UPDATED 20/05/2018 to Comply with General Data Protection Regulation 2018
Seagull Training services are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Seagull Training Services. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By visiting you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Seagull Training Services, Stibb, Bude, Cornwall EX23 9HP
Information we may collect from you
We may collect and process the following data about you:
• Information you give us: You may give us information about you by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use our Webpage or our FaceBook page Seagull Training Services ‘Accredited Training Provider’. The information you give us may include your name, address, e-mail address, phone number, personal description, photograph and date of birth.
• Information we collect about you: With regard to each of your visits to our website we may automatically collect the following information: Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit: The full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Information we receive from other sources: In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, your employer, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Uses made of the information
We use information held about you in the following ways:
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us.
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
• To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form).
• To notify you about changes to our service.
• To ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
• To allow you to participate in interactive features of our service, when you choose to do so.
• As part of our efforts to keep our site safe and secure.
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources
• We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Information collected for training purposes.
• To fulfil our contractual obligation with your employer/company or you directly, we require certain/relevant information to allow us to produce certification. Your Name, Email Address, Home Address, Date of Birth, and Telephone number are all required, and in some instance, your National Insurance Number. These details are required for the production of certification which forms part of the contract between either Seagull Training Services and your company, or Seagull Training Services and yourself and the private individual (Name & Date of Birth – if accredited training through ITSSAR or RTITB – contract & legal obligation), to post certification (Personal Address if booked Privately – contract) & to send you training confirmation and joining instructions (Email Address – contract). In addition, we also may require your telephone number if you have booked directly with us, to contact you for payment, date amendments and late arrival for scheduled training which forms part of the contract entered between both parties upon booking.
All personal data requires a lawful basis for processing, for more information on how we collect or process your personal information, contact Seagulltraining@btinternet.com. If you want more information on what each lawful basis is, or how it may be used please visit the ICO Website – Guide to Lawful Basis for Processing
Disclosure of your information
In most circumstances, we will not share your information without your prior consent. However we may share your information as outlined below;
We may share your personal information with any member of our group, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. [We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience].
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Seagull Training Services or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Where we store your personal data:
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, 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 data transmitted to our website or FaceBook page, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long do we keep your information?
In line with our accrediting bodies, we retain your information for 7 years. We do this to fulfil our legal obligation to be able to prove candidates have received adequate basic training.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at seagulltrainingservices.com
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In addition, you have new rights under GDPR as below:
2. The right of access – you can ask to access your information at any time.
3. The right to rectification – if we hold incorrect information, you can ask us to rectify this.
4. The right to erasure – covered in Access to information below – you have the right to ask us to erase your personal data, although under certain circumstances this can be rejected.
5. The right to restrict processing – you can ask to ‘block’ or suppress processing of personal data
6. The right to data portability – this allows individuals to obtain and reuse their personal data for their own purposes across different services.
7. The right to object – to for example email marketing. We have an opt in policy on email marketing so you will only be contacted via this method if you have given us explicit consent.
8. Rights in relation to automated decision making and profiling. For more information on this point, see ICO Website – Automated Decision Making
If you have any more queries on your individual rights under the Data Protection Bill or GDPR, please see the ICO Website – Individuals Rights
Individuals also have the right to withdraw consent at any time, where relevant.
Access to information
Seagull Training Services always ensure we are as open as possible when it comes to providing people access to their personal information. If you would like to know what personal information we hold about you, you can make a ‘subject access request’ under the relevant Act.
If we hold any of your person information, we will;
• Give you a description of the information,
• Tell you why we are holding the information,
• Tell you who it could be disclosed to,
• Let you have a copy of the information in an intelligible form.
If you would like to request any of your personal information held by Seagull Training Services, you must put the request in writing, addressing it to the current owner, currently Ian Robertson.
If you agree, we will try to deal with your request informally, for example providing such information over the telephone.
If we hold any of your personal information, you can ask us to correct any mistakes by contacting Ian Robertson in writing.
The right to be forgotten – this is something we take very seriously, as with every other access request, however there are limited circumstances where, due to our legal obligations, we will not be able to totally “forget” you. The ICO outline the reasons when a request for erasure can be refused – and states erasure can be refused “to comply with a legal obligation for the performance of a public interest task or exercise of official authority.”
Third Party Processors
Administrate – Seagull Training Services hold all candidate information (Name, Date of Birth, Personal Address, Email Address, Telephone Number, Individuals Picture)
ITSSAR – We use the TOPS Registration Scheme to register personal information (Name, Date of Birth and National Insurance number where relevant) with ITSSAR, who provide us with a unique identifier for each individual.
RTITB – We may use the NORS database to register personal information (Name, Date of Birth, Personal Address and National Insurance number where relevant) with RTITB, who provide us with a unique identifier for each individual.
Complaints or queries
Seagull Training Services strive to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously.
If you are aware of any breaches in the collection or use of information – which is deemed unfair, misleading or inappropriate, we urge you to let us know at the earliest possible time. We would also welcome any suggestions for improving our procedures.
If you want to make a complaint about the way we have processed your personal information, you can contact us via firstname.lastname@example.org.
Links to other websites
Write to us: Seagull Training Services, Teasel Barn, Stibb, BUDE, CORNWALL, EX23 9HP
UPDATED 20/05/2018 to Comply with General Data Protection Regulation (GDPR)