct any queries about this policy or about the way we process your personal information using the contact details below.
Email: firstname.lastname@example.org Telephone: +44(0)191 3787520 By post: The Data Protection Officer, DLC Training, Severn House, Mandale Business Park, Belmont Industrial Estate, Durham, DH1 1TF.
You can update your contact preferences by using any unsubscribe options available in communications we send you, or by contacting us.
Glossary of Terms
According to the General Data Protection Regulation, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone browser from a website’s computer and is stored on your computer’s or mobile phone’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, which the site can then access when you visit it again to track online traffic flows, for example. A website cannot access cookies sent by other websites.
A data controller determines the purposes for which and the manner in which any personal data are processed. In essence, this means that the data controller decides how and why personal data are processed.
There are nine characteristics protected under the Equality Act 2010. They are: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.
Special categories of data
The General Data Protection Regulation sets out “special categories” of data which have to be given additional protection. These comprise your racial or ethnic origin, religious beliefs, political opinions, trade union membership, genetics, biometrics (where used for ID purposes) physical or mental health, sex life and sexual orientation. Information about criminal offences or criminal proceedings are treated similarly.
Activities relating to your contract with DLC Training and Network Three Sixty Ltd;
The following data processing activities are necessary for the contract we have with you, as set out in your Registration Agreement and Conditions of Registration. They include:
- Registering you as a student
- Administering your fee payment
- Maintaining your student record
- Administering your study, including your learning events and placements, access to systems, examinations and assessments, facilitating special circumstances for assessment and examinations, etc.
- Providing support services which are necessary for your study, e.g. IT helpdesk services, disability services, and Library resources and services
- Managing queries, complaints, appeals and allegations of misconduct
- Providing academic support.
- Ensuring a safe environment.
1.2 We may use and process your personal information where it is necessary for us to pursue our legitimate interests for the following purposes:
1.2.1 Communications and marketing purposes
- To send you marketing communications about our modules, qualifications, or other services. You are able to opt out of receiving marketing communications by using the details in section 9.
- To stay in touch with you after you complete your Qualification. You will be contacted when you complete your studies with further details.
- To analyse our student body to inform our marketing strategy and to enhance and personalise your customer experience
- To verify the accuracy of data that we hold about you and create a better understanding of you as a customer.
1.2.2 Internal activities
- To prevent fraud and other criminal activities, for example fraud in relation to public funding
- To audit our activities in order to ensure regulatory compliance
- To monitor use of IT services and ensure network and information security
- To test and maintain our systems and to ensure robust performance
- To help us improve our services through employee training
2. Who do we share your Personal Data with?
2.1 Where we have a legal obligation to share data
- If you apply for discretionary financial support, we share information with the relevant financial authority.
2.2 Where we share data as part of your contract to study with us
- If your fee or part of your fee is paid by sponsorship, information may be released to your sponsor organisation, including your name, Personal student number, module details and module result.
- If you are studying a qualification or programme that leads to professional recognition we will share some information with the relevant professional body. This is necessary for you to be registered with the professional body as a student of their education programme, in order for them to ensure we are upholding their standards and for them to provide you with certification of achievement, memberships or registration as required during your training.
2.3 Sharing under other legal bases
- We will provide academic references and confirmation of study to prospective employers and to your local authority or council, with your consent.
- We will share information with the police and other agencies where necessary for the prevention and detection of crime.
2.4 Third party suppliers and service providers
We use third party suppliers and service providers for a number of activities, from providing IT systems, to providing accredited qualifications and conducting market research. It is in our legitimate interest to use third party suppliers to maintain cost effective and efficient operations. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.