Mentor Training Solutions provide equipment
training and safety courses throughout the UK

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Privacy Policy

1.0 Context and Overview

Key Details

  • Policy prepared by: Emily Bonsall
  • Approved by Board 01/05/2018
  • Policy became operational on 25/05/2018
  • Next review date 01/05/2019

Introduction

For Mentor Training Solutions Limited (Mentor) to provide training, assessments and qualifications to it’s customers and clients, promote its services, maintain its own accounts and records and support and manage it’s employees and subcontractors, it gathers and uses certain information about individuals and companies directly and legitimately associated to Mentor’s business.

Mentor is registered as a Data Controller (no.ZA157387) with the information Commissioners Office (ICO) refer to Appendix A for contact details.

2.0 Personal Data Held and Reasons for Processing

In order to conduct its business, Mentor is required to hold electronic data to:

  • Accurately contact individuals responsible for arranging training for their workforce on their sites.
  • Allow for delivery of training to those individuals who have been nominated by their employer to complete a course or those individuals who have arranged their own training.
  • Produce a certificate for an individual who has attended a course or pass the information on to the recognised accrediting body who produce the individuals certificate, for example IPAF or NPORS.
  • Produce ‘training reports’ when requested by a company who require visibility of their workforce training completions- this will include details of their employees who have been on courses arranged by Mentor.
  • Share the individual’s details with the appropriate accrediting body for the type of training undertaken.
  • Share the individual’s details with Mentor instructors and approved sub-contractor providers who are responsible for ensuring the right individuals receive scheduled training.
  • Process sales invoices to companies or individuals for services or training materials provided by Mentor.
  • Process purchase invoices for services or materials provided to Mentor.

Mentor holds electronic data on individuals in the CRM (Customer Relationship Management) system, accounting package, Office 365 and within the file structure on the server.

Mentor records and stores data on paper forms required to:

  • Carry out it’s business service - to test individuals who attend training courses.
  • To produce a certificate for an individual who has attended a course.
  • To maintain a record of the individuals’ training.
  • To share proof of training with the relevant accrediting bodies to allow them to produce a certificate of training in line with their standards.

CRM:

The information held on Mentor’s CRM includes the collection and storage of:

  • The company and company contacts with whom the Mentor Sales Teams and other departments communicate.
  • The individual contacts, employed by these companies, who attend a training course.
  • Individuals who have booked to attend a training course with Mentor
  • Associate instructors and approved subcontractor providers who carry out work on behalf of Mentor

3.0 Data Collection and Storage

Data held on the CRM system includes;

  • Company contacts
    • The company whom Mentor has been requested to deliver training on the behalf of
    • Training contact’s forename and surname
    • Job title and role within the company
    • Contact’s phone numbers
    • Contact’s company email address
    • Company address
    • Opt in / opt out of which type of marketing communications
  • Individual’s data
    • Company whom the individual is employed by
    • Name
    • Employee Number
    • National Insurance Number*
    • Date of birth
    • Course dates
    • Course details
    • Scores
    • Passed / failed

*National Insurance numbers are mandated as unique identifiers by some of the accrediting bodies with whom Mentor is approved.

Individuals’ data is collected through the completion of forms known as test sheets, registration forms and course evaluation forms. These forms are completed by the individual on the course and by a sub-contracted instructor who is authorised as a sub-processor by Mentor.

The forms include a statement explaining why the data is being collected and with whom Mentor share it.

Data collected is used to create a certificate for the individual (delegate) which is then either sent via standard postage or recorded delivery to the contact at the individual’s workplace or a central contact, dependent upon the terms agreed in the contract between the company and Mentor. In some instances, certification is produced in an electronic format and saved on to a shared filing system that is accessed by the training department of the customer that arranged the training with Mentor.

  • Tracking online activity

Mentor track activity on their website and engagement with their online marketing via cookies and marketing analysis tools, for example Google Analytics. Data retention controls are in place to periodically remove user data over time.

4.0 Sharing of Data

Mentor only share data with those who legitimately require the information to complete the purchase contact with the individual themselves or their employer. Training companies are required to share data of individuals who have been trained with the appropriate accrediting body. Individuals' data is shared to the following people / organisations:

  • With the company that ordered the training in the form of a certificate and / or badge. This information will only include:
    • Name
    • Employee number
    • Company name
    • Equipment and course title
    • Dates of training
    • Name and registration number of the Instructor / Examiner that carried out the training / testing 
  • The individual’s data is shared with the appropriate accrediting body as required by Health and Safety Law. This will include:
    • Name
    • Date of birth
    • National Insurance Number*
    • Home address*
    • Course start date
    • Course end date
    • Length of course
    • Duration of course
    • Test date
    • Instructor / Examiner name and registration number
    • Course type
    • Truck type
    • Photograph

    *National Insurance numbers and home address may be mandated as unique identifiers by some of the accrediting bodies with whom Mentor is approved.

    • Some individual’s and company data is shared with the approved trainer/assessor as required to deliver the training. This will include:
      • Company name and address
      • Site contact name
      • Delegate name
      • Delegate employee number
      • Course start date
      • Course end date
      • Length of course
      • Duration of course
      • Course type
      • Truck type

                      All of the data that Mentor holds on individuals who have done courses is classed as low risk and does not include financial records or home addresses for these individuals.

                      Cookies are also used on the Mentor website to track shopping basket contents and remember where users are in the order process. Users can disable any cookies stored on their computer, but this may limit the functionality of the Mentor website.

                      The following are necessary for the website to function properly - the Mentor website will:

                      • Remember what is in your shopping basket
                      • Remember where you are in the order process
                      • Remember that you are logged in and that your session is secure. You need to be logged in to complete an order

                      The website will not share any personal information with third parties.

                      5.0 Accuracy of Data

                      Collection of new contacts and accuracy of data

                      Mentor endeavour to accurately collect the data it needs and provide clear and transparent justification for doing so, referenced at the point of collection, including a privacy policy that is accessible via the website or the App (once developed).

                      New contacts and sales leads must be constantly brought in to the company to ensure survival and growth. 

                      Although this is not an exhaustive list, Mentor aim to bring in new contacts through the following ways:

                      • Website
                      • Cold calling
                      • Visits
                      • Leads across company groups
                      • Leads through trade union groups
                      • Marketing – online and trade magazines
                      • Trade shows

                      Mentor will only market to / contact companies where we believe content will be of legitimate interest to the company / individual but will always provide them with the opportunity to opt out via links contained in every email. Mentor does not use purchased leads to build up its contact database.

                      6.0 Data Security and Data Breaches

                      Mentor protects itself to the best of its ability against data breaches through staff training and by keeping its IT systems up to date with the latest anti-virus, ransomware and firewall protection and by complying with the latest best practice for data storage and protection. Mentor’s website is tested against hackers ensuring that there is no ‘backdoor’ entry to gain access to the IT system and individuals’ data.  If Mentor do suffer a personal data breach, the Data Protection Leader will notify the ICO and the affected parties within 72 hours of the breach. Mentor consider a breach to be an occurrence involving a loss of data which presents a risk to the rights and freedom of any individuals involved and could result in:

                      • Discrimination
                      • Damage to reputation
                      • Financial loss
                      • Loss of confidentiality
                      • Any other significant economic or social disadvantage.

                      7.0 Disclosing Data for Other Reasons

                      In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies without consent of the data subject. Under these circumstances, Mentor will disclose requested data.  However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

                      8.0 Providing Information

                      Mentor aims to ensure that individuals are aware that their data is being processed and that they understand:

                      • How the data is being used.
                      • How to exercise their rights.

                      To these ends, the company has a privacy statement setting out how data relating to individuals is used by the company- this is available on request. A version of this statement is also available on the company’s website.

                      9.0 Right to be Forgotten

                      Due to the nature of the industry in which Mentor operates, we believe in the Right to be Forgotten;

                      • Attendees of a course: if an individual employed by a company requests the right to be forgotten, Mentor will first check with the company to ensure that they approve of this data removal from their training records. Once approved, the data can be removed from the CRM.
                      • CRM Contact: if a contact no longer wishes to be contacted then we can remove that individual’s data from the CRM. If we have provided training for their company then we cannot delete their company record from our CRM as individual training records will be associated to it.
                      • Tracked online activity: anyone who would like records of their online activity removed can request to do so by emailing the Data Controller.

                      10.0 Deleting Data

                      If a contract ends between Mentor and the customer, Mentor can provide all the personal data that they hold about the customer and the individuals within the organisation, if requested.

                      Mentor will not delete the associated training records as this data may be requested as evidence of training if for example, an individual has an accident.

                      • Personal data for people who have attended one of our courses must be stored and recorded to meet standards set by the Health and Safety Executive. The industry standard for keeping this data is a minimum of 7 years. After 7 years all paper copies of the personal data collected will be shredded on-site by an approved secure shredding company. Electronic data is stored back to 2007. Our customers use this data to prove compliance to the standards set by the accrediting bodies, legislation and HSE guidance.


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