Titan Development Centre (TDC) needs to collect and use certain types of information about people with whom it deals with in order to operate. These include current, past and prospective employees, suppliers, clients and others with whom it communicates. This personal information must be dealt with properly, however it is collected, recorded or used, whether this be on paper, in a computer or recorded on other material. There are safeguards to ensure that this is in line with the Data Protection Act (incorporating the General Data Protection Regulations) 2018.
We regard the lawful and correct treatment of personal information by TDC as very important to successful operations and to maintaining confidence between those with whom we deal and ourselves. We ensure that our organisation treats personal information lawfully and correctly.
Under the data protection legislation there are six data protection principles that the Centre and all staff must always comply with in their data processing activities. In brief, the principles say that personal data must be:
- Processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency);
- Collected only for a specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation);
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation);
- Accurate and, where necessary, kept up to date; every reasonable step must also be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy);
- Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the personal data are processed (storage limitation);
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality);
- The Centre is responsible for and must be able to demonstrate compliance with these data protection principles (accountability).
Therefore, TDC will, through appropriate management and the strict application of criteria and controls:
- Observe fully the conditions relating to the fair collection and use of information;
- Meet it’s legal obligations to specify the purposes for which information is used;
- Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
- Ensure the quality of information used;
- Apply strict checks to determine the length of time information is held;
- Ensure that the rights of people about whom information is held can be fully exercised under the Act.
These include:
- The right to be informed that processing is being undertaken;
- The right of access to one’s personal data;
- The right to prevent processing in certain circumstances;
- The right to correct, rectify, block or erase information which is regarded as incorrect;
- Take appropriate technical and organisational security measures to safeguard personal information;
- Ensure that personal information is not transferred abroad without suitable safeguards.
In addition:
- Overall responsibility for Data Protection in TDC rests with the Managing Director, Simon McHardy;
- Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;
- Everyone managing and handling personal information is appropriately trained to do so;
- Everyone is appropriately supervised;
- Anybody wanting to make enquiries about handling personal information knows what to do;
- Queries about handling personal information are promptly and courteously dealt with;
- Methods of handling personal information are clearly described;
- A regular review and audit is made of the way personal information is managed;
- Methods of handling personal information are regularly assessed and evaluated.
If you are undertaking courses, work-based learning awards, exams or qualifications provided by us, we collect the information we need in order to provide these products and services to you including but not limited to your name, date of birth, gender, telephone number and qualification awarded. It may also include photos of you and copies of your signature.
This information will be held by us for a period of 40 years from the date you complete your course, work-based learning award or exam so that we can comply with regulatory requirements and requirements to deliver future services such as certificate re-prints and confirmation of awards.
Information that is processed as part of the qualification, such as your exam papers, will be held for no longer than 6 months from the date the information is collected.
We may also capture personal data about you when we conduct a quality visit (such as video evidence of training). Once we have concluded our review, the personal data stored for this purpose will be deleted or destroyed.
If you contact us to request a replacement certificate, we will retain a record of the address to which you wish the certificate to be sent for no longer than 6 months.
If you work for an educational, regulatory or government body that TDC engages with, then we will process your personal data on the grounds of our legitimate interest in fulfilling our obligations or working partnership with your organisation.
Any personal information captured as part of our engagement will stay in place so long as we hold a contract or an arrangement with the organisation or, if earlier, until we are notified that you are no longer the relevant person to contact at the organisation.
The information we hold about you is likely to include your name, email address and telephone number. The remainder of the information we collect will be organisation information and therefore not covered by data protection legislation.
We process your personal data in order to:
- Communicate with the organisation, for example to respond to requests or to seek clarifications through email or telephone.
- Retain contact information for the organisation in TDC’s compliance and business continuity systems.
If you are a learner, we may also share your data with:
- Awarding Organisations and regulators to the extent necessary to provide you with the products and services requested for you.
- The Security Industry Authority to the extent necessary to comply with regulatory requirements (the information shared is likely to include your photo ID and signature).
- The national Learning Record Service.
- Other regulatory bodies to the extent we are required to do so in relation to, for example, investigations.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Unless otherwise expressly stated in this privacy policy, we do not transfer your personal data outside of the EEA.
Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website –Â https://ico.org.uk/concerns/