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Privacy Policy

How will your personal data be used? 

Mentor Training Solutions (MTS) will use the personal data collected during the course of your training, assessment or qualification to:

  • Deliver and verify your training, assessment or qualification and produce a certificate
  • Create training records
  • Provide your company with a complete and accurate record of your training history

Your data will be securely stored by the Company and shared only with those who legitimately require the information such as the relevant accrediting bodies, regulatory bodies or government organisations (for example the Education Skills Funding Agency) or as required by law.

Data will be held for as long as is required to provide your company with a complete and accurate record of your training history. For more information on how your data is handled and stored see below for our full GDPR policy. 

MTS is registered as a Data Controller (no.ZA157387) with the Information Commissioner’s Office (ICO).

Introduction

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

MTS is registered as a Data Controller (no. ZA157387) with the Information Commissioner’s Office (ICO), see Appendix A for contact details.

Personal Data Held and Reasons for Processing

In order to conduct its business, MTS 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 completed a course/qualification or pass the information on to the recognised accrediting body who produce the individual’s certificate, for example IPAF or MPQC
  • Produce ‘training reports’ when requested by a company who require visibility of their workforce training/qualification completions – this will include details of their employees who have been on courses/qualifications arranged by MTS
  • Share the individual’s details with the appropriate accrediting body for the type of training/qualification undertaken
  • Share the individual’s details with MTS instructors/assessors and approved sub-contractor providers who are responsible for ensuring the right individuals receive scheduled training/assessment
  • Process sales invoices to companies or individuals for services or training materials provided by MTS
  • Process purchase invoices for services or materials provided to MTS
  • Deliver an Apprenticeship programme where personal learner information is collected in-line with government agency requirements
  • Satisfy Ofsted requirements around learners with protected characteristics under the Equality Act (2010)

MTS holds electronic data on individuals in the CRM (Customer Relationship Management) system, accounting package, Office 365, e-portfolio system, iAuditor, Class Marker and within the file structure on the server.

MTS records and stores data on paper forms required to:

  • Carry out its business service - to train and assess individuals who require training or qualifications
  • To produce a certificate for an individual who has completed a course or qualification
  • To maintain a record of the individuals’ training/qualifications
  • To share proof of training/assessment with the relevant accrediting bodies to allow them to produce a certificate in line with their standards
  • Record feedback in relation to their learning experiences and for apprentices personal development and welfare
  • Maintain accurate information as required in relation to the provision of the Apprenticeship programme

The information held on MTS’s systems includes the collection and storage of:

  • The company and company contacts with whom MTS’s Sales Teams and other departments communicate
  • The individual contacts, employed by these companies, who undertake a training course or qualification with MTS
  • Individuals who have booked to attend a training course or qualification with MTS
  • Associate instructors/assessors and approved subcontractor providers who carry out work on behalf of MTS

Data Collection and Storage

Data held on the MTS’s systems includes:

  • Tracking Online Activity

MTS 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.

  • Company Contacts
    • The company whom MTS has been requested to deliver training/qualifications on behalf of
    • Company contact’s forename and surname
    • Contact’s 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
    • Forename and surname
    • Employee number
    • National Insurance Number*
    • Home address*
    • Date of birth*
    • Course/qualification dates
    • Course/qualification details
    • Scores
    • Passed/failed
    • Photograph

*National Insurance Numbers, home addresses and dates of birth are mandated as unique identifiers by some of the accrediting bodies with whom MTS works.

Individuals’ data is collected through the completion of electronic and hardcopy forms such as test sheets, registration forms and course evaluation forms. These forms are completed by the individual on the course and by instructors/assessors who are authorised as a sub-processor by MTS. Data may also be provided in advance of the course via email or telephone to allow registration on the training course or qualification.

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

Data collected is used to create a certificate for the individual 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 MTS. 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/qualification with MTS. Certificates may also be stored on the e-portfolio system.

Apprenticeships

Data is collected for the purposes of the Apprenticeship programme and the drawing down of funding from the Apprenticeship Levy Fund. It is also collected to satisfy Ofsted requirements under the Education Inspection Framework. The information collected includes:

  • Name
  • Company
  • Gender
  • Sexual orientation
  • Date of birth
  • National Insurance Number
  • Enrolment date
  • Home address
  • Telephone number
  • Email address
  • Emergency contact name
  • Emergency contact number
  • Proof of ID
  • Photo
  • Ethnicity
  • Religion/belief
  • Citizenship
  • Nationality
  • Residency
  • Disability
  • Learning difficulty
  • First language
  • Previous education level
  • Qualifications
  • Receipt of benefits
  • Household employment
  • Household members (one or more adults and any dependants)
  • If the learner is currently in custody or on remand
  • Current employment status

This information is collected and recorded only by authorised personnel in the Apprenticeships Team. Data is password-protected and any hard copies are kept in a locked and secure location.

Sharing of Data

MTS only shares data with those who legitimately require the information to complete the purchase contact with the individual themselves or their employer, as well as via secure online government portals, as required by law with government departments and bodies. Training companies are required to share data of individuals who have been trained/assessed with the appropriate accrediting body. Individuals' data is shared to the following people/organisations:

 

  • With the company that ordered the training/qualification 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/assessor that carried out the training/testing/assessment
  • 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/qualification start date
    • Course/qualification end date
    • Length of course/qualification
    • Duration of course
    • Test/assessment date
    • Instructor/examiner/assessor name and registration number
    • Course/qualification type
    • Equipment/environment type
    • Photograph

*National Insurance Numbers, dates of birth and home address may be mandated as unique identifiers by some of the accrediting bodies with whom MTS is approved.

  • The individual data of apprentice’s is shared with the Education and Skills Funding Agency, as required by the Apprenticeship Funding Rules. This will include:
    • Unique Learner Number
    • Name
    • Date of birth
    • Ethnicity
    • Sex
    • Disabilities and learning disabilities
    • National Insurance Number
    • Prior attainment
    • Home address
    • Telephone number
    • Email address
    • Employment status
    • Employment start date
    • Employer ID
    • Learning start date
    • Planned learning end date
  • Some individuals’ and companies’ data is shared with the approved trainer/assessor as required to deliver the training. This will include:
    • Company name and address
    • Site contact name
    • Individual name
    • Individual employee number
    • Course/qualification start date
    • Course/qualification end date
    • Length of course
    • Course/qualification type
    • Equipment /environment type
  • Some apprentices’ data is shared with Ofsted as per its inspection remit. The data shared may include some or all of that listed on pages 3/4 of this document

All of the data that MTS holds on non-apprenticeship individuals who have undertaken courses is classed as low risk except home addresses which are required by some of the accrediting bodies. Apprenticeships data is categorised as medium risk and is held in a secure location by the Apprenticeships team. MTS do not hold information on financial records.

Accuracy of Data

Collection of New Contacts and Accuracy of Data

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

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

Although this is not an exhaustive list, MTS 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

MTS 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. MTS does not use purchased leads to build up its contact database.

Data Security and Data Breaches

MTS 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. MTS’s website is tested against hackers ensuring that there is no ‘backdoor’ entry to gain access to the IT system and individuals’ data. No personalised learner information related to the Apprenticeship programme is hosted on MTS website.

If MTS do suffer a personal data breach, the Data Controller will notify the ICO and the affected parties within 72 hours of the breach. MTS 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

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, MTS will disclose the requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Board and from the MTS’s legal advisers where necessary.

Providing Information

MTS 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, MTS has a privacy statement setting out how data relating to individuals is used - this is available on request. A version of this statement is also available on MTS’s website.

Right to be Forgotten

Due to the nature of the industry in which MTS operates, we believe in the Right to be Forgotten:

  • Attendees of a course/qualification: if an individual employed by a company requests the right to be forgotten, MTS 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/qualification 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

Deleting Data

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

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

  • Personal data for people who have attended one of our courses/qualifications 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
  • Apprentice information is retained electronically for an indefinite period. This allows MTS to provide it upon request to governmental bodies or related organisations with a legal remit. After 7 years, archived physical files will be removed and shredded on-site by an approved secure shredding company

 

 

 

 

 

 

 

 


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