The Education and Training Foundation takes its duty to process your personal data seriously. This Privacy Notice and supporting Cookie Policy explains how we collect, manage, use and protect your personal data.
PRIVACY NOTICE
1 Introduction
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 professional membership organisation, the Society for Education and Training (SET).
1.2 The ETF is the expert body for professional development and standards in Further Education (FE) and Training in England. Our role is to design, develop and deliver continuous professional development (CPD) for teachers, leaders and trainers to support government policy and meet sector needs. We have a charitable purpose to improve education and training for learners aged 14 and over. We receive 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 Notice (together with our Terms of Usage) sets out the basis on which we may process your personal data and information. We are 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 We 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 Notice.
1.7 Our data sharing relationships are:
- For all government-funded work we deliver as Department for Education (DfE) grants, DfE will be the data controller, and we will act as their data processor.
- Any third-party suppliers (‘delivery partners’), who we commission to process data on our behalf will be sub-processors.
- For any contracts or programmes of work not funded by DfE or other government agencies, we will be the data controller and our delivery partners will be our data processors.
- 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 Why we process your personal data
2.1 Data provided by yourself may include:
- At the time of registering to use an ETF-owned site; booking onto our courses or programmes; subscribing to our newsletters and communications; joining or renewing your membership with SET; subscribing to marketing or programme updates (including through SET); when updating any of the information provided at the time of registering; accepting cookies on an ETF-owned site
- At the time of subscribing to our services or posting material to our sites; if you complete any surveys that we may invite you to participate in; interacting with social media accounts; and in connection with your other communications with us
- Through attendance registers at any of our events, programmes or courses, including those run by third parties
- As a decision maker within an organisation
- As a supplier of services.
2.2 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).
2.3 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.
2.4 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 Our ‘lawful bases’ for processing your personal data
3.1 We have a number of legal reasons (or the ‘lawful bases’) 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 Contractual: We use this lawful basis to process your personal data for the purpose of any contractual relationship we have with you, for example:
- If you have signed up to one or more of our courses
- If you have become a SET member
- If you have bid for one or more of our contracts
- If you have applied for a job at the ETF (see also our separate Recruitment Privacy Notice).
3.3 Consent: We use this lawful basis for any purpose where gaining your consent to process your personal data is the most appropriate approach, for example:
- If you sign up to receive our regular newsletter or other marketing materials
- If we want your permission to include your information in any of our promotional materials (website, blogs, reports, etc.)
We will always ensure that your consent can be freely given, we provide you with a clear explanation of why we want your data and what we will do with it and that you have real choice and control over how we use your data. We will always initially ask you to opt in, not out and we will always give you the opportunity to unsubscribe or remove your previously given consent.
3.4 Legitimate interest: we may choose this lawful basis where we have a genuine and legitimate reason to process your personal data and only when we are not at risk of harming any of your freedoms, rights and interests, or you would not be surprised or likely to object to receiving the communication. Examples include:
- Sending you information about courses similar to any you have previously enquired about or participated in
- Surveys linked to courses you have participated in, your job role, etc.
- Invitations to join participation groups (e.g. focus groups, special interest groups, etc.) based on courses you have participated in, your job role, etc.
- Background services, including data analytics, maintaining the security of our systems, 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.
3.5 Public task: we use this lawful basis to process your personal data where we have ‘official authority’ by, or are performing a task on behalf of the DfE as part of our contractual requirements, which is in the public interest (set out in law). Examples include:
- Evidencing the reach of support programmes (e.g. the number of individuals who attended a course)
- Analysing the impact of support programmes
4 How we use your personal data
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:
- Internal record keeping and audit purposes
- To provide details of and improve our products and services (including SET member benefits)
- To provide a tailored experience and customise the website according to your interests
- If you register with us, to provide you with information (including our newsletter) relating to similar services, programmes or projects that we may offer from time to time
- To advise of changes to our organisation or services.
4.2 We will not sell or lease your personal information to third parties and we will only share your data with third parties when:
- It is to provide you with a service or information including any benefits and services (including membership, if relevant) provided by third parties as set out above. We require all such third parties to treat your personal information as confidential and to comply with all applicable UK Data Protection Legislation (including the General Data Protection Regulation and Data Protection Act 2018) and Consumer Legislation in place at any given time, or
- You have given your explicit consent to do so, or
- Where it is necessary to comply with an order from a statutory body which is empowered to require us to release your data; or to comply with any legal obligation; or to enforce or apply any of our terms which you are subject to; or to protect the rights, property or safety of our staff or others, or
- We are acquired by a third party, in which case personal data held by it will be one of the transferred assets.
4.3 We 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 us 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 If you hold QTLS (Qualified Teacher Learning and Skills) status and/or ATS, you can opt out from inclusion on our professional status register. Members who hold QTLS status can also opt out of the DfE’s central record of qualified teachers (managed by the Teacher Regulation Agency – TRA) at any time by simply stating which register(s) you wish to be removed from at: dataprotection@etfoundation.co.uk.
4.6 We will stop processing and or delete your personal data if you ask us to (see section 7 for your individual data rights). To do so, please contact us at: dataprotection@etfoundation.co.uk.
4.7 We will retain your information only for 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 erasure (see section 6). 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 will dispose of your data securely.
5 How we keep your personal data secure
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 we 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.
6 Data processing inside and outside the UK
6.1 We do not actively transfer personal data outside of the EEA (European Economic Area). However, some of our third party processors may use systems or sub-contractors which transfer and/hold personal data offshore (i.e. in what the GDPR call ‘third countries’). In working with these third party processors, we will take all steps reasonably necessary to ensure that they protect your personal data by having in place EU adequacy decisions or standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. By submitting your personal data, you agree to this offshore transfer, storing and/or processing.
7 Your individual rights
7.1 The General Data Protection Regulation (GDPR), gives you a number of rights:
- Right to access your personal data
- Right to have your data rectified if inaccurate or incomplete
- Right to have your data erased from our systems for any reason, in situations where the continued processing is inconsistent with GDPR requirements
- Right to have processing of your personal data carried out on a restricted basis in certain circumstances
- Right to ask for your information in a structured, commonly used (accessible) and machine readable way so that it can be transferred to another controller (or transferred by us if feasible).
- Right to object to your data being processed. Reasons may include: marketing (your absolute right) or due to our legitimate interests (your limited right: we may continue if there is an overriding justification to continue processing, e.g. a contractual requirement).
- Right to object to decisions being made solely by automated means (e.g. credit decisions, e-recruiting, etc.).
7.2 If you would like to know more about your rights under the data protection law see the Information Commissioner’s Office website.
8 Contacting us
8.1 You can withdraw consent from receiving regular information and communications from the ETF and the SET by either emailing communications@etfoundation.co.uk with ‘unsubscribe’ in the subject header or by pressing the unsubscribe option at the bottom of any communications.
8.2 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.
8.3 You can access your personal data by either downloading, completing and returning completing a Subject Access Request Form or writing to dataprotection@etfoundation.co.uk.
8.4 For any other queries relating to the processing of your personal data, or to contact the ETF’s Data Protection Officer, you can:
email us at: dataprotection@etfoundation.co.uk
write to us at:
The Education and Training Foundation
3rd Floor, 157-197 Buckingham Palace Road
London SW1W 9SP.
or ‘phone us on: 020 3740 8280.
8.5 If you have a complaint about the way we have dealt with your personal data, you can write to us at complaints@etfoundation.co.uk or direct to the UK regulator, the Information Commissioner’s Office, if you feel we are not acting fairly. Our full complaints procedures can be found in the ETF Complaints Policy.
9 Links to other sites
9.1 Our website may contain links to other websites. We do 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.
_____________
COOKIE POLICY
i. It is important to us 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.
ii. Cookies may be used on our websites 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. Some of our websites require Strictly Necessary Cookies which allow core website functionality in secure areas of the site such as login and account management.
iii. Specifically, we use cookies to understand how people are using the website so that we can improve the content and overall user experience.
iv. 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.
v. In addition to Google Analytics, we also may use a range of other cookies, pixels and web beacons when relevant to help us to personalise our communications with you and to improve your user experience on our platforms. These include, but are not limited to: Facebook (Meta) advertising, Twitter advertising, LinkedIn advertising and Microsoft Clarity.
vi. 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.
vii. The ICO website provides a user friendly outline of cookies and how they work.
viii. Please note that we are not responsible for the content on other websites.
ix. 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.
Annex A: ETF web platforms we use to process personal data
In addition to our Microsoft Dynamics 365 Customer Relationship System (CRM) which we use for internal data storage, processing and email marketing, we use the following web platforms to process your personal data:
- ETF Booking system
- ETF Professional Development Platform (PDP)
- ETF Learning Platform (course search)
- SET website
- Advanced Teacher Status (ATS) / Qualified Teacher Learning and Skills (QTLS) Portfolio
- ETF Learners (free resource about radicalisation, safeguarding and British values)
Annex B: Examples processing where we use ‘legitimate interest’ as our lawful basis:
- Direct Marketing: We will send postal, text and e-marketing communications and marketing asks which further the aims and objectives of the ETF and the Society for Education and Training. We will also make sure our marketing communications is relevant for you, tailored to your interests.
- Ordering online: In order for us to process an order, payment has to be taken and contact information collected, such as name, delivery address, email address and telephone number, provided.
- Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
- Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our supporters.
- Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests. Please see our privacy policy above for further details.
- Research and evidence: To determine the effectiveness of our services and products, marketing and communications and to develop our products, services, systems and relationships with you.
- Due Diligence: We may need to conduct investigations on supporters, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption. So that we can respect your preferences for being contacted by us.
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. Therefore, our needs do not automatically override your personal data rights (unless we have your consent or are otherwise required or permitted to by law).
First published: – 24 May 2018
Updated: – 25 July 2024
