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Privacy Notice

Welsh for Adults

Learner's Privacy Notice

This notice provides information about the Welsh for Adults ("the Course") Courses and how the National Centre for Learning Welsh ("the Centre") collects, processes and shares your personal data with Course Providers ("the Providers"), our financers and the Welsh Government ("the Government").

For the purposes of the applicable data protection law including the Data Protection Act 1998 and the General Data Protection Regulation (Regulation (EU) 2016/679) ("Data Protection Law"), the Centre, College Road, Carmarthen, SA31 3EP is Data Manager of the information we collect about you.

Efa Gruffudd Jones is the Centre's Interim Data Protection Officer and can be contacted on 03003 234324 if you have any questions or need more information.

Principles of Data Protection

The Centre will comply with Data Protection Law. The law says that the personal information we hold about you should be:

  1. Used legally, fairly and transparently.
  2. Only collected for valid purposes that we have explained clearly to you, and that the information is not used in any way that is incompatible with those purposes.
  3. For the purposes that we have told you about and for those purposes only.
  4. As accurate and up to date as possible.
  5. Kept only as long as it is needed and for the purposes that we have told you about.
  6. Stored securely.

What information will the Centre collect?

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

  • Full name
  • Date of birth
  • Home address
  • E-mail address
  • Gender
  • Ethnicity
  • National Insurance number
  • Last school attended
  • Top qualification
  • Any learning difficulties you have
  • Any health related problems
  • Course details
  • Whether you have completed a Welsh Course before, as well as any qualifications that you applied for and previously obtained
  • Course performance (including attendance and any qualification results, where necessary)
  • Any information that would help us make reasonable adjustments for you; and
  • Any information you provide to the Centre in contact forms or by correspondence

Personal information also includes special categories of personal data, including information about your race or ethnic origin, political opinion, religious or philosophical belief, membership of a trade union, genetic and biometric data, data about your health, or sexual orientation. If the Centre collects this information from you during your time on the Course, you may be asked to give specific consent.

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

The Centre will process your information to be able to complete the following purposes:

  • enroll you on the Course
  • allocate a Provider to you
  • support you during and after your Course time (where necessary)
  • run the Course on a day to day basis
  • monitor completion and progress on the Course
  • report on attendance and how the Course goes
  • report to the Welsh Government on the Course
  • share information about other Courses with you.

Where will the Centre collect information about you?

  • Information you give to the Centre. The Centre will collect information directly from you when you contact the Centre or when you enrol onto one of the Courses through the Registration Form.
  • Information that the Centre receives about you by the Provider.
  • Information that the Centre receives from other sources such as your Course tutor.

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

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to complete our contractual obligations that we are about to start with you or you have joined with.
  • Where necessary for our legitimate (or third party) interests and in a situation where your interests and basic rights do not overcome those benefits.
  • Where we need to comply with a legal or regulatory obligation.

In general, we do not rely on consent as a legal basis for processing your personal data other than in sending you third-party direct marketing communications via email or text message. You have the right to withdraw your permission to market you at any time by contacting us.

The purposes for which we will use your personal data

We need some categories of personal data to register you onto the Course as a student.

This will include (as applicable):

  • processing your personal information so that we can meet our contractual obligations with you (such as the student's contract with the Centre); (this will also include our ability to process and change any mistakes, such as ‘typo’s in your personal information identified by us);
  • processing your personal information when it is necessary to comply with our legal obligations imposed by European Union law (where applicable) and by the English Laws that apply to us in the United Kingdom.

Your consent can also be a legal 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 obtained from you, for example, when you agree to receive our marketing correspondence or when you agree to take part in market surveys or research (as applicable). You should realise that you have the right under Data Protection Law to withdraw your consent at any time given.

We have also set out below, in a table format, a description of all the ways we intend to use your personal data and which of the legal foundations we rely on to do so. We have also indicated what our legitimate interests are where appropriate.

Please note that we can process your personal data for more than one legal area, depending on the specific purpose that we use your data. Please contact us if you need details of the specific legal field that we rely on to process your personal data where more than one area is set out in the table below.

The following terms are used in the table below:

  • Legal Benefit involves the interest of our business in maintaining and managing our business to enable us to give you the best service / product and the safest experience. We ensure that we consider and balance any potential impact (both positively and negatively) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where the effect on your interests is large (unless we have your consent or otherwise where required or by law). You can find out more about how we assess our legitimate interests against any potential impact you may have by contacting us.
  • Contract Performance involves processing your data where necessary for performing a contract that you are part of, or take action on your application before or when you enter into a contract.
  • Compliance with a legal or regulatory obligation means processing your personal data where necessary to comply with a legal or regulatory obligation that we are subject to.

The recipient of your information

The Centre and Providers are funded by the Government for the purposes of providing the Courses, allocating you to a specific Provider, ensuring the Courses are run effectively, providing feedback on how much the Courses take and reporting the way the funding is used, we can share your personal data with the Provider and the Government. Where possible, the Centre can make your personal data anonymous or collate it.

The Centre, Providers and Government are all legally interested in running the Courses and helping learners with the Welsh language.

The Centre can share your personal information:

  • With Providers;
  • With the Welsh Government for the purposes of the Lifelong Learning Wales Record;
  • With governmental authorities, courts and government agencies to comply with legal orders, legal or regulatory requirements and government requests; and / or
  • With our advisers and other legal and professional evaluators.

Purpose / Activity

 

Type of data

Legal basis for processing including the basis of valid interest

To register as a learner.

 

a)  Personal details

b)  Contact information

Performing our contractual obligations with you.

To process and submit your application for the Course including:

a)    to manage payments and fee payments

b)    to collect and recover money owed to us.

a)  Personal details

b)  Contact information

c)  Financial

d)  Correspondence / Discussion

e)  Marketing and Communications

a)   Performing our contractual obligations with you.

b)   Required for our legitimate interests (to recover debts owed to us).

To manage our relationship with you which will include:

a)    informing you of changes to our terms or privacy policy

b)    to ask you to leave a review or take a review.

c)    To monitor your performance on a course, including reviewing and monitoring your scores in any tests or assessments

 

a)  Personal Details

b)  Contact information

c)   Profile data

d)  Marketing and Communications

 

a)    Performing our contractual obligations with you.

b)    Necessary to comply with legal obligation.

c)    Required for our legitimate interests (to keep our records up to date and to study how customers use our products / services).

To enable you to take part in a competition or to complete a survey.

 

a)  Personal Details

b)  Contact information

c)  Profile data

d)  Use information

e)  Marketing and Communications

 

a)    Performing our contractual obligations with you.

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

To administer and protect our business and this website (including problem solving, data analysis, testing, system maintenance, support, reporting (and data maintenance).

 

a)  Personal Details

b)  Contact information

 

a)    Required for our legitimate interests (for running our business, providing administration and IT services, network security, fraud prevention and business reorganisation or group restructuring practice).

b)    Necessary to comply with legal obligation.

To provide content and website advertisements relevant to you and to measure or understand the effectiveness of the advertisements we serve you.

a)  Personal Details

b)  Contact information

c)  Profile data

d)  Use information

e)  Marketing and Communications

Required 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 analyses to improve products / services, marketing, relationships and customer experiences.

 

Use information

 

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

To make suggestions and recommendations for Courses or Services that may be of interest to you.

a)  Personal Details

b)  Contact information

c)  Use information

d)  Profile data

a)    Required for our legitimate interests (to develop our products / services and grow our business).

  

How we use particularly sensitive personal data

There are "special categories" of sensitive information that require higher levels of security. We need further justification for collecting, storing and using this type of personal information.

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

  1. In limited circumstances, with your specific permission.
  2. Where needed for the benefit of the public, such as for equal opportunities monitoring.

Less commonly, we can process this type of information where it is needed in relation to legal claims, or where it is necessary to protect your interests (or the interests of someone else) and you cannot give your consent, or where you have already made the information publicly.

Promotional offers from us

We may use your Personal, Contact, Use and Profile Details to make a judgment on what we think you want or need, or what might be of interest to you. This is how we decide which products, services and offers may apply to you and whether to contact you to inform you of them.

You will receive marketing communications from us if you have requested information from us or have registered with us [or you gave us your details when you competed or registered for promotion].

Third party marketing

We will seek your specific permission before we share your personal data with any company outside the Course Providers for marketing purposes.

Withdrawal

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

If you withdraw from receiving these marketing messages, this will not apply to personal data provided to us as a result of [purchase of product / service, guarantee registration, product / service experience or other link].

Change purpose

We will only use your personal data for the purposes that it was collected, unless we reasonably consider that we need to use it for another reason and that that is compatible with the original purpose. If you would like clarification about 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 another purpose, we will inform you and we will explain the legal basis that allows us to do so.

Please note that we can process your personal data without your knowledge or permission, in accordance 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.

  • Third Parties:
    • Service Providers operating as UK-based processors that provide IT administration services or other similar systems]
    • Professional advisers acting as processors or joint managers including solicitors, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services].
    • From HM Revenue & Customs, regulators and other authorities acting as processors or UK-based co-managers that we will need to report on processing activities in certain circumstances].
    • From third parties we could choose to sell, transfer, or merge parts of our business or our assets. Otherwise, we may try to acquire or merge other businesses. If there is a change to our business, then the new owners can use your personal data in the same way as are set out in this privacy notice.

We require all third parties to respect the protection of your personal data and 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 allow them to process your personal data for specific purposes and in accordance with our instructions.

Data Protection

We have put in place appropriate security measures to prevent your personal data being lost, used in an unauthorised way, accidentally changed or disclosed. In addition, we restrict access to your personal data to employees, agents, contractors and other third parties that they have a business reason to know about. They will only process your personal data on our instructions and are subject to a confidentiality duty.

We have put in place procedures to deal with any suspected personal data breach and we will inform you and any relevant regulator of the breach of personal data rules where we are required to do so legally.

Your legal rights

In some circumstances, you have rights under Data Protection Law in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as "data access request"). This allows you to receive a copy of the personal data we have about you and to check that we process it legally.
  • Ask to correct the personal data that we hold about you. This allows you to correct any incomplete or incorrect data we have about you, although we may need to check the accuracy of the new data you give us.
  • Request to delete your personal data. This allows you to ask us to delete personal data where there is no good reason to continue processing. You also have the right to ask us to delete your personal data where you have used your right to object to the processing (see below), where we may have processed your information illegally or where we are required to delete your personal data to comply with local law. Please note, however, that we will not always be able to comply with your request to cancel for specific legal reasons and we will let you know, if applicable, at the time of your request.
  • Oppose the processing of your personal data where we rely on legal (or third party) benefits and there is something about your particular situation that makes you want to oppose processing on this basis as you feel it is affect your basic rights and freedoms. You also have the right to oppose where we process your personal data for direct marketing purposes. In some cases, we may be able to demonstrate that we have a strong legal basis to process your information that overcomes your rights and freedoms.
  • Ask to restrict the processing of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) where our use of the data is illegal but you do not want us to delete it; (c) where we need to hold the data even if we no longer need it as you will need to establish, practice or defend legal claims; or (d) you have objected to our use of your data but we need to check if we have a legal basis to use that defeats your objection.
  • Ask for transferring your personal data to you or to a third party. We will provide you, or a third party of your choice, your personal data in a structured, common-use format, and easily readable in paper. Please note that this right applies only to automated information that you gave us permission to use in the first instance, and used to perform a contract with you.
  • Withdraw your consent at any time where we rely on consent to process your personal data. However, this will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your permission, we may not be able to provide you with some products or services. We will advise you if this is true at the time you withdraw your permission.

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

Data Making Anonymity

We can convert your personal data into statistical data or collect in such a way to ensure that it is not known or can be identified from that data. We can use this data gathered to conduct market research and analysis, including in order to produce research and statistical reports. For example, we receive Government funding and we will need to report them on how many people have chosen to take the Course, the success rates and feedback in general about the way the Course is going on. We can share data that has been collated in several ways, including for the same reasons as we can share personal data (see below).

Retention periods

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

Transfer outside the EEA

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

Protect your personal data

We are taking steps to protect the personal data that we process and make sure it is kept safe and in accordance with Data Protection Law. In particular, we will endeavor to maintain appropriate organisational and technical actions to help protect your personal data including what is being transferred, stored or otherwise processed, against being destroyed, lost, changed, accessed without authority, or illegally or accidentally accessing. These steps include computer protection and securely secure files and facilities.

Where we have given you (or where you have selected) a password that allows you to access some parts of our Ap, you are responsible for keeping this password confidential. We will not ask you to share a password with anyone.

Failure to provide personal data

You have the right to find out about the possible consequences of failing to provide the personal data we ask you about. Any failure to provide personal data can affect your ability to be admitted to the Course.

Your right to make complaints with the authority oversight of Data Privacy

Without prejudice to any other administrative or judicial remedies you may have, you have the right to make a complaint with the UK Information Commissioner if you consider we have breached qualified data privacy laws when processing your personal data.

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

Changes to our privacy notification

Any changes we make to our future privacy notice will be posted on this page. Remember to check regularly to see any updates or changes to our privacy notice.

Contact information

The National Centre for Learning Welsh

03003 234324

office@dysgucymraeg.wales

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