ACCOUNTANCY LEARNING LTD – PRIVACY POLICY (010720 – Updated 131222)

Accountancy Learning Ltd (which means Accountancy Learning and associated companies) (AL) is an Independent Accountancy Training Provider, providing a range of blended study packages to both distance learning and Apprentice students. We take the protection of your personal information very seriously and take all precautions necessary to ensure that the information we hold about you is held securely and processed in accordance with relevant data protection legislation and our own policies and procedures.

This Privacy Notice outlines how we use your information and what you need to know to understand how we process and protect your information, why we need the information, in what circumstances we may share your information with a third party and outlines your legal rights. It also sets out any other important information we feel you need to know.

For the purposes of the General Data Protection Regulations (GDPR), AL is considered to be the Data Controller for the personal data and information we hold on individuals, regardless of whether they are private individuals or named individuals within an organisation.

Thus, we have legal obligations to keep personal information safe whether we are processing the information directly, or have commissioned a third party, referred to as a ‘Processor’ to perform the task on our behalf.

Any questions regarding our Privacy Policy should be directed to Accountancy Learning as per details at the end of this policy.

Your acceptance of these Privacy Policy terms/Explicit Consent.

By using any of the sites within our web site network, or our Services, you unconditionally agree to be bound by the Privacy Policy.

The data we collect is for a specific, explicit and legitimate purpose.

We cannot and will not use information collected for one purpose for another without your permission.

We will gain your explicit consent where we may want to legitimately use personal data we hold about you.

Why we may hold information about you and how this is collected.

To offer our services to students and employers, to support our employees and comply with our statutory and legal obligations we need to both capture and process personal information. The information we hold is collected verbally, through correspondence, from visits and inspections, when you sign up to a course or to receive our emails/course information, surveys, competitions or when speaking to us by telephone.

How we use your information.

The GDPR defines a number of data protection principles which must be observed when processing information. We strictly adhere to these principles, which in broad terms we comply with as follows.

AL will only use the information it holds about you for the purpose for which you provided it, except in the circumstances outlined in this notice or as permitted within the legislation. We will collect the minimum information necessary to fulfil that purpose and when you provide information, you will be told what it will be used for and with whom it will be shared.

We will keep the information as accurate as possible, keep your information for no longer than is necessary and dispose of the information in a secure manner when no longer needed. Whilst within our control your information will be kept securely and we shall protect it against unauthorised access and accidental loss.

You have a number of legal rights in relation to the information we hold about you, and these rights are outlined in full at the end of this notice.

AL’s legitimate interests may provide a legal basis for processing data, provided that the interests or the fundamental rights and freedoms of our students and employers are not overriding, taking into consideration your reasonable expectations based on your relationship with AL. Such legitimate interest could exist where there is a relevant and appropriate relationship between you and AL, taking into consideration whether you can reasonably expect at the time and in the context of the collection of your personal data that processing for that purpose may take place. Your interests and your fundamental rights could in particular override the interest of AL where personal data is processed in circumstances where you do not reasonably expect further processing.

We are required to use your information fairly and lawfully and we will only process (collect, store and use) personal and sensitive information about you in ways that meet the rules of GDPR.

If you cancel a course within 14 days of placing your order we shall delete your data when you cancel. If you unsubscribe from our marketing emails we shall delete your data immediately unless you continue to receive services from us as we shall need your data to continue providing those services. Data is archived after course expiry or completion date and is deleted after six years. You may enter credit card details into our website when you purchase something from us. Credit card details are processed by STRIPE and are not retained by AL.

Why does AL collect and retain Personal Data?

To fulfil our statutory functions and in order to provide you with efficient and effective service we need to collect personal data.

AL will use information about you for the provision of services. This includes but is not necessarily limited to the following:

  • To process orders or applications submitted by you.

  • To monitor your performance in your studies so that we can provide you with advice

    for improvement.

  • To process all financial transactions to and from AL in relation to your studies and

    outstanding monies due.

  • To promote social well-being we may need to share your personal and sensitive

    information with our partner agencies.

  • To identify you each time you visit a Web Site or wish to have a Service provided.

  • To improve our Web Site and Services.

  • To customise your experience, for example, provide advertisements that we think

    are relevant to you and support any specific requests for information you may make

    through keyword searches.

  • To carry our research on the demographics, interests and behaviour of all our

    customers.

  • To send you information we think you may find useful, including information about

    new AL products and Services.

  • Maintaining our own accounts and records

  • Supporting and managing our employees

  • Corporate administration and all activities we are required to carry out as a data

    controller and service provider

  • Internal financial support and corporate functions

  • Managing archived records for historical and research reasons

    The type of information we process.

    AL processes personal information to enable us to provide a range of services to customers which include:

  • Log files/IP addresses for recognition by our web server.

  • Non-personal information such as your type of internet browser (you cannot be

    identified from this)

    Use of Cookies

    Cookies are pieces of information that a Web Site transfers to your hard drive to store and sometimes track information about you. Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. However, you may not be able to take full advantage of a Web Site if you do so. Cookies are specific to the server that created them and cannot be accessed by other servers, which means they cannot be used to track your movements around the web. Although they do identify a user’s computer, cookies do not personally identify customers or passwords. Credit card information is not stored in cookies.

We use cookies for the following reasons:

  • To identify who you are and to access your account information;

  • To estimate our audience size and patterns;

  • To ensure that you are not asked to register twice;

  • To control how often visitors see similar ads;

  • To track preferences and to improve and update our Web Site; and

  • To track the progress and number of entries in some of our promotions and

    contests.

    Who information is processed about.

    We process personal information about:

  • Students

  • Employers

  • Staff

  • Complainants

  • Enquirers

  • Suppliers

  • Representatives of other organisations

    Who we share your information with.

    Your information will be shared internally when it is necessary to enable us to fulfil our contractual obligations to you, your employer or other agencies legally entitled to request such information.

    Accountancy Learning may disclose personal information if required to do so by law or if it believes that such action is necessary to protect and defend the rights, property or personal safety of Accountancy Learning and its Web Sites, visitors to the Web Sites and customers of our Services. Our Web Site contains links to the sites of third parties. When you visit these sites, we suggest that you read their privacy policies. Accountancy Learning is not responsible for the privacy policies or the content of such sites.

    AL will not sell, share or rent your information to third parties other than as explained here. AL may need to share your personal data with other service providers and partners who are contracted to carry out services on our behalf or for whom we carry out services. These providers are obliged to keep your personal details secure in line with GDPR and AL policies. Please note, AL is not responsible for the Privacy Policies of third parties.

    Third parties include but are not limited to:

  • BCTG

  • Cornwall Marine Network

  • Somerset Skills and Learning

  • Cornwall College

  • Education and Skills Funding Agency

  • Ofsted

  • Employers of apprentices

  • Mercia

  • AAT

  • Other exam centres

  • ICAEW

  • BKSB

  • Contact Associates

  • Tolley Exam Training

  • Freelance tutors

  • STRIPE

    We will only sell or rent your personal information to a third party either as part of a sale of the assets of an Accountancy Learning company or having ensured that steps have been taken to ensure that your privacy rights continue to be protected.

    Accountancy Learning may disclose aggregate statistics about our sales, our Web Site visitors and customers of our telephone services in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will not include personal identifying information.

    How we keep your information safe.

    To keep personal information safe AL has in place a range of safeguards and procedures.

    Information is kept safe using all reasonable technical measures that include precautionary measures such as Firewalls, Secure Server software (SSL) for encryption of financial information you send to us replication to Disaster Recovery site. Our firewall firmware/software is updated regularly. While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur, we use our best efforts to prevent this.

    From an organisational point of view, we train staff in data protection and how to keep your information safe. We are constantly looking at ways to improve security, and have policies and procedures in place to assist in that endeavour.

    Where is the information stored?

    Information which you submit via our Web Sites or our telephone services is stored on a computer located in the European Economic Area. This is necessary in order to process the information and to send you any information you have requested. Information submitted by you may be transferred by us to our other offices and to reputable third party suppliers, which may be situated outside the European Economic Area. Not all countries outside the EEA have data protection or privacy laws. In addition, if you use our Services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those Services.

    Marketing, Consent and Permissions.

AL will only approach you for marketing exercises where you have explicitly provided details for that purpose. We will make it easy for you to withdraw consent and will immediately stop processing your data as soon as you opt out or raise an objection to us.

It is very important to us that we provide you with the highest level of service. In order to help us do this, from time to time Accountancy Learning companies may send you details of our products and services which we think may be of interest to you. If at any time you do not wish to receive these details, please e-mail us at Accountancy Learning.

What is Personal Data?

Personal data means ‘any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’. IP addresses and cookie strings are now seen as personal data and there is no distinction between personal data about individuals in their private, public or work roles.

Sensitive Personal Data.

Some data is considered sensitive under GDPR regulations. The only part of your personal information that forms such data held by AL is as follows:

  • Data concerning a person’s mental or physical health if declared at source or subsequently uncovered during study.

  • Data concerning ethnicity – held for statistical purposes. Your Rights

    The right to be Informed.

    You have a right to be told how and why your data is being used, who it is being shared with, and if your fundamental rights or freedoms may be affected. You also have the right to be told if your information was involved in a data breach.

    The right of Rectification.

    You are entitled to have any personal data held by AL rectified if it is inaccurate or incomplete.

    If we have disclosed the personal data in question to any of our partners or other parties we will inform them of the rectification, where possible. We will also inform you about the parties to whom the data has been disclosed, where appropriate and will do this within one month.

    If we are not taking action in response to a request for rectification, we will explain why to you and inform you of your complaint rights.

    The right to Restrict Processing.

We will restrict the processing of personal data in the following circumstances:

• If you contest the accuracy of the personal data we will restrict processing until we have verified the accuracy of it.

• Where you have objected to the processing (where it was necessary for a legitimate interest), and we are considering whether AL’s legitimate grounds override yours.

• When processing is unlawful and you oppose erasure and request a restriction instead.

• If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

If we have disclosed the personal data in question to our partners or other parties, we will inform them about the restriction on the processing of personal data, unless it is impossible or involves disproportionate effort to do so.

We will inform you when we decide to lift a restriction on processing and we will retain just enough information to ensure that the restriction is respected in the future.

The right to Object.

You have the right to object to:

  • Processing based on legitimate interests.

  • Direct marketing.

  • Processing for purposes of historical research and statistics.

    If we are processing your personal data for the performance of a legal task or AL’s legitimate interests you must have an objection on grounds relating to your particular situation. We will stop processing your personal data unless:

• We can demonstrate compelling legitimate grounds for the processing, which override your interests and rights and freedoms.

The right of Access.

You have the right to access the personal data held on you. This is so you are aware of and can verify the lawfulness of the processing of your data.

We will provide, free of charge, a copy of your personal information within one calendar month of receipt of such request. However, we reserve the right to make a charge where the request is manifestly unfounded or excessive, particularly if it is repetitive. The request could also be refused. Any fee charged will be based upon the administrative cost of providing the information. A further fee will also be charged to comply with requests for further copies of the same information.

You will be asked to verify your identity when making such requests.

The right to Erasure/The right to be Forgotten.

You have the right to request the deletion or removal of personal data where there is no compelling reason for its continued processing. This will apply where:

  • The personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.

  • You withdraw consent.

  • You object to the processing and there is no overriding legitimate interest for

    continuing the processing.

  • The personal data was unlawfully processed.

  • The personal data has to be erased in order to comply with a legal obligation.

    Your request for erasure will not be complied with where the personal data is processed for the following reason:

• Statistical purposes. Complaints.

If you have any questions about the contents of this document or would like to know what information we hold on you, please contact the following:

The Data Protection Officer Accountancy Learning Southernhay Lodge Barnfield Crescent

Exeter EX1 1QT

Telephone: 01329 435349 Email: [email protected]

You have the right to complain to the Information Commissioner’s Office should you be dissatisfied with the way AL has handled your personal data. Their details are as follows:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113. https://ico.org.uk/global/contact-us/