This Privacy Notice details the Privacy & Cookies Policy for Active SCG Ltd.
2 OUR POLICY STATEMENT
2.1 At Active SCG Ltd we are committed to protecting your personal information and being transparent about what we do with it, no matter how you interact with us. Our commitment applies to all persons who want to or actually buy our goods or services, want information about our services, products and company, attend training, engage our consulting services, apply for a job or want to learn more about what we do.
(a) the Data Protection Act 1998, which will be replaced by the General Data Protection Regulation (EU) 2016/679 from 25 May 2018.
(b) the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2.3 Processing of your personal information is carried out by or on behalf of Active SCG Ltd, registered as a company in England and Wales (5205846).
2.4 This notice and our Cookies Policy tells you about how we collect, use and protect your personal information.
3 WHAT INFORMATION WE MIGHT COLLECT AND WHEN
3.1 When you engage with us by phone, email, mail, in person or online, we may collect information about you referred to in this Privacy Notice as 'personal information'.
3.2 The personal information we collect from you is limited to what is necessary to enable us to carry out the purposes for which it is collected. The type of personal information we collect depends on the context of your interactions with Active SCG Ltd, and the choices you make, including your privacy settings.
3.3 The data we may collect, store and use can include the following:
(a) Your name, surname, contact details (email address, postal address, telephone number), job title; when you submit an enquiry; when you book a safety audit, consulting service, course or training event; when you complete course registration forms; when you interact with us via social media platforms; when you apply for a job.
(b) Your passport or national ID details; qualifications and licences; when you request from us a letter or written statement which you specify must include your passport or national ID data; when you apply for a job.
(c) Information about your audit or course bookings; when you book a audit services; when you book on a course or training event.
(d) Information about your health or learning disabilities, which may require us to make any adjustments to our training events; when you provide us with this information before you commence any training; when you register for a training event.
(e) Information about other persons you may be booking a training event for; when you make a booking on behalf of other persons.
(f) Information about your transaction, including your payment card details; when you purchase any products or services using a payment card.
(g) Communications you exchange with us (for example, your emails, letters, calls); when you contact Active SCG Ltd or you are contacted by Active SCG Ltd;
(h) Your comments and feedback; when you reply to our requests for feedback; when you contact us with feedback or comments;
(i) Your posts and messages on social media directed to us; when you interact with us on social media platforms; and
4 SENSITIVE PERSONAL DATA
4.1 Data protection law recognises that certain types of personal information are more sensitive. This is known as 'sensitive' or 'special category' personal information.
4.2 Sensitive information will only be collected where necessary, so that we are able to comply with regulatory and legal requirements. Should we require sensitive personal data clear notices will be provided at the time we collect this, stating what information is needed, and the reasons why.
4.3 Where this information is necessary if you do not allow us to process any sensitive personal data, this may mean we are unable to provide all or parts of the services you have requested from us. Please be aware that in such circumstances you will not be entitled to cancel or obtain a refund of any price you have paid.
5 HOW AND WHY WE USE YOUR INFORMATION
5.1 We will use your personal information for the following purposes:
5.1.1 To manage your course/training event and provide services:
When you book to attend any of our course/training events, we use your information to perform our services in relation to the course/training event, for example to issue your course instructions, pre-course materials, certificates, and learning materials as applicable.
5.1.2 To communicate with you and maintain an effective service relationship:
For operational or administration purposes we may need to contact you via email or phone. This includes sending you confirmation of bookings and payments, sending you details related to your course/training event, notify you of any changes, etc. These communications are not made for marketing purposes, and you will continue to receive them even if you have opted out of receiving marketing related communications. We will also use your personal data if we contact you after you have sent us a request, filled in a web-form through our website or contacted us on social media. Your opinion is very important to us, so we may send you an email or SMS to seek your feedback or further information.
5.1.3 To personalise and improve your customer experience:
We may use your personal data in order to tailor our services to your needs and preferences and to provide you with a personalised product or service. We may also collect information on how you use our website, which pages of our website you visit most, which products and you search for, in order to understand what you like. We may use this information to tailor the content and offers that you see on our website and, if you have agreed to receiving marketing communications, to send you relevant messages that we think you like. If you are in the process of making a booking under your account and you leave our website before your order has been placed, we may contact you in order to help you easily complete your booking.
5.1.4 To issue you with a course certificate:
When you successfully complete a training course we will issue you with a Certificate of Attendance or equivalent which will state personal information as relevant to the training event.
5.1.5 To inform you about news and offers that you may like:
We may send you marketing communications for our products and services, if you have indicated that you are happy to receive these, for example subscribe to our newsletters or product mailing lists. If you are happy to receive marketing communications, we will provide you with news from us and also send you communications promoting our products and services. You can opt in to receiving information from us by ticking the relevant
You can choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us. You may also send an email to email@example.com with the header “Unsubscribe”.
5.1.6 To improve our services, fulfil our administrative purposes and protect our business interests:
The business purposes for which we will use your information include accounting, billing, credit or other payment card verification, fraud screening, and safety, security and legal purposes. We may also use your personal information to record and deal with a complaint, record a request not to receive further marking information, and for other essential internal record keeping purposes.
5.1.7 To comply with our legal and qualifications obligations:
For legal purses we may be required, according to the course/training event to use your information for compiling reports and records that are required of us by qualification awarding bodies or relevant Authorities. Where required and we are subject to a legal obligation, we may process your personal information to fulfil that obligation.
5.1.8 Responding to a request:
If you contact us with a query, we may use your personal information to provide you with a response. This applies if you contact us regarding us a job vacancy or any work opportunity.
6 REQUESTING ACCESS TO YOUR PERSONAL DATA
6.1 You have a right to request access to the personal data that we hold about you. This could include booking information relating to services you have purchased from us.
6.2 If you would like to request a copy of your personal data please refer to clause 11 of this policy.
6.3 If you have questions in relation to your personal data, please contact us at: firstname.lastname@example.org.
7 WHO DO WE SHARE YOUR INFORMATION WITH?
7.1 We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies or other organisations as a result of giving your details to us.
7.2 We will only share your data for the following purposes:
7.2.1 Compliance & Quality Management Requirements
We may be required, according to the course/training event you attend, to use your information for compiling reports and records that are required of us by qualification awarding bodies or relevant Authorities. You will be informed of this and provided further details when you book on a course/training event where such a requirement applies.
7.2.2 Where legally required
We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else.
7.3 We always aim to ensure that personal information is only used by third parties for lawful purposes in accordance with this Privacy Notice.
8 HOW WE PROTECT YOUR INFORMATION
8.1 We use technical and corporate organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.
8.2 We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, contractors.
8.3 Our online forms are always encrypted and our network is protected and routinely monitored.
8.4 However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.
9 HOW LONG WILL WE KEEP YOUR INFORMATION?
9.1 We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction).
9.2 If you request that we stop processing your personal information for the purpose of marketing, we may in some instances need to add your details to a suppression file to enable us to comply with your request not to be contacted.
9.3 In respect of other personal information, we will retain it for no longer than necessary for the purposes for which it was collected, considering guidance issued by the Information Commissioner’s Office.
10 INTERNATIONAL TRANSFERS OF INFORMATION
10.1 We may, on occasion decide to use the services of a supplier outside the European Economic Area (EEA), which means that your personal information is transferred, processed and stored outside the EEA. You should be aware that, in general, legal protection for personal information in countries outside the EEA may not be equivalent to the level of protection provided in the EEA.
10.2 However we take steps to put in place suitable safeguards to protect your personal information when processed by the supplier such as entering into the European Commission approved standard contractual clauses. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.
11 YOUR RIGHTS TO YOUR PERSONAL INFORMATION
11.1 Data protection legislation gives you the right to request access to personal information about you which is processed by Active SCG Ltd and to have any inaccuracies corrected.
11.2 You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information.
If you wish to exercise these rights, please contact us and send it along with copies of two separate identification documents which provide photo identification and confirm your address, such as a passport, driving licence, or utility bill. Please also provide any additional information that is relevant to the nature of your contact with us, as this will help us to locate your records.
11.3 You can send us the documents and covering letter via:
(scans or photos of your two forms of identification)
Data Protection Officer
Active SCG Ltd
West Sussex, RH11 7XX
11.4 We will respond within 1 month, on receipt of your request and copies of your identification documents. We reserve the right to charge a reasonable fee if manifestly unfounded or excessive for the administrative costs of complying with the request.
11.5 We will also charge a reasonable fee if an individual requests further copies of their data following a request.
12.1.2 This website operates an “implied consent” policy for cookies, which means that we assume you are happy with cookie usage on the site. If you are unhappy you should either not use the site or delete its cookies after visiting the site. Alternatively you could use the anonymous usage option in your browser, such as “Incognito” in Chrome, “InPrivate” in Internet Explorer and “Private Browsing” in Firefox and Safari.
12.1.3 A number of cookies are used on this site for a variety of reasons. Using cookies helps us to understand user needs, provide personalised content, improve functionality and match relevant content and services with users.
12.1.4 If you want to know more about cookies and how to control or delete them, please visit http://www.aboutcookies.org, which contains detailed guidance for users.
12.1.5 Cookies are small text files which contain a small amount of information that is downloaded to your computer or mobile device when you visit a website. When you visit the website again, or visit another website which recognises that cookie, your device is able to communicate with the website and the website can read the information held in that cookie.
12.2 Categories of Cookies
12.2.1 We use [four] categories of cookie on our websites:
(d) Behavioural Advertising & Third Party Cookies
12.2.2 Essential cookies are required for the operation of our Website and help users to navigate the website and are used for secure transactions and checkouts. Essential cookies can help load pages quickly, facilitate secure online transactions and retain the contents of your shopping cart when you continue shopping or navigate away from the page. Without cookies online shopping might not be possible.
12.2.3 Analytics cookies collect information about how visitors use our website and are used to monitor website performance and user behaviour. They allow us to recognise and count the number of visitors and to see how visitors move around our Website and to improve the website, providing better content for users and to identify areas in need of maintenance.
12.2.4 Performance cookies can help us to identify the most popular products/services/content and present this content more prominently for returning users. On Fastjet.com we use performance cookies to identify the device you are using to access the website and the country from which you are viewing the website. This allows us to present the most relevant content to you the user. Performance Cookies do not collect any information that could identify you. The information collected by these Cookies is either anonymous or pseudonymised.
12.2.5 Behavioural advertising cookies may be used by advertisers or sponsors to serve tailored advertising to users. Online behavioural advertising provides relevant advertising for users, based on interests and previous web browsing activity. We do not control these cookies placed on your computer by third party advertisers.
12.3 Cookies We Use
12.3.1 Our use of Necessary Cookies includes:
(a) identifying you as logged in to the secure parts of our website for the duration of your visit;
(b) remembering information you have previously entered to complete a form (e.g. retrieval of a quote) as you proceed through a journey on our Website. Your information is stored on our secure servers and the cookie contains only a unique reference number which links you to your stored information when you log into the Website.
12.3.2 We do not use Necessary Cookies to:
(a) collect information about you for marketing purposes; or
(b) track your internet activity on other websites.
12.3.3 Our use of Performance Cookies uses includes:
(a) analysing how visitors use our website;
(b) recording any errors that occur;
(c) testing different designs of our website; and
(d) measuring the effectiveness of our advertising.
12.4 We do not use Performance Cookies to collect personal information.
12.5 Accept or block Cookies
12.5.1 You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies (including Necessary cookies) you may not be able to access all or part of our Websites. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.
12.5.3 Where a cookie is provided by a third party, you may be able to use that third party’s own tools to block that cookie.
12.5.4 Browsers can be set to not accept any cookies at all, but many websites will not be able to function without cookies and it can slow down your online browsing activities.
12.6 IP Address
12.6.1 This site also tracks the IP addresses of its users. An IP Address is a number that identifies an Internet Service Provider and user country. IP addresses do not contain personal information and help us to build a picture of who visits the site.
12.7 Mobile device recognition
12.7.1 This site also tracks the type of device used to access the website. This allows us to direct the user to content which is optimised for their device, increasing the speed of page loading and overall usability.
13 HOW TO MAKE A COMPLAINT OR RAISE A CONCERN
13.1 If you would like more information, or have any questions about this policy, to make a formal complaint about our approach to data protection or raise privacy concerns please contact the Information Governance Team:
+44 (0) 330 311 0737
Data Protection Officer
Active SCG Ltd
West Sussex, RH11 7XX
13.2 If you would like to make a complaint in relation to how we have handled your personal information, please follow our complaints procedure. If you are not happy with the response you receive, then you can raise your concern with the relevant statutory body:
Information Commissioner’s Office
Alternatively you can visit their website.
14 CHANGES TO OUR PRIVACY NOTICE
14.1 Our Privacy & Cookies policy and associated procedures may change from time to time, so please check this page occasionally to see if we have included any updates or changes, and that you are happy with them.
(Last updated: 01 May 2018)