Herts for Learning’s CPD Hub is an online CPD resource, managed by Herts for Learning and hosted by WebBased Ltd.
For the purposes of data protection laws, the Company is the controller of personal data collected by us on the Herts for Learning CPD Hub.
This document sets out the types of Personal Data (meaning information about an individual from which that individual can be personally identified) we handle, the purposes of handling those Personal Data and any recipients of it.
For the purposes of data protection laws the Company is the data controller.
We are: Herts for Learning Limited
Address: Robertson House, Six Hills Way, Stevenage, SG1 2FQ
Information Commissioner's Office Registration Number: ZA154308
Our Data Protection Officer is: Lynette Dexter, Company Secretary
Email address for the Data Protection Officer: email@example.com. Why we collect Personal Data
We collect and hold personal information relating to our users/customers, and in relation to any individuals included in data sets that are being processed by the Company under contractual agreements.
We may share Personal Data with other agencies, but only as necessary under our legal duties or otherwise in accordance with our duties/obligations as a Company.
The Personal Data we collect from the Herts for Learning CPD Hub is provided to us on a voluntary basis when users register on this platform.
Set out below are the reasons we collect and process Personal Data, as well as the legal basis on which we carry out this processing:
3. Legal basis for processing Personal Data
- to deliver a CPD service to you
- to manage user accounts / establishment accounts
- to manage course enrolments and event bookings
- to manage course alerts
- to manage our relationship with you
We will only process your Personal Data information where we have consent or we have another lawful reason for using it. These reasons include where we:
4. Categories of Personal Data we collect about you
- need to pursue our legitimate interests
- need to process the information to carry out a contractual agreement we have with you
As a user of the Herts for Learning’s CPD Hub, we may collect the following Personal Data about you (please note this list does not include every type of Personal Data and may be updated from time to time):
i) your name;
ii) your telephone / mobile number;
iii) your email address;
iv) your home address for individual users / work address for users joined to an Establishment.
This information will be collected from you at the time that you register on the Herts for Learning CPD Hub. Contact information is used to respond to enquiries or get in touch with you when necessary.
Any Personal Data collected by us will be treated as confidential under the principles of the relevant data protection law.5. Who will have access to your Personal Data
Personal Data will be accessible by:
- members of Herts for Learning Events team staff
- Establishment Account Administrators, who can access all user accounts for their Establishment
- WebBased, the hosts of the Herts for Learning CPD Hub
We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will not share personal information with third parties without consent unless we are required to do so by law or our policies. We will disclose Personal Data to third parties:
- if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation
- in order to enforce any agreements with you
- in order to perform contracts whereby we have been commissioned to deliver events on behalf of a third party (i.e. a school, setting or Local Authority)
- in order to perform contracts with third parties including:
- Webinar Platforms (e.g. Livestorm or Accelevents)
- External trainers and keynote speakers, for the events that you are attending as a delegate
- Hotels where overnight accommodation is required for the event
- to protect the rights, property or safety of the Company
This may include sharing data with the Police and other organisations where necessary.
The above listed third party suppliers will process data on our behalf. Therefore, we audit these third party suppliers to ensure their compliance with relevant data protection laws and specify their obligations in written contracts.6. How Personal Data will be processed
Personal Data may be processed in a variety of ways; this will include but is not limited to:
- maintaining electronic records
- event administration documents (e.g. delegate attendance lists, evaluations, etc.)
- sending of emails relating to event booking or course enrolment
- general account administration
- invoicing purposes
We also use this information for the marketing our training and events, where the necessary consent has been given.7. Cookies
8. Links to other websites
You may encounter a link to an external website page whilst visiting the Herts for Learning CPD Hub. If the link is to a website that is operated by a third party you should know that we have no control over that website, or its content, and as such cannot be responsible for the protection and privacy of your data or information you provide whilst visiting the site. You are advised to check the privacy policies of those other sites for their terms and conditions.9. Where we store Personal Data and how we keep Personal Data secure
Your Personal Data is stored on systems based in the United Kingdom and all data backups are fully encrypted.
Herts for Learning’s CPD Hub has security measures in place to protect the loss, misuse and alteration of the information under our control. All instances of unauthorised attempted access to Herts for Learning’s CPD Hub are logged and investigated. Where necessary, Herts for Learning’s will inform law enforcement agencies or other relevant organisations regarding misconduct.10. Retention periods
We will only retain Personal Data for as long as is considered necessary to achieve the purposes for which it was originally collected.
Personal Data is retained on the Herts for Learning CPD Hub until the user account is closed by the individual or an establishment.
Once the user account is closed all associated Personal Data is anonymised by WebBased, in order that it does not affect any historical training statistics. 11. Your Data rights
The General Data Protection Regulation and associated data protection law gives you rights in relation to Personal Data held about you. These are:
- Right to be informed: you have the right to be informed about the collection and use of your data. This policy contains information in relation to the collection of your Personal Data, however, if we collect additional data for other purposes, we will inform you about this.
- Right of Access: if your Personal Data is held by us, you are entitled to access your Personal Data (unless an exception applies) by submitting a written request. We will aim to respond to that request within one month. If responding to your request will take longer than a month, or we consider that an exception applies, then we will let you know. You are entitled to access the Personal Data described in Section 4.
- Right of Rectification: you have the right to require us to rectify any inaccurate Personal Data we hold about you. You also have the right to have incomplete Personal Data we hold about you completed. If you have any concerns about the accuracy of Personal Data that we hold then please contact us.
- Right to Restriction: you have the right to restrict the manner in which we can process Personal Data where:
- the accuracy of the Personal Data is being contested by you;
- the processing of your Personal Data is unlawful, but you do not want the relevant Personal Data to be erased; or
- we no longer need to process your Personal Data for the agreed purposes, but you want to preserve your Personal Data for the establishment, exercise or defence of legal claims.
Where any exercise by you of your right to restriction determines that our processing of particular Personal Data are to be restricted, we will then only process the relevant Personal Data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
- Right to Erasure: you have the right to require we erase your Personal Data which we are processing where one of the following grounds applies:
- the processing is no longer necessary in relation to the purposes for which your Personal Data were collected or otherwise processed;
- our processing of your Personal Data is based on your consent, you have subsequently withdrawn that consent and there is no other legal ground we can use to process your Personal Data;
- the Personal Data have been unlawfully processed; and
- the erasure is required for compliance with a law to which we are subject.
- Right to Data Portability: you have the right to receive your Personal Data in a format that can be transferred. We will normally supply Personal Data in the form of e-mails or other mainstream software files. If you want to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format, please contact us via the details in this Notice.
- Right to Object: you have the right to object to the processing of your Personal Data where one of the following grounds apply:
- the processing is based on legitimate interests or the performance of a task in the public interest;
- the processing is for direct marketing; or
- the processing is for the purposes of scientific/ historical research and statistics.
You can find out more about the way these rights work from the Information Commissioner's Office (ICO) website.12. Controlling your personal information
If at any time you wish to close your Herts for Learning CPD Hub account and/or stop receiving information/course alerts from us, you can:
13. Subject access request (requesting your Personal Data)
- send an email to firstname.lastname@example.org identifying yourself and asking that we close your account
- you can turn off course alerts from your own user account
You are entitled request details of Personal Data that we hold about you and you can access that Personal Data by making a Subject Access Request (SAR).
A SAR is a written or verbal request for personal information (known as personal data) held about you by an organisation. Data protection legislation gives individuals the right to know what information is held about them. However, this right is subject to certain exemptions as set out in the Data Protection Act 2018.
To submit a SAR to HfL we recommend that you email a written request to our Data
Protection Officer at email@example.com. To help us respond quickly and effectively to your request, please include information regarding your relationship with us, along with a comprehensive list of what personal data you want to access and any details, relevant dates, or search criteria that will help us identify the information that you want.14. Making a complaint
If you are unhappy with the way we have dealt with any of your data protection concerns, you can make a complaint to the Information Commissioners Office (ICO), the supervisory authority for data protection issues in England and Wales. We would recommend that you complain to us in the first instance, but if you wish to contact the ICO you can do so using the details below. The ICO is a wholly independent regulator established in order to enforce data protection law.
ICO Concerns website: www.ico.org.uk/concerns
ICO Helpline: 0303 123 1113
ICO Postal Address:
Information Commissioner's Office
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