Community learning and skills - partners and organisations privacy notice
We keep this privacy notice under regular review, and it was last updated in August 2022
Kent County Council 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 and tell you about your privacy rights and how the law protects you.
Who we are
Kent County Council (KCC) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.
Community Learning and Skills (CLS) provides learning opportunities for adults, young people, and families across Kent in order to meet their aspirations for improved work skills, better personal development, strong families, and healthy creative lives. We engage with local communities throughout Kent to provide educational services which match the needs of local communities based on levels of prosperity, employment, and priorities. CLS works in an integrated way with other teams in KCC and with partner organisations to ensure that our services provide learning appropriate to the needs of individuals and families at various stages in their lives. Please see the Community Learning and Skills main privacy notice for further information regarding how we process your data.
Personal information we collect and use
Information collected by us
In the course of enquiries, engagement, planning and delivering services to you and your organisation we collect the following personal information when you provide it to us:
- personal information: such as name, job title and contact details
- personal information: the name and contact details of your employee or apprentice before they become an enrolled learner with us and the organisation name and contact details that you are associated with
- information related to our relationship with you (such as agreements, correspondence, meeting notes and attendance at events)
- bank details where applicable
- opt-in requests or consent to receive Newsletters and notifications about services on offer from Community Learning and Skills (CLS), or from one of our brands, Kent Adult Education, Kent Training and Apprenticeships or Skills.
- commercial information about your organisation (such as liability insurance, risk assessments and company number if applicable).
We also collect the following ‘special category data’ when you provide it to us:
- information related to our relationship with you (non-contact/absence reasons such as illness, if you have chosen to disclose this to us).
How we use your personal information
We use your personal information to:
- engage with you and your organisation, including your organisational preferences and requirements, for invoice or sponsorship payments, and if you have agreed to support a young person with work experience
- provide you and your organisation with information, advice and to promote further learning opportunities, and to inform you of special offers, promotions, website changes, and new services that may be of interest, if you have consented for us to do so
- work with other teams and organisations to ensure appropriate learning, employment and career opportunities are accessible to your organisation and staff (if applicable)
- monitor, report, and meet with agreed managers/staff within your organisation on individuals progress, to support and provide appropriate pastoral care for individuals from who you have requested training or are following an apprenticeship programme
- evaluate and quality assure the services we provide and contact you for feedback or evaluation on any of our services or courses delivered
- undertake analysis, profiling, or statistical research for marketing purposes and to plan new services or courses
- use your images or quotes for good news information stories or promotional material if you have consented for us to do so
- investigate and respond to any communication, complaint or request made by you
- create and/or provide you access to on-line platforms or products that will be used in the delivery of services you have requested from us investigate and process any Safeguarding or Prevent issues that may be relevant.
Where you have consented to receiving marketing communications from us, by selecting the relevant consent options at enrolment, we may use your personal data to send you targeted emails for marketing purposes.
We send emails to individuals and organisations with whom we want to develop or maintain a relationship with, in accordance with applicable data protection and marketing laws. This may include information about events, new and upcoming courses, surveys, and topical updates.
If you have consented to receive marketing communications, we may use some of your personal anonymised data, such as age, postcode, and gender to create a profile of the potential interests and needs of the wider community.
We use Campaign Monitor to manage our email updates to our learners. Campaign Monitor uses page tags and web beacons for the purposes of tracking visitors as they use an email. For example, web beacons track whether an email sent through Campaign Monitor was delivered and opened and whether links within the email were clicked. This information is collected for the purposes of providing email campaign performance information and measuring the performance of email messages sent.
Find out more information about Campaign Monitor cookies by visiting the Campaign Monitor website.
Reasons we can collect and use your personal information
When we collect your personal data, we rely on the following lawful basis:
- Article (6)(1)(a) - Consent: the individual has given clear consent to process their personal data for a specific purpose
- Article (6)(1)(f) - Legitimate interests: the processing is necessary for legitimate interests or the legitimate interests of a third party
Our Legitimate interests are:
- We need to collect and process data and retain records in order to fulfil our functions as an education provider and to maintain our relationship with our Learners and the wider community, providing the best possible educational and societal benefits.
When we collect or share special category personal data, we rely upon the following legal basis under UK GDPR:
- Article 9(2)(a) - Explicit consent
How long your personal data will be kept
We will hold your personal information securely and retain it for no longer than 14 years from your last enrolment with CLS in line with central Government audit requirements, after which the information is made inaccessible to system users or securely destroyed.
Who we share your personal information with
We share information with:
- teams within Kent County Council working to improve outcomes for children and young people
- commissioned providers of local authority services (such as education services, call centre and payment services)
- The Education and Skills Funding Agency (ESFA)
- Matrix standard
- End Point Assessment Organisations
This data sharing enables us to provide you with high quality services, training, and employment opportunities.
We will share personal information with law enforcement or other authorities if required by applicable law or in connection with legal proceedings.
We transfer your data to the following countries or organisations outside the UK:
This is based on Safeguards prescribed by the UK GDPR. For a copy email CLSGDPR@kent.gov.uk.
Under UK GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (subject access request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioners Office
- withdraw consent at any time (if applicable)
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individuals’ rights under GDPR.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at firstname.lastname@example.org.
Your Right to Withdraw your Consent
Where we rely on your consent to process your personal information, you can withdraw your consent to our use of your data at any time.
You can do this by emailing CLSGDPR@kent.gov.uk.
For marketing and promotional information, you can also click on any of the unsubscribe links within our marketing materials.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Who to contact
Please contact the Information Resilience and Transparency Team at email@example.com to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at firstname.lastname@example.org, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.
If you would like to get a copy of the information about you that KCC shares with the ESFA or DfE or post-16 providers or how they use your information, please contact the Information Resilience and Transparency Team at email@example.com.
Read our corporate privacy statement.