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Privacy Notice

Learner's Privacy Notice

This notice provides information about the [Welsh for Adults] courses (“the Course”) and how the National Centre for Learning Welsh (“the Centre”) collects, processes and shares your personal data with [providers of the course] (“the Providers”).

For the purposes of the applicable data protection law including the Data Protection Act 2018 and, the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR UK) (“Data Protection Law”), the Centre of Ffordd y Coleg, Caerfyrddin, SA31 3EP is the Data Controller of the information it collects from you. 

The Centre’s Data and Analysis Officer can be contacted on 03003234324 should you have any queries or require further information.

Data protection principles

The Centre will adhere to data protection legislation. The legislation states that the personal information we hold about you must be:

  1. Processed lawfully, fairly and in a transparent manner.
  2. Collected only for legitimate purposes which we have explained clearly to you and not used in any way that is incompatible with those purposes.
  3. Relevant and limited to what is necessary in relation to the purposes for which it is processed.
  4. Accurate and where necessary kept up to date.
  5. Kept for no longer than is necessary, for the purposes that we have informed you about..
  6. Kept safely.

What information will the Centre collect?

The Centre will collect personal information about you throughout your dealings with the Centre. This includes for example:

  • Full Name
  • Date of Birth
  • Address
  • E-mail address
  • Gender
  • Ethnicity 
  • National Insurance Number
  • Any learning difficulties you may have
  • Any health related issues 
  • Course details
  • Whether or not you have completed a Welsh Course previously, any awards entered and previously achieved
  • Performance on the Course (including attendance, any results of awards, where necessary)
  • Any information that would assist us in making reasonable adjustments for you
  • Any information that you provide to the Centre in contact us forms or through correspondence 

Personal information also includes special categories of personal data. This is data about your racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic and biometric data, data concerning your health, or sexual orientation. In the event that the Centre does collect this information from you during your time on the Course you may be asked to provide explicit consent.  

Why is the Centre processing my personal information and what is it used for?

The Centre will process your information for the purposes of:

  • your enrolment on to the Course
  • allocating you a provider
  • support during your time on the Course and thereafter (where necessary)
  • the day to day running of the Course
  • monitoring of completion and progression on the Course
  • reporting on attendance and how the Course is going
  • sharing information with you about other courses

Where will the Centre collect information from?

  • Information you give to the Centre - The Centre will collect information directly from you when you contact the Centre or when you enrol via the Registration Form on to one of the Courses.
  • Information from resources that you complete online
  • Information the Centre receives from the Provider.
  • Information the Centre receives from other sources such as your Course tutor.

Information may be shared by other Providers with the Centre for the purposes of reporting on, for example, the Course, attendance, progression and completion.

How we use your personal data

We will only use your personal data when it is lawful for us to do so. Most commonly, we will use your data in the following circumstances:

  • Where it is necessary in order that we may perform our obligations under a contract that we are about to start with you or that you have joined.
  • Where it is necessary for our legitimate interests (or those of a third party) and in situations where your interests and fundamental rights do not override those interests.
  • Where necessary for compliance with our legal or regulatory obligations.

Generally, we do not rely on permission as the legal basis for processing your personal data except in relation to sending direct marketing communications to you by email or text message. Nevertheless, you are entitled to withdraw your consent for us to send you marketing materials at any time by contacting us.

The purposes for which we will use your personal data

We need some categories of personal information in order to enrol you, and for you to become a student on the Course.

This will include (as relevant):

  • processing your personal information in order to perform our contractual obligations to you (such as the student’s contract with the Centre); this will also include our ability to process and amend any errors such as ‘typos’ in your personal information that we identify);
  • processing that is necessary in order to meet our legal obligations as placed by English law, which is applicable to us in the UK.

Your consent may also be a legitimate reason for processing your personal data in relation to your time as a student at the Centre or with the Provider. This means your specific, informed and unambiguous consent, freely given and that may be obtained from you, for example, when you agree to receiving marketing correspondence from us or when you agree to participate in surveys or market research (as applicable). You should note that you have a right under Data Protection Legislation to withdraw your consent where it was given, at any time. We have also outlined below, in table format, description of all the ways in which we intend to use your personal data, and which of the legal bases we are depending upon in order to do so. We have also noted what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose, 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 in the table below.

The following terms are used in the table below: 

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities that would have a large impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before or as you enter into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Recipients of your information

The Centre and the Providers are funded by the Government for the purposes of providing the Courses. In order to allocate you to a specific provider, ensure that the Courses are run effectively, provide feedback on uptake of Courses and to report on how the funding is being used we may share your personal data with the Provider. Where possible, the Centre may anonymise or aggregate your personal data.

The Centre, the Providers and the Government all have a legitimate interest in the running of the Courses and assisting learners with the Welsh language.

The Centre may share your personal information:

  • With the Providers;
  • With the Welsh Government;
  • With WJEC for the purpose of entering Learn Welsh for Adults Examinations;
  • With employers for purposes relating to the Cymraeg Gwaith scheme;
  • With regulatory authorities, courts and government agencies to comply with legal orders, legal or regulatory requirements and government requests; and/or
  • With our legal and other professional advisers.

 

Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest 

To register you as a learner / To enter you for examinations

(a) Personal details

(b) Contact  

Performance of a contract with you

Processing and submitting your application for a course, including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Personal details

(b) Contact  

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

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 (c) Monitoring your performance on a course, including reviewing your scores in any tests or assessments

(a) Personal details

(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 enable you to participate in the Siarad scheme

(a) Personal details

(b) Contact  

Performance of a contract with you

To register your interest in being a tutor with our Providers

(a) Personal details

(b) Contact  

Performance of a contract with you

To enable you to participate in a prize draw, competition or complete a survey

(a) Personal information

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

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

(a) Personal details

(b) Contact  

(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Personal information

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

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

(a) Usage

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

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Personal information

(b) Contact

(c) Usage

(d) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

How we use particularly sensitive personal data

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit consent.
  2. Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. 

Promotional offers from us

We may use your Personal information, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you, and contact you to inform you of them.

You will receive marketing communications from us if you have requested information from us or registered with us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Course Providers for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

  • External Third Parties:

- Service providers acting as processors based in the UK who provide IT administrative systems or other similar systems.

- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may 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 notice.

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 specified purposes and in accordance with our instructions.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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.
  • Object to processing of your personal data where we are relying on a legitimate interest (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.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

Anonymising data

We may convert your personal data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data.  We may use this aggregated data to conduct market research and analysis, including to produce statistical research and reports.  For example, we receive funding from the Government and we will need to report to them on how many people have chosen to take the Course, the success rates and general feedback on how the course is going.  We may share aggregated data in several ways, including for the same reasons as we might share personal data (see below).

Retention Periods

The Centre will only retain your personal information for the time period that you are a student on the Course and for 6 years after completion of that course.

Transfers outside of the EEA

The Centre will not transfer your personal data outside of the EEA.

  • Security of your personal data
  • We take steps to safeguard the personal data we process and make sure it is held securely and in accordance with the Data Protection Law. In particular we endeavour to maintain appropriate organisational and technical measures to help us safeguard your personal data including that which is transmitted, stored or otherwise processed, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include computer safeguards and secured files and facilities.
  • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Consequences of failure to provide personal data

You have the right to be informed about the possible consequences of failure to provide the personal data we ask you for directly in connection with the Course. Any failure to provide personal data may affect your ability to accepted for the Course.

Your right to lodge complaints with the data privacy supervisory authority

Without prejudice to any other administrative or judicial remedy you might have, you have the right to lodge a complaint with the UK’s Information Commissioner if you consider that we have infringed applicable data privacy laws when processing your personal data. 

UK: Information Commissioner’s Office, https://ico.org.uk/ 

Changes to our privacy notice

Any changes we may make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.

Contact

The National Centre for Learning Welsh

03003234324

swyddfa@dysgucymraeg.cymru

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