The Education and Training Foundation takes its duty to process your personal data seriously. This policy explains how we collect, manage, use and protect your personal data.
1.1 This policy references the Education and Training Foundation (ETF, we, us, our), a registered charity (registration no: 1153859) and company limited by guarantee (company registration number (England and Wales): 08540597). It also includes our subsidiary company, ETF Services Limited (company registration number (England and Wales): 9511877), and our professional membership organisation, the Society for Education and Training (SET).
1.2 ETF is the sector-owned, government-backed workforce development body for the further education and training sector. Our mission is to support the continuing transformation of our country’s technical and vocational education system by ensuring the sector has world-class teachers, trainers, assessors and leaders. This leads to ever-improving learner outcomes, a better skilled workforce and a stronger economy, country and society.
1.3 SET is the membership body dedicated to professionals working across further education, vocational teaching and training. It helps the careers of professionals working across the sector, inspiring them to be even better, and, connecting them with thousands of like-minded professionals and experts. It aims to raise the status of the profession, champion the quality of the sector’s professionals, and provide access to the best research and expert views there are.
1.4 This Privacy Policy (together with our Terms of Usage) sets out the basis on which we may process your personal data and information. ETF is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this Privacy Policy.
1.5 The ETF may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
1.6 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our sites, you are accepting and consenting to the practices described in this Privacy Policy.
2.1 We may process personal data that you provide to us directly (for example, through the websites that we operate, correspondence, phone, email, social media etc), via third parties who you have given permission to pass on your information, and from publicly available sources or otherwise.
2.2 These data may include information provided by you:
2.3 The information you give us may include your name, age (within a range), postcode, email address, phone number, gender, ethnicity, employer, affiliated organisations (for example, professional body), job details, related financial details (for example bank/account and debit/credit card details related to a specific financial transaction) and personal description. For some purposes, additional requirements may be needed, such as criminal convictions (e.g. should you apply for Qualified Teacher Learning & Skills status).
2.4 At the time of providing this personal information we will be clear for what purpose it is being collected, how you can subsequently ask for the data to be amended and how you can ask for it to be deleted.
2.5 We may also collect and process technical information about your computer, including (where available) your Internet Protocol address, login information, operating system and browser type and version, for system administration purposes and to report aggregate information to other organisations (including our funders). When reporting to other organisations, this is statistical data about the browsing actions and patterns of usage of our sites, and does not (of itself) identify any individual by name.
3.1 We have a number of legal reasons (or the ‘lawful basis’) that mean we can use (or ‘process’) your personal information, including consent, contractual, legitimate interest and public task (there are six in total). These are outlined in the following sections. Sometimes more than one lawful basis will apply when we process your personal data. You can find out more about this from the ICO here.
3.2 Legitimate interest: means we can process your personal information if: we have a genuine and legitimate reason; we are not harming any of your rights and interests; and you would not be surprised or likely to object to receiving the communication.
3.3 We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products, and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’. When processing your data in this way, we will also carefully consider and balance any potential impact on you and your rights.
3.4 Some typical examples of when we might use this approach are for preventing fraud, recording our reach and impact, direct marketing (including providing information regarding our products and services, where sought), maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns. See Annex 1 for further detail regarding these examples and your interests.
3.5 Consent: means we can process your personal information if consent can be freely given and you have real choice and control over how the we use your data. You must be able to give your consent through opting in and we must provide you with a clear explanation of why we want your data and what we’ll do with it. ETF seeks consent from individuals for example to receive our regular newsletter.
3.6 Contractual: means we can process your personal data to fulfil our current or planned contractual obligations with you. For example, we will process personal data as part of our tendering process with bidding and contracted organisations (our ‘delivery partners’). We will also process the personal data of our SET members using this basis.
3.7 Public task: means we can process your personal data where we have ‘official authority’ or are performing a task which is in the public interest (set out in law). As part of our Department for Education grant funding we are required to meet a number of KPIs, including evidencing the direct and indirect reach. We will store individuals’ names and e-mail addresses who have benefited from our grant funded support as evidence of our reach.
4.1 We require your personal data to understand your needs and provide you with a better service, and in particular for the following reasons:
4.2 The ETF will not sell or lease your personal information to third parties and we will only share your data with third parties when:
4.3 You can unsubscribe from marketing and communications from the ETF at any time by using unsubscribe link on any marketing or communications or by contacting us by email at: enquiries@etfoundation.co.uk.
4.4 We will stop processing your personal data if you tell us to. Please contact us at enquiries@etfoundation.co.uk.
4.5 We will delete your personal data if you tell us to. The law says we must not contact you again if you ask us not to. This means we might need to keep your contact details to make sure this happens.
4.6 We hold your information as long as necessary for each purpose we use it. For example, we will keep course evaluation data for up to seven years following the completion of the course.
5.1 All information you provide to us is stored on secure servers. We adopt appropriate technical and organisational measures to protect the security of all personal data held by the ETF, including sensitive personal data. Any payment transactions will be encrypted.
5.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5.3 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
6.1 The new data protection law (the General Data Protection Regulation, GDPR), from May 2018, gives everyone a number of rights. These are:
6.2 If you would like to know more about your rights under the data protection law see the Information Commissioner’s Office website.
6.3 You can change the way you hear from us or withdraw your permission for us to processing your personal data at any time by contacting enquiries@etfoundation.co.uk.
6.4 You have a right to access personal data being kept about you. Any person wishing to exercise this right should complete a Subject Access Request Form. The form and further information can be found on the ETF website.
6.5 You can complain to the UK regulator, the Information Commissioner’s Office, if you feel we are not acting fairly.
7.1 Our website may contain links to other websites. ETF does not have any control over the content or security of other websites and cannot be responsible for your privacy and protection if you choose to visit these websites.
8.1 It is important to the ETF that our websites are easy to use, accessible and reliable. Small files, called cookies, place small amounts of information on your computer or other device used to access the internet, such as a mobile phone.
8.2 Cookies may be used on this site to help personalise your visit, to improve how you use the site and to record your online activity. This information cannot be used to identify you personally. You can disable cookies by adjusting your browser settings, but some functions of the site may not work correctly.
8.3 Specifically, the ETF uses cookies to measure how people are using the website so that we can improve the capacity and overall user experience.
8.4 Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store and use this information. Google’s privacy policy is available here.
8.5 In addition to Google Analytics, we also may use a range of other cookies when relevant, these include: Facebook Advertising, DoubleClick, Lotame, AppNexus, EXelate, MediaMath, TradeDEsk, Semasio,Eyeota, Hotjae, Bombora and Mouseflow.
8.6 All modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’ menu of your browser. To understand these settings, the following links may be helpful, or you can use the ‘Help’ option in your browser for more details.
8.7 The BBC website provides a user friendly outline of cookies and how they work.
8.8 Please note the ETF is not responsible for the content on other websites.
9.1 If you’d like to talk through anything in this policy, find out more about your rights or obtain a copy of the information we hold about you, please contact us. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Lead who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office (ICO).
9.2 Our Data Protection Lead can be contacted by writing to: ETF, 157-197 Buckingham Palace Road, London SW1W 9SP; e-mailing enquiries@etfoundation.co.uk; or calling 020 7340 8280.
1. The following are some examples of ETF’s interests, outlining when and why we would use ‘legitimate interest’:
We’ll also hold information about you so that we can respect your preferences for being contacted by us.
2. When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Published: 24 May 2018