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Our Privacy Policy

We are Train 2 Train Limited, a company incorporated in England with company number 07380504 and having its registered office at Office 22-23, The Rear Walled Garden, The Nostell Estate, Nostell, Wakefield, West Yorkshire, WF4 1AB (“we” / “our” / “us”). We are committed to ensuring that your privacy is protected. We will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the GDPR (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy.

Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Legislation to make sure that your information is properly protected and used appropriately.

This privacy policy provides information about the personal data we process about you, why we process it and how we process it.

The Website uses cookies to distinguish you from other users of the Website. For detailed information on the cookies we use and the purposes for which we use them, please see our cookie policy.

  1. Course Delegates and Apprentices

1.1 Why do we process your personal data?

We process your personal data in order to fulfil the contract we have entered into with you, to provide the services you have requested from us. We may also process your personal data to respond to any queries or comments you submit to us, including via our Website.

We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you.

We process most of your information on the grounds of our legitimate interests (i.e. processing that is necessary to continue our relationship with you and to provide you with services), fulfilment of our contract with you or to comply with a legal obligation.

If none of the grounds set out above apply, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

1.2 Who will receive your personal data?

We only transfer your personal data to the extent we need to. Recipients of your personal data include:

  • tutors and coaches;
  • awarding organisation;
  • regulatory organisations; and
  • your employer (if applicable).

1.3 How long will we keep your personal data?

We will retain your personal data for 3 years, unless you are an apprentice in which case we will retain your personal data for 6 years. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the relevant period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data.

  1. Employees

2.1 Why do we process your personal data

We process your personal data for HR, employment and administrative purposes. We need your personal data to make sure you have all you need to be able to work for us, to make sure you are safe and secure at work and to make sure you receive all the benefits to which you are entitled.

The Employment Rights Act 1996 requires us to obtain certain personal data from you, such as your name. Without it we may be unable to offer you employment. We may need other personal data from you to be able to enter into a contract with you and provide you with all the information you need. Again, if we do not receive that personal data from you, we may be unable to offer you employment or fulfil our obligations to you as your employer.

Although we may have previously processed some or all of your personal data on the grounds of consent (usually obtained within your employment contract), from the date of issue of this privacy policy we process most of your information on the grounds of our legitimate interests (i.e. our employment of you and fulfilling our obligations as your employer). We may also rely on the fact that we need to process your personal data to fulfil our contract with you or to comply with a legal obligation. If we process special categories of data about you we will usually do so on the basis that the processing is necessary as part of your employment with us.

If none of the grounds set out above applies, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

2.2 Who will receive your personal data?

We only transfer your personal data to the extent we need to as part of your employment with us. Recipients of your personal data include:

  • payroll providers;
  • insurers;
  • pension scheme providers;
  • banks;
  • HMRC;
  • healthcare providers;
  • the hosted data centre we use;
  • third parties that provide benefits and perks to you;
  • third parties holding events that you wish to attend; and
  • our customers, clients and supplier.

2.3 How long will we keep your personal data?

We will retain your personal data for 3 years from the date your employment with us terminates, other than PAYE information which will be retained for 6 years from such date. We retain your information for this period in case any issues arise following the end of your employment, in case you have any queries about the period in which you were employed by us and in respect of PAYE information, for regulatory purposes. Your information will be kept securely at all times. Following the end of the relevant period, your files and personal data we hold about you will be permanently deleted or destroyed.

  1. Consultants, Tutors and Coaches

3.1 Why do we process your personal data?

We process your personal data to receive services from you. We may also process your personal data to respond to any queries or comments you submit to us, including via our Website.

We process most of your information on the grounds of our legitimate interests (i.e. processing that is necessary to continue our relationship with you and to receive services from you), fulfilment of our contract with you or to comply with a legal obligation.

If none of the grounds set out above applies, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

3.2 Who will receive your personal data?

We only transfer your personal data to the extent we need to. We need to share your bank details with our bank to make payment to you for the services you are providing to us.

3.3 How long will we keep your personal data?

We will retain your personal data for period for which you continue to be a tutor, coach or consultant for us. Your information will be kept securely at all times. Following the end of your work with us, the personal data we hold about you will be permanently deleted or destroyed.

  1. Website Visitors

4.1 Why do we process your personal data?

We may collect and process the following data about you:

Information you give us: You may give us information about you by completing enquiry forms on the Website or by corresponding with us by phone, email or otherwise. The information you give us may include your name, email address, address / location and phone number. We will retain this information while we are corresponding with you or fulfilling an order you have placed with us. We will retain this information for 3 years from fulfilling your order or our last date of correspondence whichever is later.

Information we collect about you: We may collect the following information from you when you visit our Website:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), courses you viewed or searched for, page response times, Website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our customer services number.

Please see our cookie policy which sets out details of the purposes for which we retain this information.

Use made of the information: We may use the information we receive and/or collect about you to:

  • fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested;
  • send you newsletters and marketing information if you have consented to us doing so;
  • notify you of products and services we offer that are similar to those you have purchased or enquired about;
  • notify you of other products and services we feel may interest you, or permit third parties to do so if you have consented to us doing so;
  • notify you of changes to our services and products; and
  • monitor Website usage and provide statistics to third parties for the purposes of improving and developing the Website and the services we provide via the Website.

We process personal information for certain legitimate business purposes, which include some or all of the following:

  • where the processing enables us to enhance, modify, personalise or otherwise improve the Website, our services and communications for the benefit of our customers;
  • to identify and prevent fraud;
  • to enhance the security of our network and information systems;
  • to better understand how people interact with the Website;
  • administer the Website and carry out data analysis, troubleshooting and testing; and
  • to determine the effectiveness of promotional campaigns and advertising.

4.2 If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services and/or products in which you may be interested.

4.3 You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent, or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information) from us please let us know by contacting us via email at info@train2train.org. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

4.4 If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you and providing the details requested and we will take steps to ensure that this information is deleted as soon as reasonably practicable. 

4.5 We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.

  1. Third Party Sites

5.1 The Website may contain links to third party websites, including websites via which you are able to purchase products and services. They are provided for your convenience only and we do not check, endorse, approve or agree with such third party websites nor the products and/or services offered and sold on them. We have no responsibility for the content, product and/or services of the linked websites. Please ensure you review all terms and conditions of website use and privacy policy of any such third party websites before use and before you submit any personal data to such websites.

  1. How safe is your information?

6.1 Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The Website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.

6.2 We don’t transfer your personal data outside of the EEA.

  1. Your rights in respect of your data

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.

Access to your data

You have the right to ask us to confirm that we process your personal data, as well as access to / copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this privacy policy.

We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.

Rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.

Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

  • where we no longer need your personal data for the purpose for which we collected it;
  • where we have collected your personal data on the grounds of consent and you withdraw that consent;
  • where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
  • where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
  • where the personal data has to be deleted to comply with a legal obligation.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.

Right to restrict processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

  • if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
  • if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
  • if the processing is unlawful; or
  • if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

Data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:

  • where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
  • where we carry out the processing by automated means.

We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.

Right to object

You are entitled to object to us processing your personal data:

  • if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
  • for direct marketing purposes (including profiling); and/or
  • for the purposes of scientific or historical research and statistics.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

Your right to complain about our processing

If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.

  1. Any questions?

If you have any further queries or comments on our privacy policy, please use our contact us page or you can contact us by emailing info@train2train.org. We always welcome your views about our Website and our privacy policy.