New Trades Career, a trading entity of Green 360 Limited company registered in England under number 9374595 and whose registered office is at 6th Floor, City Gate East, Tollhouse Hill, Nottingham, England, NG1 5FS (NTC) takes personal data privacy seriously and is committed to safeguarding and preserving that of our visitors/customers. The protection of personal data is important to us and we understand our responsibilities regarding handling your personal data with care, keeping it secure and complying with legal requirements.
NTC is registered with the Information Commissioner’s Office under registration number ZA177539 and the information you provide is safeguarded under the UK’s Data Protection legislation. To find out more information about the UK’s Data Protection legislation, please visit ico.gov.uk/.
This policy sets out how we process the personal data, describing how we do so fairly and without any adverse effects on the rights of data subjects.
NTC is a trades training specialist based in the UK providing home-based learning courses in the trades sector, serving the Construction Industry. Our courses are structured and designed with our trading partners to combine home-based learning, practical training in local centres and if required, on-site experience.
NTC acts as a Data Controller when processing personal data and information for data subjects (yourself) we have dealings with. If you have any questions about how your data is used please contact us, details can be found at the bottom of this Privacy Policy.
The privacy of our visitors and individuals/customers will always be respected in line with the organisation’s privacy principles.
All personal data and information we process, store or transfer in relation to you as a data subject is adequately protected against unauthorised access, transmission, changes or erasure. The confidentiality and security of your personal data is protected. The integrity of your personal data is preserved.
Information relating to you as a data subject is handled in a manner consistent with our privacy by default and design principles and respects your rights (the rights of the data subjects) at all times.
The processing of your personal data is lawful, based on your consent, written contract or our legitimate business interests. It adheres to all obligations of data processors in accordance with GDPR requirements and the rights of the data subjects thereunder.
We are aware and take into account the state of the art, nature, scope, context and purposes of processing together with the risk, likelihood and severity for the rights and freedoms of natural persons to implement appropriate technical and organisational measures to ensure a level of security that is appropriate to the risk.
We classify all personal data processed as strictly confidential and any person who has access to personal data is fully trained and aware of data privacy requirements and does not process personal data except on written instructions.
We take the ‘Data Protection by Design and by Default’ approach to data privacy and the processing of personal data. These principles of data protection are taken into account and considered when developing, designing, selecting and using applications, services and products that are based on the processing of personal data. Data protection is the first principle that is taken into account when personal data are being processed and when technical and organisational measures are being designed or developed.
The purpose and objective of our Data Privacy policies is to minimize and limit impact of data breaches and that Data Subjects (yourself) can have confidence in the robust and comprehensive governance processes which are implemented in relation to privacy of your personal data and its processing.
This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you whilst you visit our site.
We do update this Policy from time to time so please do review it regularly.
- Information We Collect
In running and maintaining our website we may collect and process the following data about you:
- Information about your use of our website including details of your visits such as pages viewed and the resources that you access, standard information collected by web server such information includes traffic data, location data, IP addresses, and other communication data.
- Information provided voluntarily by you. For example, when you register for information or make a purchase.
- Information that you provide when you communicate with us by any means including for example queries, complaints etc.
- Use of Cookies
When you visit our website you are informed that we use technologies to collect and store information using cookies which are saved on your device. Cookies are very small text files stored on your computer, smartphone or any other device when you visit a website. We would like to point out that cookies cannot harm your computer and we do no use them to track your use of internet after you visited our website, nor do we store information in cookies that could identify you to others.
Cookies do not collect your personal data, however without these files; website may not be fully functional. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website and its performance.
You can adjust the settings on your computer to decline, restrict or delete any cookies if you wish. This can easily be done if you activate the reject cookies setting on your computer, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how to do so depending on the browser. You can also use the browser’s anonymous browser setting (‘Incognito’ if using Google Chrome, ‘InPrivate’ in Internet Explorer and ‘Private Browsing’ if you are using Firefox).
If you decide not to accept the cookies, we would not use them for your visit on our website but may record that you have not given your consent to their use.
If you would like to know more about cookies and how you can disable them, please go to http://www.aboutcookies.org.uk/managing-cookies, which provides information on cookies on a wide variety of browsers.
There are two types of cookies on our website:
1st party cookies – cookies set by us, these cookies are placed on your computer by our website when you visit our pages. They help us recognise you as a visitor. They are used for better performance, functionality and security of our pages.
We use ‘session’ cookies to remember your choices and preferences; these usually expire when you close your browser.
We also use a limited number of ‘persistent’ cookies (for example cookies consent agreement), which are stored on your computer until you delete them, or until they expire (usually within a short period of time up to 2 years).
Cookies set by 3rd party – these are cookies placed on your computer by other companies; in general not the company whose site you are visiting. Third party cookies collect and pass anonymous information.
Our site uses Google Analytics (GA), which is a web analytics service provided by Google, Inc. GA The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with the website. To find out more please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google will use the information generated by the cookie (how you use the website including your IP address) to evaluate your use of the website, to compile reports regarding activity on the website and to provide services that relate to website activity and usage of internet. They store this information on their US servers. As with any company Google may transfer this information to third parties where they required to do so by law, or where these third parties process information of their behalf. By using this website you consent to Goole’s processing of your data as set out above. To permanently opt-out of Google Analytics for the web visit the https://tools.google.com/dlpage/gaoptout
Social media cookies
Our website does not include social media features widgets at the moment but might do in the future. These social networks may set a cookie(s) on your computer or any other device when you click on them. We do not control the cookies set by them as these social media features are either hosted by a third party or hosted directly on the Websites. We would encourage you to check the privacy policy statement of the relevant social networks before you interact with them (click on them) to ensure you agree with their functionality and how they use/process your data.
You are able to refuse the use of these third party cookies by changing the appropriate settings on your browser. Please note if you do so you may not be able to use certain features of a website.
- Use of Your Information
We use the information that we collect from you, or you provide to us, or is provided to us by third party, to provide our services and to:
- provide information to you that you request from us relating to our products or services.
- inform you of any changes to our website, services or goods and products.
- respond to any queries, complaints or requests for further information.
- carry out administration and operation of our business and keep an internal record of the communication we had with you (including notes, monitoring for quality controls etc.).
- provide services such as course materials and to support your learning.
We may collect and process data you have provided to us via filling out the online form and any other data and information you provide to us after your request for information, when you enroll on a course with us, when you communicate with us by any means as described below or/and if you visit our website, interface with our online campus (online campus facility is relevant to persons who enrolled on a course and use it to progress through their course; your account is password protected), or you communicate with our tutors and staff.
We may collect and process data you have provided to a third party (for example to a training portal or a third party website you requested to find out more about training courses from), where we would process the data on basis of those third parties having obtained valid consent from you to pass on your data to be processed in order to provide you with relevant course information.
Retention
We will process your personal data only for as long as it is necessary for the purpose for which it was originally collected and for the purposes that it is being used. It will always be stored securely.
3.1 Legal Basis on which we use your information
We would use your personal information only in a way that is lawful. We would normally use it because you consented we may do so (i.e. request for information), we may need to use your information so we can enter into a contract with you, to comply with law or for our legitimate business needs.
3.2 Personal Information when you register or request for information online or offline
We collect your personal data such as your Full Name and Contact Details (Name, Surname, home or business address, Phone numbers, Postcode, Email) when you fill out the Contacts form on our website directly. We collect it and use it based on your consent for us to process your personal data in order to contact you in reply to your enquiry or request. We (or an agent working on our behalf) will contact you by telephone call to provide you with more information about our distance learning trades training courses you are interested in. We will use personal details you provided to contact you according to your preferences (initial request for information).
We may process your personal data for marketing purposes (contacting you to provide information on our trades training courses in response to your request) for as long as we have a valid consent from you, no longer than it is necessary for the purpose it was collected for and is being used for, and for legitimate business interests (such as defending a legal claim). For example if we cannot make a contact with you we will delete your data after 6 months.
You can change your preferences and are free to do so at any time; you can withdraw your consent (to be contacted with more information about distance learning trades training courses) by sending us an email dataprivacy@green360careers.co.uk, or you can write to us at the address at the bottom of this Privacy Policy. Please note this does not affect the lawfulness of the processing, based on consent, before its withdrawal or the lawfulness of processing which may be carried out on an alternative lawful basis to consent.
3.3 Personal information when you make a purchase
We collect and process your personal data when you make a purchase. Your full name, address, email, postcode, date of birth, contact details, employment details, card details and/or identification details and other information you provide to us directly (based on interview with our Advisor), and after when you communicate with us by any means, shall be used and processed in order to assist us in supporting the client relationship you have with us and to verify your identity for this purpose, which is based on a written contract between yourself and us, or if we need to make a contact with you in respect to your contract with us.
Please be aware that the collection of your personal data is necessary for us to enter into any subsequent contract with you if it is your wish to pursue a training course to further your career.
In order to provide our services to you we use information to facilitate your training and to answer any queries regarding your course, also if we respond to a complaint or deliver our services to you (offline and online), to support your learning and in order to provide you with study materials and send reminders. We will use your information to provide our services as necessary for the performance of the contract between you and us (through our online Student’s campus website) and answer any queries via telephone, email or our online facility where you can ask questions, submit your assignments or contact your tutor.
We process your personal information only for as long as it is necessary for the duration and performance of a contract you have with us if that processing of personal data is based on a contract for providing distance learning courses in the trades industry.
Some personal information you provide to us and those details relating to your contract with us may be retained securely for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons. We will generally retain your personal information only as long as it is required for purposes for which it was collected. This will usually be the period for which we provide our service to you and plus the length of any applicable statutory limitation period after that time (usually 6 years from the end of the agreement).
We may use your email address to send you news and relevant information about the trades industry that may be relevant and beneficial to your qualification, however, you can opt out to receiving such emails at any time using the opt-out link within these emails or by sending us a request to dataprivacy@green360careers.co.uk, or writing to us at the address at the bottom of this Privacy Policy. Legal basis for this processing is our legitimate interest to deliver you news about trades industry that will help you with your studies, provided that it respects your privacy rights.
3.4 Information when you use the website
We may record information such as your geographical location, what type of internet service provider you use, your IP, or type of software you use or what pages you accessed etc.
We may process data that you provide to us this way in order to improve our website effectiveness, ensure the security of the website, to communicate with you (only when you fill in the online form or email us, in which case we collect information provided in that communication) or for back-ups. The legal basis for using and for processing your data is your consent (banner that comes up when you visit our Website notifying you of our use of cookies, please see section 2. Use of Cookies), and for our legitimate business interests such as maintaining our website.
3.5 Use of information for legitimate and legal interests
We may use and process any of your data as identified in this policy as necessary for establishing, exercising or defending legal claims and to manage risks in order to protect our business, or to support legitimate interests to you or those we as a business have (such as communication, maintaining the website and services we offer, improve effectiveness of our service and to identify technical issues with the service we provide to you), provided that it respects your privacy rights.
We may use and process any of your data as identified in this policy to comply with legal obligations we as a business are subject to.
4.Storing Your Personal Data and International Transfer
In operating our website we do not transfer data that we collect from you to locations outside of the EU. The personal data we collect from you is stored on servers which are in the European Economic Area (EEA). We do our utmost to ensure that all reasonable steps are taken to make sure that your data is treated and stored securely, and that all appropriate safeguards apply at all times.
We can neither warrant nor guarantee that the data you choose to send to us electronically is absolutely secure and as such it remains at your own risk. However, to protect your data, the data submission on our website uses ‘https’ technology and standard SSL encryption for additional security. Access to your personal data and information is password protected.
Should we engage services of companies operating in countries outside of the EAA and where the Commission has not decided that third country ensures an adequate level of protection and whose laws provide for a different standard of protection for your personal data than that provided under English law, we shall in such circumstance have in place either contractual arrangements, binding corporate rules, approved code of conduct or certification mechanism (such as EU-US privacy shield) to ensure safety of your data which will require your data to be processed to a standard compliant with the GDPR requirements.
Where none of the above applies we would ask you for your explicit consent to the proposed transfer unless it is necessary for the performance of a contract between you and us subject to adequate security safeguards.
5.Disclosing Your Information
We will not disclose your personal information to any other third party other than in accordance with this Privacy Policy and in the circumstances detailed below:
1. In the event that we sell any or all of our business to a buyer.
2. Your information may be passed to and used by all Green 360 Ltd companies and any successors in title to our business.
3. Where we are legally required by law to disclose your personal information; in order to comply with any legal or regulatory obligation that we are subject to, or where we have a legitimate interest in doing so.
4. We may share necessary data such as your full name, address and contact details with a carefully selected and trusted third party supplier company that a; provides Practical training on our behalf but only to fulfil the substantial part of the contractual study program that is practical training; b; or anyone within the EU who under our direct authority is authorised to process personal data by any means (including email communication).c; we may provide your email address to a third party data processor who provides us with technical solutions for sending emails to you d; we may provide your mobile number to a third party data processor who provides us with technical solutions for sending SMS messages to you
5. We may use personal information you provide to us for carrying out our obligations under any contract you have with us. For example, if we process your details with an awarding body, necessary for your qualification and certification.
Our Practical Training partners may contact you prior to your attendance with any necessary information you will need for the Practical training. We shall only supply such personal data to them that is necessary for them to provide the relevant service to you. The privacy of your data shall be respected and protected at all times when we work with them.
6. To further fraud protection and reduce the risk of fraud.
Your personal data will be held securely for the duration of the contract and for as long as we are obliged to by law.
Your Personal data will never be shared with any third parties for marketing purposes.
6.Updating your personal information
We endeavour to ensure that your personal information is kept as accurate as possible. Therefore if any personal information has changed or if you wish to update us with the changes to your personal information, please contact us as soon as possible either via email dataprivacy@green360careers.co.uk or in writing at the address at the bottom of this privacy policy.
7.Your Data Subject’s rights
Under data protection regulation you can exercise your data subject rights as listed below. We are obliged to respond to your request within 1 month of the receipt of the request and to do so free of charge. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We would inform you of any such extensions within 1 month of receipt of the request along with the reasons for the delay.
We shall provide information and detail the action taken on request, free of charge, in most cases; however, we reserve the right to charge a reasonable administrative fee if the request(s) is/are manifestly unfounded, excessive or repetitive.
Consequently, you have a number of rights that you can enforce against us as your Data Controller, but note that not all of these rights are always applicable in all circumstances or in full. We shall not be obliged to respond partly or in full to any request if we are unable to satisfactorily identify you as a data subject or if there are any other legal or legitimate interests for us to do so. We will always write to you to explain our reasons for doing so.
– Right of access – the right to be informed – you have the right to obtain from us confirmation to whether or not personal data concerning you are being processed by us, and where that is the case, access to the personal data (commonly known as Subject Access Request).
You may also ask to obtain confirmation from us regarding information clarifying the purpose for processing and the categories of personal data concerned, also the recipients to whom the personal data have been or will be disclosed; retention period for processing personal data or criteria that we use to determine that period; information about your rights in regards to the personal data processing or where the personal data were not collected directly from you as a data subject, provide information as to the source of your data.
Subject access request for information we hold about you must be in writing. Please mark your correspondence as ‘Subject Access Request’. You can write to us directly: Green 360 Limited, PO Box 10651, Nottingham NG1 9LN, or email us on dataprivacy@green360careers.co.uk.
– Right to rectification – you have the right to obtain from us rectification of inaccurate personal data concerning you; correct inaccurate data and to complete incomplete data.
– Right to erasure – known also as the ‘right to be forgotten’ – you have the right to withdraw your consent of the processing of personal data concerning you and we will erase your personal information upon your request unless we have other legal grounds for the processing; if processing is being made in the public interest or processing is necessary for the purposes of the legitimate interests pursued by us, you have the right to have your personal information deleted by us unless there are no overriding legitimate or legal grounds for the processing; you have the right to have personal information concerning you deleted when they are no longer necessary for the purpose for which they were collected, or the purpose no longer exists or if the processing was unlawful.
– Right to restrict processing – if processing your data is based on that being in the public interest or processing it is necessary for the purposes of the legitimate interests pursued by us, you still have the right to restrict the processing of your personal information unless there are overriding legitimate or legal grounds from our side.
You also have the right to restrict the processing of your personal information if our processing is unlawful or if we do not need to process your personal information any longer but you need to keep personal information in order to exercise or defend legal claims or, if your personal data are not correct and you contest the accuracy of the personal information until we have taken sufficient steps to correct or verify its accuracy. If the processing of your personal information is restricted we would then not further process your personal information unless we obtain your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.
– Right to data portability – (to move, copy and transfer certain personal data) if the processing of your personal data is based on your consent or based on an contract and its processing is carried out by automated means you have the right to receive personal data concerning you or personal data that you have provided to us in structured, commonly used and machine readable format, and to require us to transmit it to another controller where it is technically feasible.
– Right to object – if the processing of your data is made based on public interest or processing is necessary for the purposes of the legitimate interests pursued by us, you have the right to object against the processing of your personal information unless there are overriding legitimate or legal grounds for the processing from our side. If your personal data are processed for direct marketing purposes you have the right to object to such processing and we shall no longer process your personal data for such purposes.
– Right not to be subject to automatic decision making – we can confirm that Green 360 Limited as a data controller does not practise automated individual decision making or profiling of your personal data, prior or during the performance of a contract.
– You as a data subject have the right to lodge a complaint with the data protection supervisory authority which is the Information Commissioner Office ‘ICO’ if you are not satisfied with the processing of your personal information by us or are unhappy with our response to your request. For more information please visit ico.gov.uk/ or contact them by calling 0303 123 1113.
– Right to withdraw consent – if the processing of personal data concerning you is being done with your consent, you have the right to withdraw that consent at any time by sending us a request on dataprivacy@green360careers.co.uk or you can write to us on address below.
8.Updates to Policy
We may update this policy from time to time. We recommend you check this page regularly to be aware of any changes, and ensure you are happy with any published changes to this Policy.
9.Contacting Us
Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at dataprivacy@green360careers.co.uk or in writing at:
Green 360 Limited
PO Box 10651
Nottingham
NG1 9LN
Version 2.2, effective from 2nd October 2018