PRIVACY POLICY

This privacy policy sets out how SLT Education (Fitness Industry College), part of the SLT Group uses and protects any information that you give when enquiring, enrolling and studying with any SLT Education service.

SLT Education is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using a SLT Education service, you can be assured that it will only be used in accordance with this privacy statement.

SLT Education may change this policy from time to time by updating the information on its Websites. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 17th May 2018.

1.    SCOPE

As part of the SLT Group, SLT Education are committed to safeguarding the privacy of our learners and service users. In this policy we explain how we will treat your personal information.

All our processes and procedure regarding the collection and distribution of personal data have a key driver to demonstrate a commitment to protecting an individual’s privacy. There are various ways that you might interact with SLT Education (Fitness Industry College), and the information you provide when doing so allows us to improve our services. By using this website and our related websites (collectively, the “Site”) and by supplying your details to SLT Education, you consent to SLT Education collecting and processing your information.

2.    AIMS

The aims of this document are to explain:

  • What information we collect, and why we collect it
  • How we use that information
  • The categories of personal data collected
  • Your rights as a Data Subject
  • Obtaining your Consent
  • How we protect that information
  • How you can control your information, including accessing, updating and deleting what we store
  • How we share information collected
  • Your rights to lodge a complaint

3.    COLLECTING AND SHARING PERSONAL INFORMATION

Through our day-to-day business interactions with prospects and learners, SLT Education may collect or record the following personal and / or sensitive information.

Prospective Learners personal and / or sensitive data.

  • Personal information (such as name, gender, date of birth, address, email address, contact number)
  • Details of parents / carers (such as name, relationship, email address & contact number
  • Characteristics such as your ethnic background or any special education needs
  • Any medical conditions you have
  • Photographs
  • Applications for courses

Enrolled learners personal and / or sensitive data

  • Personal information (such as name, gender, date of birth, address, email address, contact number, passport details, national insurance number)
  • Details of parents / carers (such as name, relationship, email address & contact number
  • Characteristics such as your ethnic background or any special education needs
  • Any medical conditions you have
  • Photographs / Video Footage
  • Assessment information (course grades and marks)
  • Your GCSE and College grades and results
  • Details of behaviour issues or exclusions

SLT Education currently utilise software and services from the following external companies to deliver our main obligated services to our customers;

  • Engage – Learners online education platform
  • Exerp (Clublead – Pulse Fitness) – Fitness Membership management
  • Team App – Training, Matchday and Enrichment communications
  • VirtuaGym – Fitness Member App
  • Revitalize – FREE community health & wellbeing platform
  • Graphitas – Web Developers
  • Campaign Monitor – Learner and Propsect Communications, newsletters and updates
  • AOC College & FA Portals – Sports registration details to be eligible to compete

The above companies are designated as Data Processors. SLT Education remain the Data Controller of all personal data.

We do not share personal information about you with anyone outside of SLT Education without permission from you or your parents/carers, unless the law and our policies allow us to do so. Where it is legally required, or necessary for another reason allowed under data protection law, we may share personal information about you with:

  • Local Authorities
  • The Department for Education (a government department)
  • Your family and representatives
  • Our regulator OFSTED
  • Financial organisations
  • Central and local government
  • Our auditors
  • Health authorities
  • Health and social welfare organisations
  • Professional advisers and consultants
  • Police forces, courts, tribunals
  • Professional bodies

SLT Education may also post links to third party websites as a service to you. These third party websites are operated by companies that are outside of our control, and your activities at those third party websites will be governed by the policies and practices of those third parties. We encourage you to review the privacy policies of these third parties before disclosing any information, as we are not responsible for the privacy policies of those websites.

4.    USING PERSONAL INFORMATION

SLT Education uses the information we collect to provide you with services which you request and to improve our existing services and the content of our Site.

Why we use this data

  • Support student learning
  • Support Student Progression
  • Support Student Recruitment
  • Monitor and report on student progress
  • Provide appropriate pastoral care
  • Protect student welfare
  • Assess the quality of our services
  • Carry out research
  • Comply with the law regarding data sharing
  • Track how well SLT Education as a whole is performing
  • Look after your wellbeing
  • Get in touch with prospects, learners and parents when we need to
  • Provide prospects, learners and parents with communication updates (e-news, letters)
  • Ensure appropriate advice and guidance regarding course enrolments
  • Ensure appropriate advice and guidance on career pathways

Where we have got permission to use your data, you or your parents/carers may withdraw this at any time. We will make this clear when we ask for permission and explain how to go about withdrawing consent.

Some of the reasons listed above for collecting and using your information overlap, and there may be several grounds which mean we can use your data.

SLT Education may also use or disclose your personal information when SLT Education believes, in good faith, that such use or disclosure is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user/service agreements, or (iii) protect the rights, property or safety of SLT Education, SLT Education’s users, or others. SLT Education reserves the right to transfer and disclose your information if SLT Education becomes involved in a business divestiture, change of control, sale, merger, or acquisition of all or a part of its business. 

5.     WEB USER TRACKING (USE OF COOKIES, IP ADDRESSES AND AGGREGATE INFORMATION)

Cookies are a technology that can be used to help personalise your use of a website. A cookie is an element of information that a website can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or decline at any time. To enable SLT Education to assess the effectiveness and usefulness of this Site, and to give you the best user experience, we collect and store information on pages viewed by you, your domain names and similar information. Our Site makes use of anonymous cookies for the purposes of:

  • Completion and support of Site activity
  • Site and system administration
  • Research and development
  • Anonymous user analysis, user profiling, and decision-making.

An Internet Protocol (“IP”) address is associated with your computer’s connection to the internet. SLT Education may use your IP address to help diagnose problems with the server, to administer the Site and to maintain contact with you as you navigate through the Site. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Site.

Aggregate information is used to measure the visitors’ interest in, and use of, various areas of the Site and the various programs that SLT Education administers. SLT Education will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, SLT Education may undertake statistical and other summary analyses of the visitors’ behaviours and characteristics. Although Sentinel Leisure Trust may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

6.    YOUR RIGHTS AS A DATA SUBJECT

The Data Subject is the person or persons SLT Education hold any information on and for. As the Data Subject, you can be assured that:

  • The Data Subject has the right to Access personal details upon request
  • The Data Subject has the right to rectify any inaccuracies within their data
  • The Data Subject has the right to have all their personal data erased (right to be forgotten)
  • The Data Subject has the right to rectifying any processing of their personal data
  • The Data Subject has the right to obtain a copy of their personal data in a commonly used format and have it transferred to another controller
  • The Data Subject has the right to object to the processing of their personal data
  • The Data Subject has the right to object to any automated decision making
  • The Data Subject has the right to compensation for damages caused by infringements of the Regulation from the Data Controller or Data Processor

All requests by the Data Subject to petition any of the above Rights should be, in the first instance, raised with the Data Protection Officer, [email protected] .

7.    DATA PROTECTION PRINCIPLES

Under the GDPR Sentinel Leisure Trust is committed to ensuring that:

  • personal data is processed lawfully, fairly and in a transparent manner
  • personal data is collected for specific, explicit and legitimate purposes
  • personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
  • personal data is accurate and, where necessary, kept up to date and all inaccuracies having regard to the purposes for which is was collected are erased or rectified at the first opportunity
  • personal data is kept no longer than is necessary for the purpose for which it was collected
  • personal data is processed in a manner that ensures appropriate security and personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage using appropriate technical or organisational methods
  • personal data is limited to what is necessary in relation to the purpose for which is was collected, adequate and relevant
  • personal data is collected and processed in a legal manner in relation to consent, categories of personal data, contract and legal obligations, Legitimate, Vital and Public interests and process documentation.

8.    CONSENT

Giving Consent to SLT Education will only be undertaken where the individuals have:

  • a genuine choice and level of control over how your data is used
  • the right to ONLY opt-in to give consent with no pre-ticked or implied consent options
  • individuals are made fully aware of what they are consenting to
  • the right to withdraw consent at any time by speaking to a member of staff, emailing [email protected]ootballindustrycollege.com or [email protected] or changing your preferences on any email marketing communication you receive.
  • the right to know the purpose of collecting and processing your data

SLT Education will hold a copy of your consenting action in relation to who consented, when and how you were told. This information will be kept by SLT Education as long as is deemed appropriate.

Special categories of data, defined by the GDPR as data which may be ‘particularly sensitive in relation to fundamental rights and freedoms’ and deserve specific protection, will only be requested for specific and documented reasons. Any special categories of Data requested will only follow an affirmative and explicit action by the customer to give consent for this data to be collected.

All third parties who partner SLT Education will be verified as offering a good standard of data security for SLT Education customer information, meeting the necessary requirements for GDPR before any partnership agreement is undertaken.

9.    COLLECTING AND USE OF EMPLOYEE PERSONAL INFORMATION

We also collect personal information from our employees and from job applicants (human resource data) in connection with administration of our human resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance, review and development processes, training, access to our facilities and computer networks, employee profiles, employee directories, human resource recordkeeping, and other employment related purposes. It is the policy of SLT Education to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

  • To comply with local, regional, national contractual legislation requests
  • Inquiries from third parties with a signed authorisation from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below)
  • Third parties with which SLT Education has contractual agreements to assist in administration of company sponsored benefits

Prospective employers, government agencies, financial institutions, and residential property managers routinely contact SLT Education requesting information on a former or current employee’s work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the People Solutions team or payroll department. For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee’s signed authorisation to release information. The form will be returned directly to the requesting party and filed as part of the People Solutions or payroll department’s confidential records.

10.    SECURITY

The security of your personal information is important to us. We follow generally accepted best practice industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

SLT Education uses all reasonable measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained, and follows applicable laws regarding safeguarding any such information under our control. In addition, in some areas of our Sites, SLT Education may use encryption technology to enhance information privacy and help prevent loss, misuse, or alteration of the information under SLT Education control. SLT Education also employs industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.

No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, SLT Education cannot guarantee the absolute security of your information. The Internet by its nature is a public forum, and SLT Education encourages you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.

11.    MONITORING AND ENFORCEMENT

SLT Education regularly reviews our compliance with our privacy policy. We also adhere to several self-regulatory frameworks in addition to complying with applicable law. If we receive formal written complaints, we will follow up with the person making the complaint. We work with the appropriate regulatory authorities to resolve any complaints that cannot be resolved directly.

12.    COMPLIANCE

As part of the SLT Group (Sentinel Leisure Trust) SLT Education adheres to the European Union (“EU”) Data Protection (95/46/EC) and e-Privacy (2002/58/ED) Directives, the Data Protection Act 1998 and the General Data Protection Regulations. Sentinel Leisure Trust does, for legitimate business reasons, transfer minimal data outside the EU and all/any company operating or storing information in the US will be required to comply to European Union (“EU”) Data Protection (95/46/EC) and e-Privacy (2002/58/ED) Directives, the Data Protection Act 1998 and the General Data Protection Regulations or have signed up to the US Privacy Shield.

13.    DATA PROTECTION (UK)

As part of the SLT Group (Sentinel Leisure Trust) SLT Education is registered as a Data Controller under the Data Protection Act: Certificate of Registration number A8313090.

14.    INFORMATION PROCESSOR ACTIVITIES

SLT Education operates as an information Data Controller for our business customers located in the EU. Sentinel Leisure Trust’s business customers remain the information controllers with respect to any EU Customer Information that they provide to Sentinel Leisure Trust for our provision of services. SLT Education therefore acts in accordance with the instructions of such customers regarding the collection, processing, storage, deletion and transfer of EU Customer Information, as well as other matters such as the provision of access to and rectification of EU Customer Information.

Individuals may contact the Data Protection Officer identified below to review any personal information held about them. SLT Education reserves the right to take reasonable steps to authenticate the

identity of any such individual seeking access to such personal information. Questions, comments, or access requests regarding EU Personal Information should be directed to the Data Protection Officer identified below.

 15.    RETENTION OF PERSONAL DATA

SLT Education will only continue to hold personal data for a reasonable time to a point where the data is no longer required or used. At such a point, some of the personal data may be retained for a longer period for eg: statistical and performance analysis.

16.     ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

If you have provided SLT Education with your personal information, you have the right to inspect the information stored by us for accuracy, or may request that the information be removed from our records. Sentinel Leisure Trust will make all reasonable efforts to comply with such requests except where it would require a disproportionate effort (for example developing a new system or changing an existing practice). We may require that you verify your identity before we act on a request to edit or remove your information. Please direct any questions about your Personal Information to [email protected] .

17.    SOCIAL MEDIA AND ONLINE ENGAGEMENT

We use a variety of new technologies and social media options to communicate and interact with learners, potential learners, employees and potential employees. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, SLT Education use certain third-party platforms including, but not limited to, Facebook, Twitter, Instagram, Youtube and LinkedIn.

Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by SLT Education. When interacting with the SLT Education presence on those websites, you may reveal certain personal information to SLT Education or to third parties. Other than when used by SLT Education employees for the purpose of responding to a specific message or request, SLT Education will not use, share, or retain your personal information.

 18.    CHANGES TO THIS PRIVACY POLICY

SLT Education may change this privacy policy from time to time. If this privacy policy changes, the revised privacy policy will be posted at the “Privacy Policy” link on the Site’s home page. In the event that the change is significant or material, we will notify you of such a change by revising the link on the home page to read “Newly Revised Privacy Policy.” Please check the privacy policy frequently. Your continued use of the Site constitutes acceptance of such changes in the privacy policy, except where further steps are required by applicable law.

19.    CONTACTING SLT EDUCATION (SLT GROUP)

 Questions regarding this privacy policy should be directed to [email protected] of which will be forwarded to the Director of Education. Receipt of the question or complaint will be acknowledge, and a investigation will commence, and a response shall be sent within 21 days.

Individuals wishing to ask us to cease processing personal data should also be forwarded to the Director of Education. The request will be acknowledged, and action taken where appropriate (or responded to) within 21 days.

 If a complainant remains dissatisfied with the outcome of his/her complaint, he/she may seek an independent review from the Information Commissioner’s Office (ICO).  This is the independent body responsible for overseeing the DPA.  The ICO can be contacted at:

The Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

FURTHER INFORMATION)

More information about the Data Protection Act 1998 is available on the Information Commissioner’s website at www.ico.gov.uk

 

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