Runway

Privacy Policy

Introduction

How we use your informaton

We are committed to protecting your privacy. We take great care to ensure your information is kept safe and secure. This policy explains how we will collect, store, use and share your personal information.

We collect information in several ways including when you use our website, submit a course enquiry form, enrol on a course or provide information to us by post, email, phone or text.

Key terms and their meanings

Data Controller – means the person or entity which alone or jointly with others determines the purposes and means of the processing of personal data.

Data Protection Law – the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998/2018 

Sensitive Information – this is also known as Special Category Data and includes information revealing about a person’s racial or ethnic origin, political opinions or trade union membership, religious or philosophical beliefs, health, sex life or sexual orientation, or genetic data and biometric data for the purpose of uniquely identifying a natural person. Information about criminal convictions is often included in this definition.

Data Controllers – For the purposes of the data protection law the data controller for the services we provide to you will be Runway Apprenticeships Ltd. We are registered with the ICO, registration number ZA124731.

Data Protection Officer We have appointed a Data Protection Officer to oversee our handling of personal information.

Oliver Trailor, Data Protection Officer
e- olivertrailor@runwaytraining.co.uk
t- 01732 402 402

Who do we collect information about?

We collect information about the following types of individuals:

  • Previous, current and prospective learners (including apprentices)
  • Previous, current and prospective employer contacts
  • Previous, current and prospective staff members
  • Named contacts from partner organisations including colleges, government agencies and awarding organisations.

When do we collect information about you?

We collect information about you:

  • When you apply to us for information on a course
  • When you contact us (by phone, email, through our website or otherwise) such as to update or check your details, complete surveys, provide feedback or fill in forms
  • When you sign-up for a course, place an order on our website or leave comments
  • When you contact us to make a complaint or report a problem

What information do we collect about you?

The personal information that we collect will depend on your relationship with us. We will collect different information depending on the course you are looking to enrol on with us, and whether you are an existing learner, making a new enquiry or enquiring on behalf on someone else.

Please note, in certain circumstances we may request and/or receive sensitive personal information about you. For example, we may need to access details of any unspent criminal convictions for the purposes of enabling you to access certain government funding streams.

If you provide personal information to us about other individuals you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any consent where we indicate that it is required for the processing of that individual’s personal data in accordance with this Privacy Policy. Please see below for detailed information regarding the types of personal information we are likely to collect and use about you.

Personal Information:

  • General information such as your name, address, date of birth, email address and phone number
  • Details of prior attainment
  • Identification information such as national insurance number and passport number
  • Occupation

We may collect information when you use our website including data that allows us to monitor your preferences and how you use our website. This helps us to organise our website content in order to improve your experience.

The information we collect includes:

  • Details of transactions you carry out through our website.
  • Information that you provide by filling in forms on our website even if those forms are not submitted
  • Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time)
  • Products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Special Category (sensitive) Personal Information and Criminal Personal Information:

  • Details about your health but only if this information is pertinent to (i) Funding (for example medical conditions which are notifiable to the tutor such as prone to flashing lights), Safeguarding administration (for example to help us to identity a potentially vulnerable learner), (iii) Funding eligibility (for example to establish whether a learner or potential learner would be entitled to funding or additional funding).
  • Information relating to your criminal history (including offences and alleged offences and any caution, court sentence or criminal conviction) but only if this information is pertinent to (i) the eligibility process (ii) Safeguarding administration.
  • We do not actively request details about your race and/or ethnicity, but this information may be recorded if it is pertinent to (i) Funding eligibility (ii) a complaint (for example an allegation is made by you of racial discrimination).
  • We do not actively request details about your political opinions, religious or philosophical beliefs or trade union membership but this information may be recorded if it is provided by you whether through phone, email, letter, or via a website, app, social media or online chat.

How do we collect your information?

We collect personal information from a number of different sources including:

  • Directly from you or from someone else on your behalf by website, phone, email, SMS, paper documents or in person.
  • From our records
  • From referral agencies and partner organisations including colleges & training providers
  • Other publically available sources, including, but not limited to, Google Earth and social media
  • Through customer and employer surveys
  • From government agencies such as the education and skills funding agency

What are the purposes for which information about you is used?

We may process your information for a number of different purposes. For each purpose we must have a legal ground for such processing. When the information that we process is classed as special category or sensitive personal information, we must have an additional legal ground for such processing. Whether you provide us with the information, or we collect information from you or we are provided with information from other sources, we may use this information:

a) To review your course application and provide appropriate information, advice and guidance

Legal grounds:

· Our having an appropriate business need to use your information to provide suitable courses and ensure it matches your requirements

b) To enrol you on to a course with Runway Training and if appropriate a funding partner

Legal grounds:

· To meet our obligations with funding partners and ensure we have an accurate record of your data including contract details

Additional legal ground for sensitive personal information:

· Either because the use of this information is necessary for the purpose of carrying out eligibility checks for funding as permitted by Data Protection Law, or, because you have provided us with your explicit consent.

c) To evaluate your application and ability to pay for your course by instalments (if applicable)

Legal grounds:

• such use is necessary in order to provide your course

Additional legal ground for sensitive personal information:

• Either because the use of this information is necessary for the purpose of carrying out eligibility checks for funding as permitted by Data Protection Law, or, because you have provided us with your explicit consent.

d) To provide and manage your course

Legal grounds:

• Our having an appropriate business need to use your information to provide services which does not overly prejudice you.

•  such use is necessary in order to provide your course

Additional legal ground for sensitive personal information:

• Either because the use of this information is necessary for the purpose of carrying out eligibility checks for funding as permitted by Data Protection Law, or, because you have provided us with your explicit consent.

e) Communicating with you and resolving any complaints that you might have

Legal grounds:

·  Our having an appropriate business need to use your information to provide services which does not overly prejudice you.

· such use is necessary in order to provide your course

Additional legal ground for sensitive personal information:

·  Either because the use of this information is necessary for the purpose of carrying on insurance business as permitted by Data Protection Law, or, because you have provided us with your explicit consent.

f) To transfer to third parties for the purpose of providing you with the services required under the insurance contract or other services which you have elected to receive from us in connection with your course.

Legal grounds:

· Our providing the course and other contracted services involving third parties

Additional legal ground for sensitive personal information:

· You have provided your explicit consent to the provision of these additional services which necessitate the transfer of sensitive personal information

g) To transfer to third parties where you have elected to enter into a contract with that third party for separate services

Legal grounds:

·  You have provided your explicit consent to allow us to provide the third party with your details to enable you to enter into a contract with that third party.

Additional legal ground for sensitive personal information:

·  You have provided your explicit consent to the provision of these additional services which necessitate the transfer of sensitive personal information

h) Complying with our legal or regulatory obligations

 Legal grounds:

· The use is necessary in order for us to comply with our legal obligations

Additional legal ground for sensitive personal information:

· Either because the use of this information is necessary for the purpose of carrying on business activities as permitted by Data Protection Law, or, because you have provided us with your explicit consent.

· The use is necessary in order for us to establish, exercise or defend our legal rights

i) Recover outstanding payments

Legal grounds:

· Our having an appropriate business need to use your information in order to recover debts which does not overly prejudice you

Additional legal ground for sensitive personal information:

· The use is necessary in order for us to establish, exercise or defend our legal rights

j) To provide you with information about goods or services we feel may interest you, including news updates and details of special offers

Legal grounds:

· You have provided your explicit consent which can be withdrawn at any time.

k) To improve our customer service

Legal grounds:

· Our having an appropriate business need to use your information in the improvement of our customer service which does not overly prejudice you

l) To measure the effectiveness of our advertising

Legal grounds:

· Our having an appropriate business need to use your information to ensure our advertising is effective which does not overly prejudice you

m) To notify you about changes to our services or products

Legal grounds:

· Our having an appropriate business need to use your information to keep our customers up to date with changes to our products or services which does not overly prejudice you.

n) To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes

Legal grounds:

· Our having an appropriate business need to use your information to maintain our websites which does not overly prejudice you.

o) To allow you to participate in interactive features of our services / website

Legal grounds:

· Our having an appropriate business need to use your information to offer an interactive website for customers which does not overly prejudice you.

Who do we share the information we collect about you with?

Sharing within Runway Training

We may share your information within Runway Training for the following reasons:

  • To obtain a course quote
  • To administer and manage your course
  • To provide you with services required as part of your learning agreement with us
  • To provide data analysis in order to assist us with the pricing of our products and detect market trends
  • Where you have given your explicit consent, for marketing purposes;
  • To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • To improve our website, including as part of our efforts to keep our website safe and secure
  • To allow invoicing and to recover any outstanding payments;
  • For legal, financial reporting and regulatory purposes.

Sharing with third parties

We may also share your information with selected third parties, in order to offer services to you or to perform any necessary functions on our behalf. This may include:

  • Your relatives, guardians or named next of kin
  • Where you have named an alternative contact (such as a relative) to speak with us on your behalf. Once you have told us your alternative contact, this person will be able to discuss all aspects of your course with us and make changes on your behalf.
  • Our funding partners such as government agencies, local authorities or other educational institutes or other companies who work as partners.
  • Other third parties who assist in the administration of course delivery such as OneFile and ForSkills who provide e-learning materials.
  • We may also share personal information with CRM systems including PICS (Pellcomp) and Salesforce, more information on their own data and privacy policies can be requested via our data officer Oliver Trailor (olivertrailor@runwaytraining.co.uk).
  • Clubs or groups that you have elected to join (for example the Runway Training Facebook Group)
  • Search engine operators who can assist us in the improvement of our website.

How long do we keep personal information for?

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes and in order to comply with our contractual, legal and regulatory obligations. We have implemented a Document Retention Policy which records of details how long various types of information should be retained. The Policy is reviewed on a regular basis to ensure that it aligns to current legal and regulatory requirements. The retention periods vary depending upon the circumstances of an individual matter but in general our retention periods for customer facing documentation can be set out as follows:

Course enquiry information10 yearsContractual obligation as paperwork may be called upon at audit.
Enrolment information and associated documents10 yearsContractual obligation as paperwork may be called upon at audit.
EU funded provision including- Student records, academic achievements, and associated evidence.As outlined by ESF/SFA contract – currently up until 2022Contractual obligation as paperwork may be called upon at audit.

If you would like further information regarding the periods for which your personal information will be stored, please see the contact details outlined in the “How to Contact Us” section below

Your Rights

Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in the “How to Contact Us” section of this Privacy Policy. Please note:

  • In some cases we may not be able to comply with your request (e.g. we might not be able to delete your data) for reasons such as our own obligations to comply with contractual, legal or regulatory requirements. However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.
  • In some circumstances exercising some of these rights (including the right to erasure, the right to restriction of processing) will mean we are unable to continue providing you with your course and may therefore result in the cancellation of our services to you. You will therefore lose the right to complete your qualification and/or course, including in relation to any event that occurred before you exercised your right of erasure.

The right to access your personal information

You have the right to access a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests.

The right to rectification

We take reasonable steps to ensure that the personal information we hold about you is accurate and up to date. However, if you do not believe this is the case, you can ask us to update or amend it.

The right to erasure

In certain circumstances, you may ask us to erase your personal information

The right to restriction of processing

In certain circumstances, you are entitled to ask us to stop using your personal information.

The right to data portability

In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.

The right to object to marketing

You can ask us to stop sending you marketing messages at any time.

The right to withdraw consent

For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information.

The right to lodge a complaint with the ICO

You have a right to complain to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations.

More information can be found on the ICO’s website at: www.ico.org.uk/concerns

Making a complaint will not affect any other legal rights or remedies that you have.

How we protect your information

We want you to have confidence in how we use and hold your data. We know that to achieve this we must preserve the security and confidentiality of your personal information. We have therefore developed a range of organisational, procedural and technical security measures designed to protect personal information from unauthorized use or disclosure.

Examples of some of these measures include:

  • Regular backup schedules and disaster recovery environment for key systems and services.
  • Secure file transfer methods are used to encrypt data.
  • Usage of data loss prevention tools within Runway Training.
  • Data breach investigation: Audit and logging tools used to investigate any potential or reported breaches.
  • Data breach response: A plan that pulls together our compliance, legal and IT security teams to ensure rapid assessment and mitigation of data breaches

Changes to our Privacy Policy

We keep our Privacy Policy under review and it is updated periodically. For example, those changes may be due to government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up-to-date Privacy Policy.

This Privacy Policy was last updated on: 9th July 2018
Version: 1.1
Document Creation Date: 24.5.2018
Implementation Date: 25.5.2018
Review Date: 25.5.2020
Distribution to: All

How to Contact Us

Please contact us if you have any questions about our Privacy Policy or to exercise any of your rights

Data Protection Officer
190 High Street
Tonbridge
Kent
TN9 1BE

Email: enquiries@runwaytraining.co.uk.

Where you have made the request by electronic means, the information will be provided to you by electronic means where possible.

If you have a complaint about the way in which your data has been processed, you can contact the ICO at: www.ico.org.uk/concerns

Copyright © 2018 Runway Apprenticeships Ltd – Company Registered in England 8957135

Call Us: +44 (0)1732 402 402
190 High Street,
Tonbridge, Kent TN9 1BE