This policy applies with effect from 25 May 2018.
We, at the EW Group, value your privacy and security and are committed to keeping your data safe in line with our legal obligations under the Data Protection Act 2018 and General Data Protection Regulation (GDPR).
The GDPR sets out a number of different legal bases upon which we may collect and process your personal data, including (among others):
Consent – in specific situations we can collect and process your data with your consent, for example, when you opt into receiving our newsletters or when you provide us with a testimonial for use on our website.
Contractual – in certain circumstances, we need your personal data in order to enter into contracts with you and to comply with our obligations under the contract.
Legal Compliance – if the law requires us to, we may need to collect and process your data, for example, we can pass on details of people involved in criminal activity affecting the EW Group.
Legitimate interest – we may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business which does not materially impact your rights, freedoms or interests.
Your personal data is held by the EW Group in accordance with one of the legitimate legal bases set out above, depending upon the nature of your relationship with us.
1. Who controls your information?
2. What sort of personal data do we collect?
The type of personal data we collect depends on the nature of our relationship.
2.1 If we have entered into a contract with you (or pre-contact discussion) we collect your name, email address, telephone number, job title or role as well as the name and address of your organisation/employer.
2.2 For sales and marketing purposes we collect your name, email address and telephone number (if voluntarily provided);
2.3 When you make an enquiry or register for one of our e-learning courses, we collect your name and email address; and
2.4 When you make an enquiry or register for one of our certified courses, e.g. ILM, we collect your name, age, email address, telephone number, date of birth, job title/role, personal address and, if applicable, the name of your employer and their address.
3. How is your personal data collected?
We collect your personal data in different ways, depending on your relationship with us.
3.1 During pre-contract discussions and/or when entering into a contract with us, we collect your personal data by electronic mail (email)
3.2 When you visit our website, your personal data is collected on our website enquiry form and processed on our behalf by Scoro, our customer relationship management provider. When you register for our newsletter, you do so by completing a form that is linked with Mailchimp, who manage the mailing list on behalf of the EW Group.
3.3 When you make enquiries about one of our e-learning courses, your personal data is collected via email.
3.4 When you register for one of our certified courses, your personal data is collected by way of a registration form completed and returned by you.
4. Why is your personal data collected?
4.1 your personal data is collected in order that we may have pre-contract discussions with you and/or to enter into a contract with you;
4.2 for sales and marketing purposes, e.g. to pursue potential client leads and/or to inform contacts about upcoming events organised by the EW Group;
4.3 in order to enrol you on our group e-learning programmes. These programmes are hosted on LMS and the third-party providers are Nimble. We also collect your personal data so that we can send you login details and reminders to complete your course.
4.4 in order to register you for candidate enrolment on one of our certified courses, e.g. ILM; to enter the course results and to issue your certificate. We also collect your personal data so that we can contact you as regards course arrangements.
5. How is your personal data used?
5.1 contracts: your personal data are stored on our database (Scoro) and used for the purpose of fulfilling our contractual obligations to you. The details of your organisation/employer are shown on the face of the contract and not your personal details.
We will not share your personal data with third parties other than as may be necessary for the effective performance of our contractual obligations.
5.2 sales and marketing: your personal data are stored on our database (Scoro) and may, from time to time, be used for sales and marketing purposes.
5.3 when you sign up for one of our e-learning courses, your personal data are entered in Nimble and you are added to our system as a ‘learner’. Your data are stored on the system to allow reminder emails to be sent, as appropriate;
5.4 when you complete and submit a registration form for our certified courses, e.g. ILM, your data is stored in Sharepoint and your details are entered onto a delegate management spreadsheet. Under our agreement with ILM we are obliged to pass your personal data, i.e. name, email and date of birth to ILM for enrolment purposes and to enable ILM to produce and send your certificate. We will not share your personal data other than for these purposes.
6. With whom will your personal data be shared?
6.1 any personal data disclosed for the purpose of entering into or the performance of a contract will not be shared with third parties other than upon the client’s request or otherwise as may be required for the effective performance of the contract, e.g. to EW Group’s staff and/or Consultant Partners.
6.2 personal data collected, stored and used by us for sales and marketing purposes will be shared with Scoro servers and Mailchimp servers for the purposes specified in the contracts (as amended) between the EW Group and Scoro and the EW Group and Mailchimp. They are bound by the same conditions of privacy and will not use or transmit your personal information for any other purposes.
6.3 personal data collected, stored and used by us in connection with e-learning courses will be shared with Nimble, our providers. They are bound by the same conditions of privacy and will not use or transmit your personal information for any other purposes.
6.4 personal data collected, stored and used by us in connection with our certified courses, i.e. ILM will be shared with ILM for the purposes specified above. They are bound by the same conditions of privacy and will not use or transmit your personal information for any other purposes.
7. How do we protect your data?
7.1 Online Privacy
When you are on www.theewgroup.com or other EW Group sites, and are asked for personal information, you are sharing that information with the EW Group alone unless otherwise stated. We use the information we collect about visitors to our website to help us understand more about how our site is used and to be able to send you appropriate communications.
Our website is hosted by Nimbus Hosting and information provided to us using the site may be logged and stored securely by them for the purposes of tracing any site errors. They are bound by the same conditions of privacy and will not use or transmit your personal information for any other purposes.
When you give EW Group personal information, we take steps to ensure that your information is treated securely, e.g. encryption, password protection, firewalls, etc. Unfortunately, it is not possible to guarantee the total security of any data transmitted over the Internet. While we strive to protect your personal information, EW Group cannot ensure or warrant the security of any information you transmit to us, and you therefore do this at your own risk. Once we receive your transmission, we use our best effort to ensure its security on our systems.
7.2 Sharing information
EW Group will not disclose any of your personally identifiable information, except when we have your permission to do so, or because you have asked us to do something before entering into a contract with you, e.g. provide a quote. Where we have already entered into a contract with you, we may need to share your information in order to fulfil our contractual obligations to you. We will also share information in special circumstances such as when we believe in good faith that the law requires it.
As stated above, EW Group may, from time to time, instruct third party providers to collect and store personal data on its behalf. Such suppliers or agents will be bound not to further transmit this information or use it in any other way than for the intended purpose. EW Group doesn’t use the information provided to our suppliers for any other purpose and we do not share your information with other third parties.
8. How long do we keep your personal data?
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal accounting or reporting requirements.
At the end of that retention period, your data will either be deleted or anonymised (so that it can no longer be associated with you) for research or statistical purposes.
When determining the appropriate retention period for personal data we consider the amount, nature and sensitivity of the data, the potential risk of harm (to you) from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, alongside the applicable legal requirements.
The EW Group periodically reviews all the personal data it holds to ensure that it is not collected or processed for longer than is necessary.
9. What are your rights over your personal data?
You have the right to request:
- access to the personal data we hold about you, free of charge in most cases;
- the correction of your personal data when incorrect, out of date or incomplete. The EW Group does not currently undertake direct marketing;
- that we stop any consent-based processing of your personal data after you have withdrawn that consent;
- in certain specified circumstances, that the personal data we hold about you be erased;
- that the data we hold about you be transferred to someone else, e.g. another service provider;
- that your personal data is not used in automated decision making (making a decision solely by automated means without any human involvement). The EW Group currently does not make use of automated decision making;
- in certain specified circumstances, to restrict or suppress the personal data we hold about you, e.g. permission to store but not use your personal data.
We have appointed a dedicated Group Data Protection Officer, Jon Sinclair, who can help you with any requests you have relating to items in this section. His contact details are included in section 10 below.
10. Contact details
You can contact the Group Data Protection Officer by:
Telephone: 0191 737 1011
Write to: FAO Jon Sinclair, Group Data Protection Officer, 9 Apollo Court, Koppers Way, Monkton Business Park South, Hebburn, South Tyneside, NE31 2ES
If you are dissatisfied with the way in which we have handled your data, you have the right to complain to the Group Data Protection Officer, or to complain to the privacy regulator – the Information Commissioner’s Office (ICO)
The ICO can be contacted using the following:
- by telephone on 0303 123 1113
- on their personal live chat channel at www.ico.org.uk/livechat
- by post to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF