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Privacy Policy Overview

UKMC (UK Management College) is committed to protecting your personal data. This policy explains how and why we use your personal data to make sure you remain informed and in control of your information.

UKMC will ask its learners or potential learners to “opt-in” to receive information about our products and courses. This means you’ll have the choice as to whether you want to receive these messages.

You can choose not to receive information or change how we contact you at any time. If you would like to, please let us know by:

Emailing: info@ukmcglobal.com

In writing to: UKMC, City View House, 5 Union Street, Manchester, M12 4JD, United Kingdom.

Telephone:+44 (0) 161 4780015, +44 (0) 7940524435

Office opening times are Monday to Friday 9.30am – 5.30pm (Excluding Public Holidays)

We will never sell your personal data. We may share personal data with other organisations who we work with to provide the service to you. However, these activities will be carried out under contracts which have strict requirements to keep your information confidential and secure.

About Us

Your personal data (i.e. any information which identifies you, or which can be identified as relating to you) will be collected and used by UKMC which is a limited company with Company No: 10159748

For the purposes of data protection law, UKMC will be the Data Controller.

What information do we collect?

Personal data you give to us

We collect data you give to us. For example:

Personal details (name, date of birth, email, address, telephone, education details etc.) when you sign up to an apprenticeship agreement

Data known as sensitive personal data (ethnicity, additional learning needs)

Financial information (payment information such as credit/debit card or direct debit details.

Information created by your involvement with UKMC

Your activities and involvement with UKMC create additional personal data, for example, information about your education progress and qualifications.

We may analyse your personal data to build a profile which helps us decide which of our communications you might be interested in.

Information from other organisations

We sometimes receive personal data from other organisations, for example, where they have passed us information about people who are interested in our apprenticeships and training courses.

We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.

We may also use other organisations to help us conduct research and analysis on personal data (and this can result in new personal data being created).

Sensitive personal data

We may collect or store data known as sensitive personal data (such as information relating to additional learning needs or ethnicity). We will do this where we have been asked to do so by official Government agencies or where the information is needed for the assessment of additional educational support needs.

If we do this, we’ll take extra care to ensure your personal data is protected.

Accidents or incidents

If an accident or incident occurs in one of our training centres or involving one of our employees then we’ll keep a record of this (which may include personal data and sensitive personal data).

How do we use personal information?

We only ever use your personal data with your consent, or where it is necessary:

To enter into, or perform, a contract with you

To comply with a legal duty

To protect your vital interests; this means, for example, keeping you safe from harm

For our own (or a third party’s) lawful interests, provided your rights are not affected

We will only use your information for the purpose or purposes it was collected for.

Administration

We use personal data for administrative purposes. This includes:

Receiving payment (e.g. direct debits or payment card details) 

Maintaining databases of our learners and their educational progress

Performing our obligations under apprenticeship or training contracts

Helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this).

Marketing

We use personal data to communicate with people and to promote UKMC. This includes keeping you up to date with our news and offerings. 

Research and Analysis

We may carry out research and analysis on the data we hold to understand behaviour and responses and identify patterns and trends.

We evaluate, categorise and profile personal data to tailor services and communications we send out (including targeted advertising) and to prevent unwanted material from being sent to you. 

Anonymised data

We may combine sets of personal data and change the personal data so that it can no longer be linked to any particular person. This information may then be used to monitor UKMC’s business performance or to identify trends or patterns within our existing learner database.

Disclosing and sharing data

We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about further opportunities in education.

We may share personal data with other organisations who provide us with services. For example, we may use an IT supplier to process personal data. However, these activities will be carried out under contracts which have strict requirements to keep your information confidential and secure.

Marketing

UKMC will ask its learners and contacts to “opt-in” for marketing communications. This means you’ll have the choice as to whether you want to receive these messages.

Young people

As an education provider, we regularly process the personal data relating to young people who enquire about courses and training opportunities.

How do we protect personal data?

We use a variety of physical and technical methods to keep your data safe and to prevent unauthorised access or sharing of your personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information using both physical and electronic means.

Our employees receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

Payment security

All electronic forms that request financial data will use secure web technology to encrypt the data between your web browsers and our computers.

If you use a credit card, we will pass your credit card details securely to our payment provider. UKMC complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details.

CCTV

Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and UKMC. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review CCTV will be recorded over.

UKMC complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is in use.

Storage of personal data

Where UKMC information is stored

UKMC’s operations are based in the UK and we store our data within the European Economic Area (EEA).

We will never process or store personal information outside of the EEA.

How long does UKMC Keep information for?

We will only use and store information for as long as it is needed for the purposes it was collected for. How long we keep information depends on the information and what it’s

used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).

We continually review what information we hold and delete what is no longer required. We never store payment card information.

How do we ensure that you remain in control of your data?

We want to ensure you remain in control of your personal data and that you understand your legal rights which include:

The right to ask and be told whether or not we have your personal data and, if we do to obtain a copy of the personal data we hold (this is known as a subject access request)

The right to have your data deleted (though this will not apply where it is necessary for us to continue to use the data to administer your training course or apprenticeship.

The right to have incorrect data amended

The right to object to your data being used for marketing purposes or profiling

Please note that there are some exceptions to the rights above and, although we will always try to respond to your satisfaction, there may be situations where we are unable to do so. For further information about your rights, please email info@ukmcglobal.com

Complaints

You can complain to UKMC directly by contacting our Quality Manager Adele Higgins, using the contact details set out above. If you would like to make a complaint which does not directly relate to your data protection and privacy rights please see UKMC’s complaints policy which is available on the website, or request via email to info@ukmcglobal.com

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk

Cookies and links to other sites

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as

an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites 

Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the ‘Contact us’ link at the top of the web page).

If an external website requests personal information from you, the information you provide will not be covered by the UKMC’s privacy policy. We suggest you read the privacy policy of any website before providing any personal information.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with UKMC.

Changes to this privacy policy

We’ll amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.

This Privacy Policy was last updated on 03/04//2021

Due for review: March 2022

Issued: December 2019 Version: 1.1

Reviewed: 04/03/2021 Next review: March 2022

UKMC, City View House, 5 Union Road, Manchester, M12 4JD, United Kingdom.


Data Protection Policy – GDPR

Policy Name: Data Protection Policy – GDPR

Policy Version: V2

Effective Date: 14/05/2018

Review Date: 04/03/2021

Next review: March 2022

Policy Responsibility: Management

For Action By: All Staff

 

Rationale

UKMC is committed to a policy of protecting the rights and privacy of individuals, including learners, staff and others, in accordance with the General Data Protection Regulation (GDPR) May 2018.

 

The new regulatory environment demands higher transparency and accountability in how centre’s manage and use personal data. It also accords new and stronger rights for individuals to understand and control that use.

 

The GDPR contains provisions that the centre will need to be aware of as data controllers, including provisions intended to enhance the protection of student’s personal data. For example, the GDPR requires that:

 

We must ensure that our centre privacy notices are written in a clear, plain way that staff and students will understand.

 

UKMC needs to process certain information about its staff, students and other individuals with whom it has a relationship for various purposes such as, but not limited to:

 

  1. The recruitment and payment of staff
  2. The administration of programs of study and courses
  3. Student enrolment
  4. Examinations and external accreditation
  5. Recording student progress, attendance and conduct
  6. Collecting fees
  7. Complying  with  legal  obligations  to funding bodies and government including local government.

 

To comply with various legal obligations, including the obligations imposed on it by the General Data Protection Regulation (GDPR) UKMC must ensure that all this information about individuals is collected and used fairly, stored safely and securely and not disclosed to any third party unlawfully.

 

 

Compliance

This policy applies to all staff and students of UKMC. Any breach of this policy or of the Regulation itself will be considered an offence and the centre’s disciplinary procedures will be invoked.

 

As a matter of best practice, other agencies and individuals working with UKMC and who have access to personal information, will be expected to read and comply with this policy. It is expected that departments who are responsible for dealing with external bodies will take the responsibility for ensuring that such bodies sign a contract which among other things will include an agreement to abide by this policy.

 

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments to the GDPR and other relevant legislation.

 

 
The Code of Practice on GDPR for UKMC gives further detailed guidance and UKMC undertakes to adopt and comply with this Code of Practice.

 

 

 

General Data Protection Regulation (GDPR)

This piece of legislation came in to force on the 25th May 2018. The GDPR regulates the processing of personal data, and protects the rights and privacy of all living individuals (including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them. Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images), and may include facts or opinions about a person.

 

The GDPR also sets out specific rights for centre students in relation to educational records held within.

 

 

 

Responsibilities under the GDPR

 

UKMC will be the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for controlling the use and processing of the personal data. The Principal who is available to address any concerns regarding the data held by centre and how it is processed, held and used.

 

The Senior Management is ultimately responsible for all day-to-day data protection matters, and will be responsible for ensuring that all members of staff and relevant individuals abide by this policy, and for developing and encouraging good information handling within the centre. Although all staff handling information have a responsibility to understand and follow DPA.

 

The Senior Management is also responsible for ensuring that the centre’s notification is kept accurate. Compliance with the legislation is the personal responsibility of all members of the centre who process personal information.

 

Individuals who provide personal data to the centre are responsible for ensuring that the information is accurate and up-to-date.

 

 

 

Data Protection Principles

 

The legislation places a responsibility on every data controller to process any personal data in accordance with the eight principles. More detailed guidance on how to comply with these principles can be found in the DPCoP. Please follow this link to the ICO’s website (www.ico.gov.uk)

 

In order to comply with its obligations, undertaken to adhere to the eight principles:
 

 

 

  1. Process personal data fairly and lawfully.

 

UKMC will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant. For example,

 

  1. Process the data for the specific and lawful purpose for which it collected that data and not further process the data in a manner incompatible with this purpose.

 

UKMC will ensure that the reason for which it collected the data originally is the only reason for which it processes those data, unless the individual is informed of any additional processing before it takes place.

 

  1. Ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed.

 

UKMC will not seek to collect any personal data which is not strictly necessary for the purpose for which it was obtained. Forms for collecting data will always be drafted with this mind. If any irrelevant data are given by individuals, they will be destroyed immediately.

 

  1. Keep personal data accurate and, where necessary, up to date.

 

UKMC will review and update all data on a regular basis. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the centre if, for example, a change in circumstances mean that the data needs to be updated. It is the responsibility of the centre to ensure that any notification regarding the change is noted and acted on.
 
  1. Only keep personal data for as long as is necessary.

 

UKMC undertakes not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. This means UKMC will undertake a regular review of the information held and implement a weeding process.

 

UKMC will dispose of any personal data in a way that protects the rights and privacy of the individual concerned (e.g. secure electronic deletion, shredding and disposal of hard copy files as confidential waste). A log will be kept of the records destroyed.

 

  1. Process personal data in accordance with the rights of the data subject under the legislation.

 

Individuals have various rights under the legislation including a right to:
 
  • be told the nature of the information the centre holds and any parties to whom this may be disclosed
  • prevent processing data likely to cause damage or distress
  • prevent processing data for purposes of direct marketing
  • be informed about the mechanics of any automated decision taking process that will significantly affect them
  • not have significant decisions that will affect them taken solely by automated process
  • sue for compensation if they suffer damage by any contravention of the legislation
  • take action to rectify, block, erase or destroy inaccurate data
  • request that the Office of the Information Commissioner assess whether any provision of the Act has been contravened.

 

UKMC will only process personal data in accordance with individuals’ rights.

 

  1. Put appropriate technical and organisational measures in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data.

 

All members of staff are responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties.

 

UKMC will ensure that all personal data is accessible only to those who have a valid reason for using it.

 

UKMC will have in place appropriate security measures e.g. ensuring that hard copy personal data is kept in lockable filing cabinets/cupboards with controlled access (with the keys then held securely in a key cabinet with controlled access):

 

  • keeping all personal data in a lockable cabinet with key-controlled access
  • password protecting personal data held electronically
  • archiving personal data which are then kept securely (lockable cabinet)
  • placing any PCs or terminals, CCTV camera screens etc. that show personal data so that they are not visible except to authorised staff
  • ensuring that PC screens are not left unattended without a password protected screen-saver being used.

 

In addition, UKMC will put in place appropriate measures for the deletion of personal data – manual records will be shredded or disposed of as ‘confidential waste’ and appropriate contract terms will be put in place with any third parties undertaking this work. Hard drives of redundant PCs will be wiped clean before disposal or if that is not possible, destroyed physically. A log will be kept of the records destroyed.

 

This policy also applies to staff and students who process personal data ‘off-site’, e.g. when working at home, and in circumstances additional care must be taken regarding the security of the data.

 

  1. Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

 

UKMC will not transfer data to such territories without the explicit consent of the individual.

 

This also applies to publishing information on the Internet – because transfer of data can include placing data on a website that can be accessed from outside the EEA – so UKMC will always seek the consent of individuals before placing any personal data (including photographs) on its website.

 

 
 
If the centre collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.

 

 

Consent as a basis for processing

 

Although it is not always necessary to gain consent from individuals before processing their data, it is often the best way to ensure that data is collected and processed in an open and transparent manner.

 

Consent is especially important when UKMC is processing any sensitive data, as defined by the legislation.

 

UKMC understands consent to mean that the individual has been fully informed of the intended processing and has signified their agreement (e.g. via the enrolment form) whilst being of a sound mind and without having any undue influence exerted upon them. Consent obtained on the basis of misleading information will not be a valid basis for processing. Consent cannot be inferred from the non-response to a communication.

 

“Personal Details

  • For the purposes of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679 you consent to the centre holding and processing personal data including sensitive personal data of which you are the subject, details of which are specified in the centre’s data protection policy.
  • This will include marketing images and the centre CCTV.”

 

UKMC will ensure that any forms used to gather data on an individual will contain a statement (fair collection statement) explaining the use of that data, how the data may be disclosed and also indicate whether or not the individual needs to consent to the processing.

 

UKMC will include the specified statement from the DfE on the student enrolment form and update when required following the SFA’s technical guidance:

 

How We Use Your Personal Information

This privacy notice is issued by the Education and Skills Funding Agency (ESFA), on behalf of the Secretary of State for the Department of Education (DfE). It is to inform learners how their personal information will be used by the DfE, the ESFA (an executive agency of the DfE) and any successor bodies to these organisations. For the purposes of the Data Protection Act 1998, the DfE is the data controller for personal data processed by the ESFA. Your personal information is used by the DfE to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique learner number (ULN) and a personal learning record (PLR).

 

Your information may be shared with third parties for education, training, employment and well-being related purposes, including for research. This will only take place where the law allows it and the sharing is in compliance with the Data Protection Act 1998.

 

The English European Social Fund (ESF) Managing Authority (or agents acting on its behalf) may contact you in order for them to carry out research and evaluation to inform the

 

 

effectiveness of training.

 

You can opt out of contact for other purposes by ticking any of the following boxes if you do not wish to be contacted:

About courses or learning opportunities. For surveys and research.

By post.

By phone. By email.

Further information about use of and access to your personal data, and details of organisations with whom we regularly share data are available at: https://www.gov.uk/government/publications/esfa-privacy-notice

 

UKMC will ensure that if the individual does not give his/her consent for the processing, and there is no other lawful basis on which to process the data, then steps will be taken to ensure that processing of that data does not take place.

 

 

Subject Access Rights (SARs)

Individuals have a right to access any personal data relating to them which are held by the centre. Any individual wishing to exercise this right should apply in writing to the Principal. Any member of staff receiving a SAR should forward this to the Principal.

 

The centre reserves the right to charge a fee for data subject access requests (currently £20).

 

Under the terms of the legislation, any such requests must be complied with within 40 days.

 

For detailed guidance on responding to SARs, see the CoP.

 

 

 

Disclosure of Data

Only disclosures which have been notified under the centre’s DP notification must be made and therefore staff and students should exercise caution when asked to disclose personal data held on another individual or third party.

 

UKMC undertakes not to disclose personal data to unauthorised third parties, including family members, friends, government bodies and in some circumstances, the police.

 

Legitimate disclosures may occur in the following instances:

 

  • the individual has given their consent to the disclosure.
  • the disclosure has been notified to the OIC and is in the legitimate interests of the centre.
  • the disclosure is required for the performance of a contract.

 

There are other instances when the legislation permits disclosure without the consent of the individual.
For detailed guidance on disclosures see the Code of Practice (CoP).

 

In no circumstances will UKMC sell any of its databases to a third party.

 

 

 

Publication of centre Information

 

UKMC publishes various items which will include some personal data, e.g.

 

  • internal telephone directory
  • event information
  • photos and information in marketing materials
 
It may be that in some circumstances an individual wishes their data processed for such reasons to be kept confidential, or restricted centre access only. Therefore it is UKMC policy to offer an opportunity to opt-out of the publication of such when collecting the information.

 

 

Email

It is the policy of UKMC to ensure that senders and recipients of email are made aware that under the DPA, and Freedom of Information Legislation, the contents of email may have to be disclosed in response to a request for information. One means by which this will be communicated will be by a disclaimer on the centre’s email.

 

Under the Regulation of Investigatory Powers Act 2000, Lawful Business Practice Regulations, any email sent to or from the centre may be accessed by someone other than the recipient for system management and security purposes.

 

CCTV

There are some CCTV systems operating within UKMC for the purpose of protecting centre members and property. UKMC will only process personal data obtained by the CCTV system in a manner which ensures compliance with the legislation.
 

 

Procedure for review

This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.

 

Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection which is available from the website.

 

For help or advice on any data protection or freedom of information issues, please do not hesitate to contact:
 
UKMC English Academy Privacy Policy

Privacy Policy Overview

UKMC (UK Management College) is committed to protecting your personal data. This policy explains how and why we use your personal data to make sure you remain informed and in control of your information.

UKMC will ask its learners or potential learners to “opt-in” to receive information about our products and courses. This means you’ll have the choice as to whether you want to receive these messages.

You can choose not to receive information or change how we contact you at any time. If you would like to, please let us know by:

Emailing: info@ukmcglobal.com

In writing to: UKMC, City View House, 5 Union Street, Manchester, M12 4JD, United Kingdom.

Telephone:+44 (0) 161 4780015, +44 (0) 7940524435

Office opening times are Monday to Friday 9.30am – 5.30pm (Excluding Public Holidays)

We will never sell your personal data. We may share personal data with other organisations who we work with to provide the service to you. However, these activities will be carried out under contracts which have strict requirements to keep your information confidential and secure.

About Us

Your personal data (i.e. any information which identifies you, or which can be identified as relating to you) will be collected and used by UKMC which is a limited company with Company No: 10159748

For the purposes of data protection law, UKMC will be the Data Controller.

What information do we collect?

Personal data you give to us

We collect data you give to us. For example:

Personal details (name, date of birth, email, address, telephone, education details etc.) when you sign up to an apprenticeship agreement

Data known as sensitive personal data (ethnicity, additional learning needs)

Financial information (payment information such as credit/debit card or direct debit details.

Information created by your involvement with UKMC

Your activities and involvement with UKMC create additional personal data, for example, information about your education progress and qualifications.

We may analyse your personal data to build a profile which helps us decide which of our communications you might be interested in.

Information from other organisations

We sometimes receive personal data from other organisations, for example, where they have passed us information about people who are interested in our apprenticeships and training courses.

We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.

We may also use other organisations to help us conduct research and analysis on personal data (and this can result in new personal data being created).

Sensitive personal data

We may collect or store data known as sensitive personal data (such as information relating to additional learning needs or ethnicity). We will do this where we have been asked to do so by official Government agencies or where the information is needed for the assessment of additional educational support needs.

If we do this, we’ll take extra care to ensure your personal data is protected.

Accidents or incidents

If an accident or incident occurs in one of our training centres or involving one of our employees then we’ll keep a record of this (which may include personal data and sensitive personal data).

How do we use personal information?

We only ever use your personal data with your consent, or where it is necessary:

To enter into, or perform, a contract with you

To comply with a legal duty

To protect your vital interests; this means, for example, keeping you safe from harm

For our own (or a third party’s) lawful interests, provided your rights are not affected

We will only use your information for the purpose or purposes it was collected for.

Administration

We use personal data for administrative purposes. This includes:

Receiving payment (e.g. direct debits or payment card details) 

Maintaining databases of our learners and their educational progress

Performing our obligations under apprenticeship or training contracts

Helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this).

Marketing

We use personal data to communicate with people and to promote UKMC. This includes keeping you up to date with our news and offerings. 

Research and Analysis

We may carry out research and analysis on the data we hold to understand behaviour and responses and identify patterns and trends.

We evaluate, categorise and profile personal data to tailor services and communications we send out (including targeted advertising) and to prevent unwanted material from being sent to you. 

Anonymised data

We may combine sets of personal data and change the personal data so that it can no longer be linked to any particular person. This information may then be used to monitor UKMC’s business performance or to identify trends or patterns within our existing learner database.

Disclosing and sharing data

We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about further opportunities in education.

We may share personal data with other organisations who provide us with services. For example, we may use an IT supplier to process personal data. However, these activities will be carried out under contracts which have strict requirements to keep your information confidential and secure.

Marketing

UKMC will ask its learners and contacts to “opt-in” for marketing communications. This means you’ll have the choice as to whether you want to receive these messages.

Young people

As an education provider, we regularly process the personal data relating to young people who enquire about courses and training opportunities.

How do we protect personal data?

We use a variety of physical and technical methods to keep your data safe and to prevent unauthorised access or sharing of your personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information using both physical and electronic means.

Our employees receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

Payment security

All electronic forms that request financial data will use secure web technology to encrypt the data between your web browsers and our computers.

If you use a credit card, we will pass your credit card details securely to our payment provider. UKMC complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details.

CCTV

Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and UKMC. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review CCTV will be recorded over.

UKMC complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is in use.

Storage of personal data

Where UKMC information is stored

UKMC’s operations are based in the UK and we store our data within the European Economic Area (EEA).

We will never process or store personal information outside of the EEA.

How long does UKMC Keep information for?

We will only use and store information for as long as it is needed for the purposes it was collected for. How long we keep information depends on the information and what it’s

used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).

We continually review what information we hold and delete what is no longer required. We never store payment card information.

How do we ensure that you remain in control of your data?

We want to ensure you remain in control of your personal data and that you understand your legal rights which include:

The right to ask and be told whether or not we have your personal data and, if we do to obtain a copy of the personal data we hold (this is known as a subject access request)

The right to have your data deleted (though this will not apply where it is necessary for us to continue to use the data to administer your training course or apprenticeship.

The right to have incorrect data amended

The right to object to your data being used for marketing purposes or profiling

Please note that there are some exceptions to the rights above and, although we will always try to respond to your satisfaction, there may be situations where we are unable to do so. For further information about your rights, please email info@ukmcglobal.com

Complaints

You can complain to UKMC directly by contacting our Quality Manager Adele Higgins, using the contact details set out above. If you would like to make a complaint which does not directly relate to your data protection and privacy rights please see UKMC’s complaints policy which is available on the website, or request via email to info@ukmcglobal.com

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk

Cookies and links to other sites

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as

an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites 

Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the ‘Contact us’ link at the top of the web page).

If an external website requests personal information from you, the information you provide will not be covered by the UKMC’s privacy policy. We suggest you read the privacy policy of any website before providing any personal information.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with UKMC.

Changes to this privacy policy

We’ll amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.

This Privacy Policy was last updated on 03/04//2021

Due for review: March 2022

Issued: December 2019 Version: 1.1

Reviewed: 04/03/2021 Next review: March 2022

UKMC, City View House, 5 Union Road, Manchester, M12 4JD, United Kingdom.

UKMC English Academy Data Protection Policy


Data Protection Policy – GDPR

Policy Name: Data Protection Policy – GDPR

Policy Version: V2

Effective Date: 14/05/2018

Review Date: 04/03/2021

Next review: March 2022

Policy Responsibility: Management

For Action By: All Staff

 

Rationale

UKMC is committed to a policy of protecting the rights and privacy of individuals, including learners, staff and others, in accordance with the General Data Protection Regulation (GDPR) May 2018.

 

The new regulatory environment demands higher transparency and accountability in how centre’s manage and use personal data. It also accords new and stronger rights for individuals to understand and control that use.

 

The GDPR contains provisions that the centre will need to be aware of as data controllers, including provisions intended to enhance the protection of student’s personal data. For example, the GDPR requires that:

 

We must ensure that our centre privacy notices are written in a clear, plain way that staff and students will understand.

 

UKMC needs to process certain information about its staff, students and other individuals with whom it has a relationship for various purposes such as, but not limited to:

 

  1. The recruitment and payment of staff
  2. The administration of programs of study and courses
  3. Student enrolment
  4. Examinations and external accreditation
  5. Recording student progress, attendance and conduct
  6. Collecting fees
  7. Complying  with  legal  obligations  to funding bodies and government including local government.

 

To comply with various legal obligations, including the obligations imposed on it by the General Data Protection Regulation (GDPR) UKMC must ensure that all this information about individuals is collected and used fairly, stored safely and securely and not disclosed to any third party unlawfully.

 

 

Compliance

This policy applies to all staff and students of UKMC. Any breach of this policy or of the Regulation itself will be considered an offence and the centre’s disciplinary procedures will be invoked.

 

As a matter of best practice, other agencies and individuals working with UKMC and who have access to personal information, will be expected to read and comply with this policy. It is expected that departments who are responsible for dealing with external bodies will take the responsibility for ensuring that such bodies sign a contract which among other things will include an agreement to abide by this policy.

 

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments to the GDPR and other relevant legislation.

 

 
The Code of Practice on GDPR for UKMC gives further detailed guidance and UKMC undertakes to adopt and comply with this Code of Practice.

 

 

 

General Data Protection Regulation (GDPR)

This piece of legislation came in to force on the 25th May 2018. The GDPR regulates the processing of personal data, and protects the rights and privacy of all living individuals (including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them. Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images), and may include facts or opinions about a person.

 

The GDPR also sets out specific rights for centre students in relation to educational records held within.

 

 

 

Responsibilities under the GDPR

 

UKMC will be the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for controlling the use and processing of the personal data. The Principal who is available to address any concerns regarding the data held by centre and how it is processed, held and used.

 

The Senior Management is ultimately responsible for all day-to-day data protection matters, and will be responsible for ensuring that all members of staff and relevant individuals abide by this policy, and for developing and encouraging good information handling within the centre. Although all staff handling information have a responsibility to understand and follow DPA.

 

The Senior Management is also responsible for ensuring that the centre’s notification is kept accurate. Compliance with the legislation is the personal responsibility of all members of the centre who process personal information.

 

Individuals who provide personal data to the centre are responsible for ensuring that the information is accurate and up-to-date.

 

 

 

Data Protection Principles

 

The legislation places a responsibility on every data controller to process any personal data in accordance with the eight principles. More detailed guidance on how to comply with these principles can be found in the DPCoP. Please follow this link to the ICO’s website (www.ico.gov.uk)

 

In order to comply with its obligations, undertaken to adhere to the eight principles:
 

 

 

  1. Process personal data fairly and lawfully.

 

UKMC will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant. For example,

 

  1. Process the data for the specific and lawful purpose for which it collected that data and not further process the data in a manner incompatible with this purpose.

 

UKMC will ensure that the reason for which it collected the data originally is the only reason for which it processes those data, unless the individual is informed of any additional processing before it takes place.

 

  1. Ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed.

 

UKMC will not seek to collect any personal data which is not strictly necessary for the purpose for which it was obtained. Forms for collecting data will always be drafted with this mind. If any irrelevant data are given by individuals, they will be destroyed immediately.

 

  1. Keep personal data accurate and, where necessary, up to date.

 

UKMC will review and update all data on a regular basis. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the centre if, for example, a change in circumstances mean that the data needs to be updated. It is the responsibility of the centre to ensure that any notification regarding the change is noted and acted on.
 
  1. Only keep personal data for as long as is necessary.

 

UKMC undertakes not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. This means UKMC will undertake a regular review of the information held and implement a weeding process.

 

UKMC will dispose of any personal data in a way that protects the rights and privacy of the individual concerned (e.g. secure electronic deletion, shredding and disposal of hard copy files as confidential waste). A log will be kept of the records destroyed.

 

  1. Process personal data in accordance with the rights of the data subject under the legislation.

 

Individuals have various rights under the legislation including a right to:
 
  • be told the nature of the information the centre holds and any parties to whom this may be disclosed
  • prevent processing data likely to cause damage or distress
  • prevent processing data for purposes of direct marketing
  • be informed about the mechanics of any automated decision taking process that will significantly affect them
  • not have significant decisions that will affect them taken solely by automated process
  • sue for compensation if they suffer damage by any contravention of the legislation
  • take action to rectify, block, erase or destroy inaccurate data
  • request that the Office of the Information Commissioner assess whether any provision of the Act has been contravened.

 

UKMC will only process personal data in accordance with individuals’ rights.

 

  1. Put appropriate technical and organisational measures in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data.

 

All members of staff are responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties.

 

UKMC will ensure that all personal data is accessible only to those who have a valid reason for using it.

 

UKMC will have in place appropriate security measures e.g. ensuring that hard copy personal data is kept in lockable filing cabinets/cupboards with controlled access (with the keys then held securely in a key cabinet with controlled access):

 

  • keeping all personal data in a lockable cabinet with key-controlled access
  • password protecting personal data held electronically
  • archiving personal data which are then kept securely (lockable cabinet)
  • placing any PCs or terminals, CCTV camera screens etc. that show personal data so that they are not visible except to authorised staff
  • ensuring that PC screens are not left unattended without a password protected screen-saver being used.

 

In addition, UKMC will put in place appropriate measures for the deletion of personal data – manual records will be shredded or disposed of as ‘confidential waste’ and appropriate contract terms will be put in place with any third parties undertaking this work. Hard drives of redundant PCs will be wiped clean before disposal or if that is not possible, destroyed physically. A log will be kept of the records destroyed.

 

This policy also applies to staff and students who process personal data ‘off-site’, e.g. when working at home, and in circumstances additional care must be taken regarding the security of the data.

 

  1. Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

 

UKMC will not transfer data to such territories without the explicit consent of the individual.

 

This also applies to publishing information on the Internet – because transfer of data can include placing data on a website that can be accessed from outside the EEA – so UKMC will always seek the consent of individuals before placing any personal data (including photographs) on its website.

 

 
 
If the centre collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.

 

 

Consent as a basis for processing

 

Although it is not always necessary to gain consent from individuals before processing their data, it is often the best way to ensure that data is collected and processed in an open and transparent manner.

 

Consent is especially important when UKMC is processing any sensitive data, as defined by the legislation.

 

UKMC understands consent to mean that the individual has been fully informed of the intended processing and has signified their agreement (e.g. via the enrolment form) whilst being of a sound mind and without having any undue influence exerted upon them. Consent obtained on the basis of misleading information will not be a valid basis for processing. Consent cannot be inferred from the non-response to a communication.

 

“Personal Details

  • For the purposes of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679 you consent to the centre holding and processing personal data including sensitive personal data of which you are the subject, details of which are specified in the centre’s data protection policy.
  • This will include marketing images and the centre CCTV.”

 

UKMC will ensure that any forms used to gather data on an individual will contain a statement (fair collection statement) explaining the use of that data, how the data may be disclosed and also indicate whether or not the individual needs to consent to the processing.

 

UKMC will include the specified statement from the DfE on the student enrolment form and update when required following the SFA’s technical guidance:

 

How We Use Your Personal Information

This privacy notice is issued by the Education and Skills Funding Agency (ESFA), on behalf of the Secretary of State for the Department of Education (DfE). It is to inform learners how their personal information will be used by the DfE, the ESFA (an executive agency of the DfE) and any successor bodies to these organisations. For the purposes of the Data Protection Act 1998, the DfE is the data controller for personal data processed by the ESFA. Your personal information is used by the DfE to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique learner number (ULN) and a personal learning record (PLR).

 

Your information may be shared with third parties for education, training, employment and well-being related purposes, including for research. This will only take place where the law allows it and the sharing is in compliance with the Data Protection Act 1998.

 

The English European Social Fund (ESF) Managing Authority (or agents acting on its behalf) may contact you in order for them to carry out research and evaluation to inform the

 

 

effectiveness of training.

 

You can opt out of contact for other purposes by ticking any of the following boxes if you do not wish to be contacted:

About courses or learning opportunities. For surveys and research.

By post.

By phone. By email.

Further information about use of and access to your personal data, and details of organisations with whom we regularly share data are available at: https://www.gov.uk/government/publications/esfa-privacy-notice

 

UKMC will ensure that if the individual does not give his/her consent for the processing, and there is no other lawful basis on which to process the data, then steps will be taken to ensure that processing of that data does not take place.

 

 

Subject Access Rights (SARs)

Individuals have a right to access any personal data relating to them which are held by the centre. Any individual wishing to exercise this right should apply in writing to the Principal. Any member of staff receiving a SAR should forward this to the Principal.

 

The centre reserves the right to charge a fee for data subject access requests (currently £20).

 

Under the terms of the legislation, any such requests must be complied with within 40 days.

 

For detailed guidance on responding to SARs, see the CoP.

 

 

 

Disclosure of Data

Only disclosures which have been notified under the centre’s DP notification must be made and therefore staff and students should exercise caution when asked to disclose personal data held on another individual or third party.

 

UKMC undertakes not to disclose personal data to unauthorised third parties, including family members, friends, government bodies and in some circumstances, the police.

 

Legitimate disclosures may occur in the following instances:

 

  • the individual has given their consent to the disclosure.
  • the disclosure has been notified to the OIC and is in the legitimate interests of the centre.
  • the disclosure is required for the performance of a contract.

 

There are other instances when the legislation permits disclosure without the consent of the individual.
For detailed guidance on disclosures see the Code of Practice (CoP).

 

In no circumstances will UKMC sell any of its databases to a third party.

 

 

 

Publication of centre Information

 

UKMC publishes various items which will include some personal data, e.g.

 

  • internal telephone directory
  • event information
  • photos and information in marketing materials
 
It may be that in some circumstances an individual wishes their data processed for such reasons to be kept confidential, or restricted centre access only. Therefore it is UKMC policy to offer an opportunity to opt-out of the publication of such when collecting the information.

 

 

Email

It is the policy of UKMC to ensure that senders and recipients of email are made aware that under the DPA, and Freedom of Information Legislation, the contents of email may have to be disclosed in response to a request for information. One means by which this will be communicated will be by a disclaimer on the centre’s email.

 

Under the Regulation of Investigatory Powers Act 2000, Lawful Business Practice Regulations, any email sent to or from the centre may be accessed by someone other than the recipient for system management and security purposes.

 

CCTV

There are some CCTV systems operating within UKMC for the purpose of protecting centre members and property. UKMC will only process personal data obtained by the CCTV system in a manner which ensures compliance with the legislation.
 

 

Procedure for review

This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998.

 

Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection which is available from the website.

 

For help or advice on any data protection or freedom of information issues, please do not hesitate to contact: