Introduction

Contented is committed to data security and the fair and transparent processing of personal data. This privacy policy (Policy) sets out how members of Contented treat learner and other personal data, including persons appearing in video footage filmed and/or retained by the company (“data subjects”). Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

Who we are

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), Contented Ltd is the ‘controller’ of learner personal data. Contented Ltd is a private company registered in England & Wales, number 3949963. Our registered address is 33b Government Row, Enfield, Greater London EN3 6JN.  Our associated company in Ireland, Contented Communications Ltd, is registered at 6 Glenaulin Park, Chapel Izod, Dublin 20, company number 599762.  We refer to these as the Contented Group.

Contented (we, us, our) is a strategic communications company specialising in change and innovation.  Contented develops & delivers communications strategies, tools and products for corporate and public sector projects and programmes. From market visits and study tours to digital storytelling, we help engage audiences and inspire behaviours.

If you have any queries about this policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Officer: by writing to Privacy Officer, Contented Ltd, 33b Government Row, London EN3 6JN; or by email to privacy@contented.net

What personal data do we collect?

We may collect and process the following personal data:

1. Information you provide to us.

If you:

  • complete a form on our website;
  • complete a survey;
  • correspond with us by phone, e-mail, or in writing;
  • report a problem;
  • sign up to receive our communications;
  • create an account with us;
  • enter into a contract with us to receive products and/or services;
  • complete a filming consent form to waive your rights;
  • sign a confidentiality agreement to supply services for us.

then we may collect your name, e-mail address, postal address, telephone number and job role.

Information about other people

If you provide information to us about any person other than yourself, such as your relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

Contributors (people) in video and audio productions

If you are featured in digital content that we produce, such as an interview or as a participant in an event we are filming, we may ask you to sign a release form to consent to us using your image.  If you are interviewed, this will normally appear with your name and a descriptor of your function as appropriate to the audience.

2. Information we collect about you automatically:

If you visit our website, we may automatically collect the following information:

  1. technical information, including the internet protocol (IP) address used to connect your computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  2. information about your visit to our website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction;
  3. information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

3. Information we receive from other sources:

We may also receive information about you if you use any of the other websites we operate or the other services we provide.

If you are a tutor, apprentice, or learner (including on work experience placement), we may also receive information about you from your centre, training provider, university or employer when they register to receive products and/or services form us, including placing you with us.

Sensitive personal data

In certain limited cases, we may collect certain sensitive personal data from you (that is, information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, or details of criminal offences. However, we will only do so on the basis of your explicit consent.

Training, Learning & Certification

As well as your name, gender, and date of birth, we may also collect other categories of personal data if required in relation to a specific qualification or programme, and personal data if required to carry our quality assurance processes, investigations, complaints and appeals. This personal data may be provided to us by centres, providers, awarding bodies, or other industry bodies you have registered with to receive learning, assessment, and/or certification products and/or services provided by us.

In exceptional circumstances, we may be provided with sensitive personal data, such as information about your health, to enable us to administer requests for reasonable adjustments, or sensitive personal data relating to an investigation, complaint, or appeal. Such information should only be provided to us by your Centre or Provider if you have given your explicit consent to your centre or provider.

We assign a unique learner number to each learner at the point of learner enrolment which we also use in relation to your learning, assessment, and certification.

How do we use your personal data?

When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

Training, assessment & certification:

We may use your personal data where this is necessary to pursue our legitimate interests as a provider of training, assessment, and certification products and/or services, including to:

  • provide you with products and/or services for which you have registered;
  • undertake administration in relation to products and/or services for which you have registered;
  • provide you with a certificate, credential or other record of learning;
  • contact you directly in relation to our quality assurance processes, investigations, appeals, and complaints;
  • contact you directly in relation to new and existing products, services, news, awards and events offered by certifying or accrediting bodies, or among the Contented Group;
  • assess and provide reasonable adjustments in relation to your learning or assessment where requested.

Contract performance:

we may use your personal data to fulfil a contract, or take steps linked to a contract:

  • to provide the products and/or services to you;
  • to communicate with you in relation to the provision of the contracted products and services;
  • to provide you with administrative support such as account creation, security, and responding to issues; and
  • provide you with industry information, surveys, information about our awards and events, offers and promotions, related to the products and/or services.

Audio and/or Video Production: we may use your recorded contribution to edit into video and audio materials as part of the service we provide to our customers/clients.

Legitimate interests: where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:

  • providing you with newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by a member of the Contented Group which may be of interest to you;
  • communicating with you in relation to any issues, complaints, or disputes;
  • improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our website;
  • performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns.

NOTE: you have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your rights.

Consent: where you have given your express consent to receive marketing communications, we may use your personal data to:

  • send you newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by a member of the Contented Group which may be of interest to you;
  • developing, improving, and delivering marketing and advertising for products and services offered by a member of the Contented Group.

Where required by law: we may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

Who do we share your personal data with?

We may share your personal data with members of the Contented Group and their staff, including contracted suppliers.  You can read more about our group companies at www.contened.net

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share your personal data with trusted third parties including:

  • legal and other professional advisers, consultants, and professional experts;
  • service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services; and service providers contracted to us in connection with provision of learning, assessment, and training products and services such as markers, moderators, assessors, certification or credentialing providers; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may share your personal data with relevant third parties, where necessary, in relation to your learning, assessment, or certification, including:

  • certification, professional or awarding bodies, regulatory authorities, sector skills councils, and similar industry bodies;
  • consortiums, authorised representatives, and partners; and
  • centres, providers, awarding bodies, professional bodies and similar third parties, such as to offer you student membership in relation to leadership and management.

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of seven years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities. Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.

We will also retain personal data relating to your learning, assessment, and certification to enable us to provide information about your learning or a replacement certificate. We will retain personal data relating to our quality assurance processes, appeals, or investigations for seven years to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.


Where do we store your personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We will store any recording of your audio/video contribution on digital or analogue video and sound recording media files.

Where you have a username or password (or other identification information) which enables you to access certain services or parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 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 personal data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

Under the GDPR, you have various rights with respect to our use of your personal data:

Right to Access

You have the right to find out more about the personal data which the company holds about you, what it is doing with that personal data, and why, and to request a copy of the personal data.  You can do this by contacting us at the email or Contented Ltd’s registered office at 33b Government Row, London EN3 6JN.  Please include with your request information that will enable us to verify your identity. We will normally respond with 30 days of receipt. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.

We will respond to any requests from a person or company to locate footage that they appear in and, if requested, delete that footage – except where a person has signed a Waiver Release form waiving their right to ask for media they appear in to be deleted.

The Company does not charge a fee for the handling of normal requests. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

Right to rectification

We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the pressing of your personal data, please contact us using the contact details provided below.

Right to restrict processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.

Right to data portability

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Unsubscribing

You may unsubscribe from marketing communications at any time by contacting us at enquiry@contented.net or by using the ‘unsubscribe’ functionality on the footer of any marketing communications sent to you.

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns for more information on how to report a concern to the UK Information Commissioner’s Office.

Changes to our Policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.

Contact

If you have any queries about this policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Officer: by writing to Privacy Officer, Contented Ltd, 33b Government Row, London EN3 6JN; or by sending an email to privacy@contented.net

Authorisation & Review

This Data and Privacy Policy has beenreviewed and authorised by:
Name: Gerard Davies
Position: Managing Director and Quality Manager, Contented Ltd
Review date: 01August 2018
Due for review by: 01February 2019