Privacy Policy

 

1. Introduction

This website is operated by the Federation for Industry Sector Skills & Standards (“we”, “us” and “our” below).

 

Welcome to the Federation for Industry Sector Skills & Standards Limited privacy policy.

 

The Federation for Industry Sector Skills and Standards represents, promotes and supports the 21 Sector Skills Councils (SSCs) across the UK. Our members are groups of employers who have chosen to collaborate on skills in their sectors. Although our members are businesses, not individuals, we do collect and use personal information relating to individuals as part of our activities. This is primarily in order to manage our membership and to help us support and promote workplace skills generally throughout the UK.

 

We are committed to a policy of protecting the rights and privacy of individuals, in accordance with the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (“the Data Protection Legislation”). This statement sets out our privacy policy and explains what we do with the personal information that we collect from our members or any users of our websites.  Please read the following to understand our views and practices regarding personal information.

 

This privacy policy will inform you how the Federation collects and looks after your personal data, about your privacy rights and how the law protects you when:

 

      • you visit any website operated by the Federation, including any sites operated for the apprenticeship certification scheme in England, Wales and Scotland (the “Websites”);
      • you us any of our online services which are available through the Websites; or
      • you join the Federation as a member.

This privacy policy and the Websites are not intended for children, and we do not knowingly collect data relating to children.

 

Third party sites/applications:

 

This policy applies only to our own Websites and services. Our Websites and services may include links to third-party websites, plug-ins or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. We encourage you to read the relevant privacy statements or make enquires about said statements for any third party website you visit, or service you use.

 

Contact details: 

 

We have appointed a data protection lead who is responsible for overseeing questions in relation to our data protection practices and this privacy policy.  If you have any questions or concerns regarding this policy, you should contact us using the details directly below.

Federation for Industry Sector Skills & Standards (UK Company Number SC175918)

14 – 18 Hill Street

Edinburgh

EH2 3JZ

info@fisss.org

 

Changes to the privacy policy:

 

We keep our privacy policy under regular review. This policy was last updated March 2023. Historic versions can be obtained by contacting us at the address above. We reserve the right to modify or amend this privacy policy at any time and for any reason. The most recent version of our privacy policy will be made available through a link on each of the Websites .  If there are substantial changes to the policy, we will notify any affected data subjects by email (if provided).

 

2. The data we collect about you

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  We may check the details you provide with fraud prevention agencies and share information with them if we suspect fraud. It is important that you don’t provide false or inaccurate information or impersonate another individual.

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes first name, last name, username or similar identifier
  • Contact Data includes billing address, work addresses, work email addresses, and telephone numbers.
  • Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Websites.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, the company/organisation you work for and your current job within the company/organisation.
  • Usage Data includes information about how you use our Websites, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

We do not act as a data controller process any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

3. How we collect your data

 

We may collect your personal data through direct interactions with you in a number of different ways. These include;

 

  • When you interact with us directly, for instance by contacting, making an enquiry, or registering and maintaining the details of a members account.
  • When you access or use our Websites, or use any of our services.
  • Where you request marketing, such as a newsletter or updates on our events.
  • If you ask us a question or provide us with some feedback.

 

We will also get automated information from you as  you interact with our Websites, and certain data, such as Technical Data about your equipment, browsing actions and patterns will be automatically collected.  We collect this personal data by using cookies and other similar technologies, as set out in the Cookies section below.

 

We will receive personal data about you from various third parties and public sources as set out below:

 

  • Technical Data from analytics providers (such as Google) or other search information providers;
  • Identity and Contact Data from publicly available sources, such as Companies House based in the UK.

 

Federation as a processor

 

Where we act as a data processor for apprenticeship providers, we also receive some personal information direct from the relevant provider through our Websites.  Any processing that we do in this role is covered by a data processing schedule setting out or obligations under Data Protection Legislation.  There may, on occasion, be special category data provided and we will always ensure there are adequate technical and organisational measures in place to protect the integrity and confidentiality of this data.

 

4. Use of your information

 

Generally we only process and retain data for the above purposes in cases where (a) you have given us your consent to do so, (b) where it is necessary in order for us to fulfil our contractual obligations with you, (c) where it is necessary to facilitate our pursuit of a legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests, or (d) where we need to comply with a legal obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or for example, by opting out of our newsletters using the unsubscribe link at the bottom of the email.

 

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To administer the membership of your company/organization, confirm your identity, and keep our membership records up to date

(a) Identity

(b) Contact

Performance of a contract with you

To administer the products and services purchased by your company/organization, confirm your identity, and keep our customer records up to date

(a) Identity

(b) Contact

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our Websites, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Websites updated and relevant, to develop our business and to inform our marketing strategy)

Marketing / Promotional offers:

We may also use your personal information to inform you of news we think you would find interesting, or to send you promotional materials relating to any new features and offers relating to any of the products or services we provide through our Websites.

 

Third party marketing:

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting Out:

 

You can request that we, or third parties stop sending you promotional or other marketing material at any time. For our own marketing you can opt out of this service at any time using the ‘unsubscribe’ function.

 

Opting out of receiving such marketing material will not affect our collection of your personal data due to your usage of our Websites, products or services.

 

Cookies

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of the Websites may become inaccessible or not function properly.  For more information about the cookies we use, please see our relevant policy on each Website.

 

Change of purpose

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. Disclosure of data to third parties

 

We may share your personal information with third parties but only in the strictly limited circumstances set out below. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions.

 

  • In certain circumstances we may share your personal information with affiliated companies and service providers who perform functions on our behalf such as our internet service provider.
  • We may also supply your personal information to government bodies and law enforcement agencies but only: if we are required to do so by the requirements of any applicable law; if in our good faith judgment, such action is reasonably necessary to comply with legal process; to respond to any claims or actions; or to protect our rights or those of our customers and the public.
  • We may also share data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, or when we seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

6. Transmission of data overseas

We do not expect to transfer any personal data out with the UK or EEA.  If we did need to carry out an international transfer, we would take necessary steps to ensure a similar degree of protection is afforded to it and notify you prior to the transfer occurring.

 

7. Data security

We demonstrate our commitment to protecting your personal information by ensuring appropriate standards of technology and operational security are used to protect personal information; such as using a secure server and network firewall connection.  Operationally, access to personal information is restricted to authorised personnel who are under a duty to maintain the confidentiality and security of such information.

 

Should a data breach occur, we have procedures in place to investigate any such matter. You, and any applicable regulator will be notified, if necessary, of any relevant breach. A record of any breaches will be kept by the company.

 

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, or if there is a reasonable basis to believe there is a prospect of some form of dispute with you.

 

In general, and unless otherwise explained, we’ll hold your personal information based on the following criteria:

 

  • We will keep personal information held as part of our membership records for the duration of that organisation’s membership. At the end of the membership, we will delete the majority of records and only retain the minimum information necessary to deal with any future issues; and/or
  • Retention periods in line with legal and regulatory requirements or guidance

In some circumstances we will anonymise your personal data so that it can longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

Please contact us if you need any further details on our data retention practices.

 

9. Your legal rights

 

You can exercise your rights by contacting us using the contact details set out in the “Introduction” section above.

 

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.

 

You have a number of legal rights in relation to the information that we hold about you, including:

 

  • Right to access: You have the right to request access to your personal data held by us, which enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Right to rectification: You have the right to have personal data rectified if inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us. Requests are to be made in writing and will be handled within one month of receipt of the request.
  • Right to erasure: You have the right to request the deletion or removal of personal data in the following circumstances:
  • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • When you withdraw consent, and the data was originally collected based on said consent.
  • When you object to the processing and there is no overriding legitimate interest for continuing the processing.
  • The personal data was unlawfully processed.
  • The personal data has to be erased in order to comply with a legal obligation.

 

This does not provide an absolute “Right to be forgotten”. Where the personal data in question has been disclosed to a third party, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so. Personal data will be erased from our internal and cloud servers. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you withdraw your consent, we may not be able to provide certain products or services to you, but we will advise you if this is the case at the time you withdraw your consent.

 

  • Right to restrict processing: You have a right to ‘block’ or suppress processing of personal data if you contest its accuracy; have objected to the processing; processing is unlawful and you oppose erasure; we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
  • Right to object: You have the right to object to processing where we are relying on legitimate interests or those of a third party and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

You also have the right to make a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk if you think that any of your rights have been infringed by us. However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

 

In order to comply with your requests, we may need to collect further information from you to confirm your identity, ensure you can exercise your rights in a secure manner, and prevent the disclosure of your data to persons without a right to receive it.

 

Many of the rights listed above are limited to certain defined circumstances and we may not always be able to comply with your request.  We will tell you if this is the case.