Privacy and cookie policy

Introduction

This privacy policy describes how The Training Exchange Ltd (‘The Training Exchange’) collects, processes, shares and stores personal data.

What data do we collect and process?

The Training Exchange collects information about organisations and individuals for the purpose of promoting and delivering training and consultancy services. This includes organisation name, individual name, job title, work address, work email and telephone numbers (mobile and landline). Occasionally, where individuals give these as their contact details, we collect and process personal addresses, email addresses and telephone numbers.

This data is defined as ‘personal data’, that is any information which, either alone or in combination with other information, identifies you as an individual (General Data Protection Regulation 2018).

The Training Exchange will only process your personal data in accordance with applicable data protection and privacy laws. We collect the minimum amount of data necessary to deliver our services.

In some instances we may request sensitive personal data from you, if you have any access needs that we need to know about that might affect your learning experience. Sensitive personal data includes information related to religion or other beliefs, health or disability. Providing sensitive personal data is never a requirement to use our services; by providing us with this information you are consenting to us using it in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such information to our website or services.

If you provide us with information about other people or organisations, it is your responsibility to obtain their consent regarding us storing and processing their information in accordance with this policy.

Whilst The Training Exchange seeks to keep information up to date, we also rely on users to inform us if their information is incorrect or out of date and if any alterations need to be made.

If you do not want us to process your information and use it as detailed in this policy, you can remove or alter your permission at any time (see Your rights below).

Why do we need your personal data?

This information helps The Training Exchange and associate trainers to:

• Know who is coming to courses so that we can tailor courses accordingly.
• Report back to organisations that purchase training about who has attended.
• Enhance and improve the services we provide.
• Provide individuals and organisations with information about training opportunities and consultancy services offered by The Training Exchange.
• Analyse who accesses our services for future planning purposes.

How do we collect data?

We collect personal data when people use our services. You or your organisation may provide this data when:

• You sign up to or attend a Training Exchange event or training.You ask for information about The Training Exchange services by email, over the phone, or directly with a Training Exchange member of staff.
• You correspond with us by phone, email or otherwise.

We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners or commissioners; or if that information is in the public domain, for example on your organisation website.

Cookies

We may use technology to track the patterns of behaviour of visitors to our website. This can include using a "cookie" which would be stored on the hard drive of your computer or mobile device by our website. Some cookies are essential to ensure the site works as expected; others are non-essential and anonymously track visitors to enhance experience of the site. You can remove or reject cookies via your browser settings. Disabling cookies may mean some features of the site are unavailable (see Cookie policy).

Sharing your personal data

We may share your personal data with our third party service providers who provide services such as payment processing, information technology and related infrastructure provision. These third parties are Microsoft (who provide our email and office systems, supported by Third Sector Systems), Mailchimp, Survey Monkey, Quickbooks, Guru Data (database design and servicing), Jon O’Hara (web design and support), Hunter Accountants. They are only permitted to use your personal data to the extent necessary to enable them to provide their services to us and are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.

We may share your personal data with associate trainers who are contracted to provide training and consultancy services on our behalf, and with our book keeper. Our associate trainers and our bookkeeper are only permitted to use your personal data to the extent necessary to enable them to provide their services to us and are required to sign contracts to demonstrate GDPR compliance.

We may share your data with third parties on the basis that we are jointly undertaking or being commissioned to fulfill a contract with them, this may include your employer.

We may share your personal data if and when we sell or transfer all or a part of our business or assets. This could include any merger, acquisition, or bankruptcy transaction or proceeding.

We may share personal data as we believe necessary or appropriate to comply with applicable laws; to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; to enforce our Policy; and to protect our rights, privacy, safety or property, and/or that of you or others.

Location and accessibility of data

Information is stored on our secure servers in the UK and we have implemented the appropriate measures to protect it from improper access, destruction, tampering and loss. Data held by The Training Exchange is accessible to our staff members and associate trainers so that we can provide a thorough and personalised service. The Training Exchange has internal agreements with staff and associate trainers which requires them to not share information outside of The Training Exchange, unless required to do so by law.

Data retention

We will only retain your personal data for a maximum of 48 months after your last interaction with our services or other contact with The Training Exchange unless a longer retention period is required or permitted by law (for example for regulatory purposes). Some service contracts require data relating to their delivery to be retained by the provider for a number of years after the contract has been completed, and HMRC requires us to retain company accounts for at least 6 years from the end of the last company financial year they relate to. Therefore The Training Exchange may retain some information for archival purposes and historical analysis for more than 48 months in order to comply with such requirements. All data is deleted securely.

Our policy on children

Our Services and Website are not usually directed to individuals under 16, and as such individuals under 16 should not submit information to our site or otherwise use our site and services. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact us and we will delete any information from our files. If a contract involves work with young people under 16, we will ensure consent from parents or carers to process any personal information.

Your rights

Object- You have the right to object to any processing of your data at any time.

Opt-out- you may contact us anytime to opt-out of:

• Direct marketing communications;
• Collection or processing of your sensitive personal data; and
• Any other processing we undertake.

If you wish to unsubscribe from a mailing or newsletter you can click the unsubscribe button at the bottom of the email.

Access - You may access the information we hold about you at any time by contacting us directly using the contact details at the bottom of this page.

Amend - You can contact us to update or correct any inaccuracies in your personal data. We will contact individuals and organisations periodically to review and correct the information we hold about them. We remind users to take responsibility to maintain the accuracy of information we hold about them, and inform us of any changes.

Erase and forget - You have the right to request we erase any information you no longer want us to hold.

If you wish to exercise any of the rights detailed above, please contact us. In your request, please make clear what personal data is concerned, and which of the above rights you would like to enforce.

We may need to verify your identity before implementing your request and will try to comply with your request within 30 days of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Complaints

We are committed to resolving any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us using the details below. We will respond to your complaint within 30 days and in accordance with our complaints procedure. We hope to resolve any complaint brought to our attention, however, if you feel that your complaint (about our use of your data) has not been adequately resolved, you have the right to contact the Information Commissioner’s Office.