Privacy Notice
1. Purpose
This Privacy Notice explains how ATC Training Limited collects, uses, stores and shares personal data relating to learners, prospective learners, customers and other individuals who interact with us.
It also explains your rights in relation to your personal data and how to contact us or the Information Commissioner’s Office (ICO) if you have a concern.
ATC Training Limited processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.
2. Who We Are
Data Controller: ATC Training Limited
Registered Office: Amber Court, William Armstrong Drive, Newcastle upon Tyne, NE4 7YA
ICO Registration Number: ZA780195
ATC Training Limited is responsible for determining how and why personal data covered by this Privacy Notice is processed.
Where training or services are provided by another company within the ATC Group, that company may be the relevant data controller and additional or alternative privacy information may apply.
3. Personal Data We Collect
The personal data we collect will depend on your relationship with us and the training or services being provided.
This may include:
- name, address, telephone number and email address;
- date of birth, nationality and identification information where required;
- employer or sponsoring organisation details;
- qualifications, prior attainment and employment information;
- course enrolment, attendance and participation records;
- assessment results, examination results and certification information;
- assignments, assessment evidence and other learner submissions;
- course progress and completion records;
- communications with tutors, assessors and other ATC personnel;
- reasonable adjustment, accessibility or additional support information;
- images, audio or video recordings where required for training, assessment or quality assurance;
- payment, transaction and limited financial information;
- records of meetings, courses or events attended;
- feedback, complaints, appeals or other correspondence; and
- technical and account information associated with our websites, learning platforms and other systems.
We will only collect personal data that is appropriate for the purpose for which it is required.
4. Special Category Personal Data
In some circumstances we may need to process information that is considered special category personal data under data protection legislation.
This may include information relating to health, disability or other circumstances where it is necessary to provide learner support, consider a reasonable adjustment, meet a legal or regulatory requirement, or safely deliver training and assessment.
Special category personal data will only be processed where an appropriate lawful basis and additional condition for processing applies.
5. How We Use Your Personal Data
We may process personal data to:
- respond to enquiries and applications;
- process purchases and enrol learners;
- create and administer learner accounts;
- provide training, learning and assessment services;
- verify identity, qualifications and entry requirements;
- monitor attendance, participation and course progress;
- conduct examinations and assessments;
- provide learner support and reasonable adjustments;
- undertake internal and external quality assurance;
- register learners with awarding organisations or other relevant bodies;
- process results and certification;
- communicate with learners and customers;
- maintain qualification and training records;
- process payments and manage accounts;
- prevent and investigate malpractice, fraud or misuse of our services;
- respond to complaints and appeals;
- meet safeguarding, health and safety or regulatory responsibilities;
- maintain the security and integrity of our systems and services;
- monitor and improve the quality of our training and services;
- meet legal, regulatory, awarding organisation and approval requirements; and
- undertake appropriate marketing and business communications.
6. Our Lawful Bases for Processing
The lawful basis we rely upon will depend on the purpose for which personal data is being processed.
Contract
We may process your personal data where this is necessary to enter into or perform a contract with you. This includes activities such as enrolment, provision of training, assessment, learner account administration, customer support and delivery of purchased services.
Legal Obligation
We may process personal data where necessary to comply with legal obligations, including applicable financial, taxation, regulatory and record-keeping requirements.
Legitimate Interests
We may process personal data where this is necessary for our legitimate business interests and those interests are not overridden by your rights and interests.
This may include appropriate business administration, maintaining records, quality assurance, service improvement, fraud prevention, system and information security and certain business communications.
Consent
Where appropriate, we may ask for your consent to undertake a particular processing activity. Where processing is based on consent, you may withdraw your consent at any time.
Other lawful bases may apply where permitted or required by data protection legislation.
7. Learning Records Service
Where applicable to your course or qualification, information you provide may be shared with the Learning Records Service (LRS).
The LRS issues Unique Learner Numbers (ULNs) and maintains Personal Learning Records. It is operated on behalf of the Department for Education.
Further information about how the LRS processes personal information and how you can access your Personal Learning Record is available through the relevant LRS privacy notice published on GOV.UK.
8. Sharing Your Personal Data
We will only share personal data where there is an appropriate reason and lawful basis for doing so.
Depending on the course or service concerned, information may be shared with:
- awarding organisations and qualification bodies;
- regulators and approval bodies, including Ofqual, the Civil Aviation Authority (CAA) and OPITO where applicable;
- the Department for Education, Learning Records Service and other government or public bodies where applicable;
- your employer, sponsor or organisation commissioning your training, where appropriate;
- tutors, assessors, Internal Quality Assurers and other authorised personnel;
- learning management system, technology, hosting and IT service providers;
- payment service providers;
- professional advisers and auditors;
- debt recovery providers where necessary;
- regulatory, government or law enforcement authorities where required; and
- other organisations where sharing is necessary to provide the service, meet an applicable requirement or protect our legitimate interests.
Where an employer, sponsor or other organisation has purchased or commissioned training on your behalf, we may provide relevant information to that organisation. This may include information relating to your enrolment, attendance, participation, progress, assessment outcome, completion or certification where there is an appropriate basis for doing so.
We do not sell personal data and will not provide your personal data to another organisation for that organisation’s own marketing purposes without an appropriate lawful basis.
9. Service Providers
We use third-party systems and service providers to support the delivery and administration of our services.
These may include providers of:
- learning management systems;
- website and hosting services;
- email and communications;
- customer and learner administration systems;
- assessment and examination systems;
- cloud storage and productivity systems;
- payment processing;
- electronic signatures;
- remote assessment or invigilation; and
- other business and technology services.
Where another organisation processes personal data on our behalf, we will use appropriate contractual and organisational controls in accordance with applicable data protection requirements.
10. International Transfers
Some of our service providers, systems or ATC Group activities may involve personal data being accessed, stored or processed outside the United Kingdom.
Where personal data is transferred internationally, we will take appropriate steps to ensure that the transfer complies with applicable data protection legislation. Where required, this may include use of recognised adequacy arrangements, contractual safeguards or another permitted transfer mechanism.
11. How Long We Keep Personal Data
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to meet applicable legal, contractual, regulatory, awarding organisation and approval requirements.
Different types of records may therefore be retained for different periods.
When determining an appropriate retention period, we may consider:
- the nature and purpose of the record;
- applicable legal and taxation requirements;
- awarding organisation or qualification requirements;
- regulatory or approval requirements;
- certification and verification requirements;
- contractual obligations;
- the need to respond to complaints, appeals or legal claims; and
- legitimate operational and business requirements.
Personal data that is no longer required will be securely deleted, anonymised or otherwise disposed of in accordance with our data retention arrangements.
12. Security of Your Personal Data
ATC Training Limited maintains appropriate technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or destruction.
Access to personal data is restricted according to business need and the responsibilities of the individuals concerned.
Further internal controls relating to data protection, information security, systems and records are maintained through ATC Training’s Data Protection and GDPR Policy, IT Policy and associated procedures and controls.
13. Your Rights
Depending on the circumstances and the lawful basis being relied upon, you may have the right to:
- request access to personal data we hold about you;
- request correction of inaccurate or incomplete personal data;
- request deletion of your personal data;
- request restriction of processing;
- object to certain processing;
- request transfer of your personal data in a portable format where applicable;
- withdraw consent where processing is based on your consent; and
- raise a concern about how your personal data is being processed.
These rights are not absolute and exemptions or restrictions may apply in certain circumstances.
We may need to verify your identity before responding to a request.
14. Marketing
We may communicate with existing and prospective customers about courses, services or other relevant opportunities where we have an appropriate lawful basis to do so.
Where consent is required for electronic marketing, we will obtain it before sending the relevant communication.
You may opt out of marketing communications at any time by using the unsubscribe facility provided in the communication or by contacting us.
Opting out of marketing will not prevent us from sending communications that are necessary to administer your account, course, qualification, order or other service.
15. Cookies and Website Information
Our websites may use cookies and similar technologies for purposes such as providing website functionality, maintaining security, understanding website usage and supporting marketing activities where permitted.
Further information about the cookies used, their purposes and available choices is provided through the applicable Cookie Policy and cookie consent arrangements on our website.
16. Raising a Concern or Exercising Your Rights
If you have a question about how we process your personal data, wish to exercise one of your data protection rights or have a concern about our use of your information, please contact:
ATC Training Limited
Amber Court
William Armstrong Drive
Newcastle upon Tyne
NE4 7YA
Email: info@atctraining.co.uk
We will respond to data protection requests in accordance with applicable legal requirements.
17. Complaints to the Information Commissioner’s Office
If you are dissatisfied with the way ATC Training Limited has handled your personal data, you also have the right to raise a complaint with the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.
Information about making a complaint and exercising your data protection rights is available from the ICO website at ico.org.uk.
18. Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes to our activities, systems, legal requirements or the way in which personal data is processed.
The current version will be published on our website.