Privacy Notice

Contents

Introduction

How we collect your information

How we use your information

How we use information about our Learners

The lawful basis for processing your information and how we use it

Sharing information with others

Data Transfers outside of the EEA/EU and data portability

How long your information is kept

What do we use your data for?

Security of your personal information

Job applicants, current and former FSC employees

Your rights

Complaints or queries

Subject Access Request Process

How to contact us

Changes to this privacy notice

Introduction

This privacy notice tells you what to expect when the Fire Service College (FSC) collects personal information.

This privacy notice is a public declaration of how the FSC (Part of Capita Group plc) applies the Data Protection Principles & Rights afforded to individuals by the GDPR, to the personal data that we process.

FSC is committed to complying with the 6 principles relating to the processing of personal data under the GDPR in all that we do. These principles are:

• Lawfulness, fairness & transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Integrity and confidentiality

How we collect your information

We may collect your personal data in a number of ways, for example:

• From your organisation/employer who will be booking training or events on your behalf
• From the information you provide to us when you interact with us before arrival, for example updating your own information on our ‘My Learning Portal’
• When you apply to train at FSC and complete enrolment forms
• When you communicate with us by telephone, email or via our website, for example to make enquiries or raise concerns
• In various other ways as you interact with us during your time as a learner at FSC, for the various purposes set out below;

The types of information we collect

We may collect the following types of personal data about you:

• Your name, and contact information such as address, organisation, email address and telephone number, as well as your date of birth, gender, emergency contact details, national insurance number (or other tax identification number) and your passport number or national identity card details, country of domicile, your nationality and when providing work seeking opportunities, your CV. We will also allocate you a unique ID number
• Information relating to your enrolments, the courses or events you have or intended to attend and/or completed, dates of study and examination results. We will also keep records relating to assessments of your work, details of examinations taken and actual examination results and other information in your learner record
• Sensitive personal data and information including:
  • Information concerning your medical conditions or Mobility Impairment (e.g. disability)
  • Dietary Requirements

How we use your information

Visitors to our websites

When someone visits www.fireservicecollege.ac.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of cookies by the FSC

You can read more about how we use cookies on our Cookies page: https://www.fireservicecollege.ac.uk/cookies/

E-newsletter

We use a third-party provider, Mailchimp, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see the Mailchimp privacy notice.

Links to external websites

FSC website contains links to other websites. Please note that these links are intended for your convenience only.

Links to third party websites do not constitute endorsement, sponsorship or approval by the FSC of the content, policies or practices of those third-party websites.

This privacy notice does not cover the links within this site linking to other websites, if you have any concerns regarding your privacy when visiting a linked third party, you should ensure that you check the privacy statement/policies of those websites.

How we use information about our Learners

The purposes for which we may use personal data (including sensitive personal data) we collect during a learner’s association with us include:

• Educational matters, including:
• The provision of our core teaching and learning services (e.g. registration, assessment, attendance, managing progress, misconduct investigations, certification, graduation)
• Maintaining learner records
• Providing library, IT and information services
• Non-educational matters in support of our core services, including:
• Event management and attendance
• Safeguarding and promoting the welfare of learners
• Ensuring learners safety and security
• Managing learner accommodation
• Arranging learner transportation prior, during and/or after the course;
• Managing the use of social media
• Managing car parking on site
• Administering finance (e.g. invoicing, purchase orders, payments)
• Other administrative purposes, including:
• Recruitment
• Carrying out research and statistical analysis
• Carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations)
• Providing operational information (e.g. providing IT support, information about building closures or access restrictions on site or safety advice)
• Promoting our services (e.g. providing information about leisure centre or other events happening on and off site)
• Preventing and detecting crime
• Recording any near miss and actual accidents/injuries to comply with Health and Safety legal obligations
• Dealing with grievances and disciplinary actions
• Dealing with complaints and enquiries.

The lawful basis for processing your information and how we use it

We may process your personal data due to a legitimate business interest with your organisation/employer or with you, or in order to meet our contractual obligations. In this respect, we use your personal data for the following:

• To interact with you before you are enrolled as a learner, as part of the learner enrolment process (e.g. to send you a prospectus or answer enquiries about our courses)
• Once you have enrolled, to provide you with joining instructions which may include pre-assignment details as set out in our course prospectus
• To deal with any concerns or feedback you may have
• For any other purpose for which you provide us with your personal data.

We may also process your personal data because it is necessary for the performance of our tasks carried out in the public interest or because it is necessary for our or a third party's legitimate interests. In this respect, we may use your personal data for the following:

• To monitor and evaluate the performance and effectiveness of the FSC, including by training our staff or monitoring their performance
• To maintain and improve the educational, corporate, financial, estate and human resource management of the FSC
• To promote equality and diversity at the FSC
• To seek advice on our rights and obligations, such as where we require our own legal advice
• Recovering monies you owe to us
• For fundraising purposes.

We may also process your personal data for compliance with our legal obligations. In this respect, we may use your personal data for the following:

• To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws and safeguarding requirements
• For the prevention and detection of crime
• Reporting accidents and incidents for the Health & Safety Executive (HSE)
• In order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.

We may also process your personal data where:

• It is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional)
• It is necessary to protect your or another person’s vital interests, or
• We have your specific or, where necessary, explicit consent to do so.

Sharing information with others

For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties. Unless an opt-out is in place, we may disclose limited personal data to a variety of recipients including:

• Our employees, agents and associate trainers where there is a legitimate reason for their receiving the information, including:
• Associate trainers in relation to attendance logging, learner assessments and feedback
• Catering company in relation to dietary requirements
• Those with an interest in tracking learners progress and attendance, including:
• Current or potential employers (to provide references and, where learners are sponsored by their employer and/or where you take part in a placement, to provide details of progress/attendance);
• Professional and regulatory bodies (e.g. Skills for Justice, JOIFF or Pro Board etc) in relation to the confirmation of qualifications, professional registration and conduct and the accreditation of courses Government departments and agencies where we have a statutory obligation to provide information (e.g. HSE, the Home Office (in connection with UK visas and immigration)
• Crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards)
• Parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure).

Capita Sharing

We may share limited information with other Capita Businesses for legitimate purposes as part of our necessary obligations for internal reporting, processing of invoices and payments and to update existing customers of service and product updates or opportunities available within Capita plc Group.

Data Transfers outside of the EEA/EU and data portability

Information that we collect may be stored, processed and transferred between any of the countries in which we operate in or supply from in order to enable us to use the information in accordance with this privacy statement. International transfers outside of the EU, e.g. Capita India and the US will be managed under Privacy Shield agreed terms or via other adequate security assessments and data protection controls (including EU model clauses) to enable us to carry out our service obligations to our clients, suppliers and business partners.

How long your information is kept

Subject to any other notices that we may provide to you at the time of collecting your data, we may retain your personal data for a period of seven years after your association with us has come to an end or in accordance with our Data Retention periods. Where data is captured under a consent basis it will confirm the period specified at time of capture.

FSC only keeps data for as long as is necessary. Once the data has reached the end of its retention period the data is deleted. For further details on the Data Retention, please contact us using the details at the end of this document.

What do we use your data for?

FSC offers various services to the public. We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.

Security of your personal information

FSC takes information security extremely seriously. Significant investment has been made in all our systems to create the most secure environment possible.

We continue to take all reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information.

We will store all the personal information you provide on our secure (password- and firewall- protected) servers. All electronic transactions you make to or receive from us will be encrypted. We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in to our systems).

Job applicants, current and former FSC employees

FSC is the data controller for the information you provide during the process unless otherwise stated.

What information do we ask for, and why?

The information we ask for is used to assess your suitability for employment. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

What will we do with the information you provide to us?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

Use of data processors

Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Capita HR Services

If you are employed by FSC, relevant details about you will be provided to Capita HR Services who provide payroll services to FSC. This will include your name, bank details, address, date of birth, emergency contacts, National Insurance Number and salary.

Secondments

We also offer opportunities for people to come and work with us on a secondment basis. We accept applications from individuals or from organisations who think they could benefit from their staff working with us.

Applications are sent directly to the FSC. Once we have considered your application, if we are interested in speaking to you further, we’ll contact you using the details you provided. We might ask you to provide more information about your skills and experience or invite you to an interview.

How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of 12 months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

Information generated throughout the assessment process, for example interview notes, is retained by us for 12 months following the closure of the campaign.

Equal opportunities information is retained for 12 months following the closure of the campaign whether you are successful or not.

Your rights

The FSC recognises the further rights of data subjects under the GDPR which include;

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• More information on Direct Marketing
• The right to withdraw consent
• The right to complain to the Supervisory Authority
• Rights related to automated decision making and profiling

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/  

Complaints or queries

FSC tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of FSC’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

How to make a complaint to us

If you want to make a complaint or query about the way we have processed your personal information, please contact the Compliance Officer using the details found at the bottom of this document.

Alternatively, if you are unhappy with our response, you have the right to complain to the Supervisory Authority, the details of which are below:

Supervisory Authority: Information Commissioner’s Office (ICO)

Website: https://ico.org.uk/concerns/

Email: casework@ico.org.uk                                                     

Telephone: 03031231113

Subject Access Request Process

You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to:

• The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
• The description of the exact information you are seeking.

FSC will work collaboratively with our clients to ensure that we fulfil all obligations under the Data Protection Act and GDPR regarding subject access requests. We may withhold such personal information to the extent permitted by law.

How to contact us

If you want to request information about our privacy policy, if you have a complaint or wish to execute a right, you can contact us by:

Writing to:

The Compliance Officer

The Fire Service College

London Road

Moreton in Marsh

Gloucestershire

GL56 0RH

Or by email to: ComplianceOfficer@fireservicecollege.ac.uk

Or by phoning Reception on: 01608 650831 and asking for FSC Compliance Officer.

The Fire Service College Limited is a registered data processor under the Information Commissions Office – Reg.no. Z3584953

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 9 May 2018.