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ESA GDPR privacy notice

1.  Background

ESA (Entrance Systems Alliance) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our learners, staff, members, suppliers, and consultants and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

2.  Information about us

Entrance Systems Alliance: A company limited by guarantee and not having a share capital, registered in England under company number 12491681.

Registered address: The Barn, Shuttington Fields Farm, Main Road, Shuttington, Tamworth B79 0HA

Trading styles: Entrance Systems Alliance, ESA

Main trading & postal address: The Barn, Shuttington Fields Farm, Main Road, Shuttington, Tamworth B79 0HA

Data Protection Officer: Patricia Sowsbery-Stevens

Email address: nvqtraining@esa.uk.com

Telephone number: +44 (0)1827 338323

3.  What does this notice cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

4.  What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 6.

5.  What are your rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
  • The right to access the personal data we hold about you. Part 11 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 12 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s office.

6.  What personal data do we collect?

We may collect some or all the following personal data (this may vary according to your relationship with us):

  • Name
  • Address
  • Email address
  • Telephone number
  • Business name
  • Job title
  • Payment information
  • Information about your preferences and interests
  • Photograph or video
  • National Insurance (NI) number
  • Racial or ethnic origin
  • Sex
  • Any barriers to learning
  • Date of birth

We do not obtain data from any third parties.

7.  How do we use your personal data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

  • Providing and managing your certification, qualification and card schemes.
  • Supplying our services to you. Your personal details are required for us to enter into a contract with
  • Personalising and tailoring our products and/or services for
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link or by replying with the word “unsubscribe” in the subject line of any email or in the case of postal information by writing to or emailing us).
  • Manage membership records and accounts.
  • Fulfil our statutory role as an Assessment Centre for the Awarding Organisation NOCN.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

8.  How long will we keep your personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • Accounting Data: We will keep this category of data for the duration of the period you are a member of [or supplier to] Entrance Systems Alliance (ESA). We shall retain your data only for as long as necessary in accordance with applicable laws. On the closure of your account, we may keep your data for up to 7 years after you have cancelled your relationship with us [or we have ceased purchasing goods and/or services from you]. We may not be able to delete your data before this time due to our legal and/or accountancy obligations.;
  • Data used for email marketing and communication purposes: This category of data is cleansed after each use, normally on a weekly basis to remove bounces, unsubscribes, dead addresses, mailing returns etc. We may keep your data for up to 7 years after first use or longer where re-subscription, open rate statistics or other such indicators confirm that emails are still being read.
  • Data used for postal mailing purposes: This category of data is cleansed and/or updated from returns provided to us by Royal Mail following each mailing. We may keep your data for up to 7 years after first use or longer where re-subscription or other such confirmation has been
  • Data used for telemarketing or SMS messaging: This category of data (landline and mobile phone numbers), whilst in some cases may have been collected with other data, it will only be used by us for essential communication purposes and not telemarketing or SMS messaging. ESA does not enter into telemarketing or SMS marketing practices. We may keep your data for up to 7 years after first use or longer where re-subscription or other such confirmation has been

9.  How and where do we store or transfer your personal data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

There is no foreseeable reason that would cause us to share or transfer your data to a third party based in the US. However, if we did this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 12 for further information about the data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take several important measures, including the following:

  • Secure storage on local password protected and/or encrypted
  • Secure storage in the cloud using industry standard service
  • Secure transfer of data to third parties by password protected FTP connection or encrypted
  • Secure transfer of data to third parties by encrypted

10.  Do we share your personal data?

We may sometimes contract with the following third parties to supply products and/or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

Telephone enquiries: 0300 999 1177

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described in Part 7 and Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained in Part 7 and Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11.  How can you access your personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request” or SAR.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will aim to respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

12.  How do you contact us?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of The Data Controller):

Email address:            nvqtraining@esa.uk.com

Telephone number:     +44 (0) 1827 338323

Postal Address:           The Barn, Shuttington Fields Farm, Main Road, Shuttington, Tamworth B79 0HA

13.  Changes to this privacy notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.  Any changes will be made available either on our website www.ESA.uk.com  or via a personal email communication.

A partnership between:

  • DHF
  • ADSA