Lifecykle Consulting Ltd Trainer Privacy Notice

Introduction

Lifecykle Consulting, also trading as ‘DrivingCPC’ (we, us, our) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you apply to become a trainer with us. It also tells you about your privacy rights and how the law protects you. This privacy notice supplements our other privacy policies and is not intended to override them.

Important information and who we are

Purpose of this privacy notice

This privacy notice will inform you as to how we look after your personal data when you apply to become a trainer with us. It also tells you about your privacy rights and how the law protects you. This privacy notice supplements our other privacy policies and is not intended to override them.

It is important that you read this privacy notice together with our privacy notice on our website and any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using your data.

Controller

Lifecykle Consulting Ltd, (we, us or our) is the controller and responsible for your personal data in this privacy notice.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice, whose contact details are below should you have any questions about this privacy notice, including any requests to exercise your legal rights:

Contact details

Data Protection Officer: Dean Pask


Lifecykle Consulting Ltd (also trading as DrivingCPC)
Email address: This email address is being protected from spambots. You need JavaScript enabled to view it.
Postal address: 27, Old Gloucester Street, London, WC1N 3AX United Kingdom
Telephone: 0800 7765975

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 20 February 2019.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes name (first and last name).
  • Contact Data includes email address, organisation (where applicable) and telephone numbers.
  • Driving License Data includes Driving License number and License Category.
  • Qualifications and Experience Data includes training related experience, qualifications and competency.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, for you to deliver one of our authorized courses or to gain authorization for a course you wish to deliver). In this case, we may have to reject your application with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • complete the request for contact forms on the website (see privacy notice on our website);
    • apply to become a trainer;
    • apply to deliver a new course;
    • give us some feedback.

 

How we use your personal data

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

  • Where you have asked us to contact you.
  • Where we need to perform the contract (to provide goods or services), we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

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

Purposes for which we will use your personal data

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

Note that we may process your personal data for more than one lawful ground 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To respond to your request to contact you

(a)    Identity

(b)    Contact

Solicited communication

Process your application to become a trainer and/or authorise a new course

(a)    Identity

(b)    Contact

(c)    Marketing and Communications

(d)    Driving License

(e)    Qualifications and Experience

 

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation

Update to Driving Authority of Training Competency

(a)    Identity

(b)    Driving License

(c)    Qualifications and Experience

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation

To manage our relationship with you which will include notifying you about changes to our terms or privacy notice

(a) Identity
(b) Contact

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation

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

In order to enter into contract with you we will need to provide your driving license, experience and qualifications data to JAUPT or FORS to gain approval for delivery of the course. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with. In this case, we may have to cancel your application with us but we will notify you if this is the case at the time.

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.

International transfers

We have ensured that the information you share with us is stored and hosted in the UK.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our trainers for six years after they cease being trainers for tax purposes. In some cases, we hold on to trainer related data until the statutory limitation period for bringing claims has passed.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We will keep basic information where you have enquired about or applied to be a trainer with our organization for 12 months in case you wish to proceed with any application at a later date. You have the right to request erasure of your personal information at any time.

Your legal rights

Under certain circumstances, 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 or email us at This email address is being protected from spambots. You need JavaScript enabled to view it.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 



Driving CPC is a division of Lifecykle Consulting Ltd. Registered in England No 11586347
Registered Address: 27, Old Gloucester Street, London, WC1N 3AX United Kingdom.
Telephone 0200 8881788, This email address is being protected from spambots. You need JavaScript enabled to view it.