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 The 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. The ETF receives funding from the Department for Education, more information about our funding can be found here.
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 Data provided by yourself may include:
2.3 The information you give us may include, but is not limited to, your name, age, address, 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 or accessibility requirements for courses).
2.4 At the time of providing this personal information we will be clear of the purpose it is being collected, how you can subsequently ask for your 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. For more information on this please refer to our Cookie Policy below.
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), promoting resources or materials in areas you have expressed interest, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, gaining insights and understanding journeys related to usage of our services and sites, 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’ or suppliers). We will also process the personal data of our SET members and individuals who register on a course through ETF Booking System, 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 and contractual funding we are required to meet a number of targets, including evidencing the reach and impact of support programmes, such as the number of individuals who attended a course. We will store and share personal information related to our work which may have been contracted or commissioned by the Department for Education or any other third party.
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 The ETF will complete due diligence on third parties we ask to process data on our behalf. As part of our contract management processes, we keep an overview of how your data is processed by third parties.
4.4 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: communications@etfoundation.co.uk.
4.5 We will stop processing and or delete your personal data if you ask us to. Please contact us at dataprotection@etfoundation.co.uk.
4.6 We retain your information as long as necessary for each purpose we use it. In some instances, we are obliged by law to keep it for a defined period and in this event, this negates your right to be forgotten. For example, we keep all financial transaction for seven years as outlined by the Companies Act 2006. At the end of specified retention periods we dispose of your data securely.
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. All payment transactions are encrypted and stored securely.
5.2 Although the ETF try to ensure your personal data is protected, we cannot guarantee the security of your data transmitted to our site; any transmission of data 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 and/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 General Data Protection Regulation (GDPR), 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 processing your personal data by contacting dataprotection@etfoundation.co.uk.
6.4 You have a right to access the personal data that is stored about you. Any person wishing to exercise this right should complete a Subject Access Request Form and send the completed form to dataprotection@etfoundation.co.uk. The form and further information can be found on the ETF website.
6.5 For any other queries related to your individual rights you can contact dataprotection@etfoundation.co.uk.
6.6 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, web beacons and flash cookies when relevant, these include, but are not limited to: Facebook Advertising, DoubleClick, Lotame, AppNexus, EXelate, MediaMath, TradeDEsk, Semasio,Eyeota, Hotjae, Bombora and Mouseflow.
8.6 It is usually possible to stop your browser accepting cookies, or to stop it accepting cookies from a particular website. 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.
8.9 If content is shared through social media, you may be sent cookies from those sites. We do not control the settings of these cookies so do check third party sites for more information about the cookies they use and how to manage them.
9.1 If you would 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.
9.2 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. Contact details can be found below. Alternatively, you can complain directly to the Information Commissioner’s Office (ICO).
9.3 Our Data Protection Lead, Gina Hobson, can be contacted by writing to: ETF, 157-197 Buckingham Palace Road, London SW1W 9SP; e-mailing dataprotection@etfoundation.co.uk; or calling 020 7340 8280.
We’ll also hold information about you so that we can respect your preferences for being contacted by us.
Published: 24 May 2018
Updated: 24 May 2019