|Policy prepared by:||Robert Price (Director)|
|Approved by DPO:||11/05/2018|
|Policy became operational on:||11/05/2018|
|Next review date:||May 2019|
Your Personal Data
Personal data relates to a natural living individual who can be identified from that data.
Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.
The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
Who We Are
We are Inrad Group Ltd. We provide the following services:
- Water Rescue Training
- BC Canoeing and Kayaking Courses
- Adventure Activities
- First Aid Training
How Do We Process Your Personal Data
Inrad Group Ltd complies with its obligations under the “GDPR” by
- keeping personal data up to date;
- storing and destroying it securely;
- collecting or retaining only required and legitimate data;
- protecting personal data from loss, misuse, unauthorised access or disclosure
- ensuring that appropriate technical measures are in place to protect personal data.
How We Collect and Use Personal Data
We collect your Personal Data in a number of ways and for various purposes, including:
- When you register for a course or activity Read MoreWe collect Personal Data when you use or interact with our Services, including when you register with us, obtain coaching and training services, make purchases from us (including processing of payment), and when you ask us to customize products, or Services. This Personal Data may include name, address, phone number, email address, date of birth and payment information.
- When you communicate with us or sign up for promotional materials.
Read MoreWe collect Personal Data when you communicate with us or sign up to receive promotional materials or information via email or text messages – including email address, mobile number, etc.
If you consent to such messages, we may use your Personal Data and other information to communicate with you about Inrad Group Ltd products or Services you have purchased or used. We may use your Personal Data to respond to your requests for technical support, product information or to any other communication you initiate. We may also use your Personal Data to address your requests, inquiries, and complaints.
How We Disclose Personal Data
Your personal data will be treated as strictly confidential and will only be shared with others for purposes connected with the the issuing of certificates by and registration with our Awarding Bodies. For further information on legitimate interests please see our website at www.inrad.co.uk//privacy-policy/ We will only share your data with third parties with your consent (see additional consent form). In particular we will share your data for:
- For the production and recording of certificates of attendance and qualificationsRead MoreWe release your personal data, including: Full name, date of birth, sex, full address, telephone, number and e-mail address to our Awarding Organisations for the sole purpose of producing pass and attendance certificates and registering you with appropriate qualification organisations. We have obtained GDPR assurances form all such organisations that they are GDPR compliant.
Third parties that we share your information with in order to produce and register your qualification are:
- Rescue Emergency Care (All first Aid qualifications and Training)
- British Canoeing (Certain BC qualifications and courses)
- Historica (Certain Water Qualifications where the awarding organisations is SFJ Awards).
- DofE (all DofE courses, expeditions etc)
What We Use Your Personal Data For
- to enable us to provide a responsible and safe course or event for our clients;
- to administer assessments, progress and records;
- to manage our staff and volunteers;
- to maintain our own accounts and records;
- to inform you of news, events, activities and services run by Inrad Group Ltd;
- to share your contact details with our awarding bodies so they can award certificates, and register you as a learner.
Legal Basis for Processing your Data (Lawful Basis)
In case of questions about the processing of your Personal Data please contact us via our contacts page or in writing at the address given, under Contacting us, at the end of this document.
- Vital Interests:Read MoreTo ensure that you, other members of a course or event and the general public are safe and to protect your life in the case of accident or emergency.
- Criminal Conviction DataRead MoreInrad Group Ltd will process Criminal Conviction Data through the Disclosures and Barring Service (DBS), in accordance with Article 10, when employing full time, part time or sessional staff. In particular we will seek DBS information relating to:
- Children’s Barred List Information
- Adult Barred List Information
No comprehensive register of criminal convictions shall be kept by Inrad Group Ltd.
- For the performance of a contract Read MoreTo perform our contractual obligations to you, including account registration, fulfilling orders or purchases you have made (including processing of payment), contacting you in relation to any issues with your order, in relation to the provision of the Services, when you ask us to customise a product or service, where we need to provide your Personal Data to our service providers.
- To meet legal obligations Read MoreTo comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.
- For Legitimate InterestsRead MoreTo operate our business and provide the Services, other than in performing our contractual obligations to you for Inrad Group’s “legitimate interests” for the purposes of applicable law – except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.For example, the following areas include processing covered by Legitimate Interests, subject to applicable law:
- Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and also to address your requests, inquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other Inrad Group e-mails or communications. These types of communications do not require consent. We also process your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and we have not asked you for your consent in that regard.
- Respond to Your Requests. To respond to your requests for technical support or to any other communication you initiate.
- Compliance with Law and Public Safety. To assist in the investigation of suspected illegal or wrongful activity, including sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property (including intellectual property and copyright materials), or the rights or safety of third parties.
- Merger or Acquisition. To support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
Consent As A Basis For Processing
In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when providing us with your Personal Data through our Services or a form. We may request your consent for a number of activities including:
- Processing sensitive Personal Data. Read MoreWe may request your consent to process sensitive Personal Data. Such as:
- on-going course assessment
- medical declaration forms
- images and recordings
You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection. Please contact us via the contacts page regarding this.
We will retain your Personal Data for as long as is necessary to provide you agreed Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For qualifications having legitimacy periods, such as 3-year first aid qualifications, etc, we will retain your data for up to 2 years after the expiry date. Data pertaining to accidents or complaints will be retained in accordance with current legislation.
Where permissible, we will also delete your Personal Data upon your request. For information on how to make a deletion request contact us via the contacts page on our website. Specifically, we retain data while it is still current on:
- candidate / participant’s name address and unique learner number
- telephone mobile numbers of those with parental responsibility for contact only
- medical / injury information
Your Rights And Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of your personal data which Inrad Group Ltd holds about you;
- The right to request that Inrad Group Ltd corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for Inrad Group Ltd to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that arestriction is placed on further processing;
- The right to object to the processing of personal data: this applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of educational research and statistics).
- The right to lodge a complaint with the Information Commissioners Office.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
Links to Other Websites.
We do not knowingly collect Personal Data online from children under 13. If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our contact page on our website. If we become aware that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove the data.
How to Contact Us
To exercise all relevant rights, queries of complaints please in the first instance contact:
21 Pipe Gate
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.