1. STATEMENT OF PURPOSE
1.1 Asset-Wisdom Ltd (AW) 08662804 provides on-line training and learning solutions to corporate customers, resellers and individuals on a global basis. In providing these services, AW collect, use and disclose personal information. Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is either identified or reasonably identifiable.
1.3 AW are required to comply with the UK Data Protection Act of 1998 and the GDPR of 2018 as set out in our Policy No AW005. The APPs regulate the manner in which personal information is handled.
1.4 AW will grow and provide services to corporate customers and individuals based globally, this policy will be updated to ensure that AW complies with the data protection requirements of each country and where appropriate individual states and counties.
2. WHAT TYPE OF INFORMATION IS COLLECTED?
2.1 Personal Information
2.1.1 The type of personal information that AW collect and hold about an individual depends on the type of dealings they have with AW. If we need to identify or verify an individuals’ identity, AW may collect their name, gender, date of birth, driver’s licence and/or passport details, student ID number, username, password, security question and answer. If AW need to communicate with an individual, AW may collect their email, residential and postal addresses and telephone numbers. If an individual applies to enrol in a training course or otherwise access AW’s services, we may collect details of their employment and employer, training history, qualifications, banking and payment details.
2.1.2 To help AW improve its services, we may collect an individual’s response to surveys and details about how, when and why they access AW’s services.
2.1.3 If an individual applies for a job with AW, we will collect the information they include in their application.
2.2 Sensitive information
2.2.1 Sensitive information is personal information such as health information and information about racial or ethnic origin that is generally afforded a higher level of privacy protection.
2.2.2 AW only collect sensitive information where it is reasonably necessary for our business functions and the individual have consented, or AW are required to do so by law.
2.3 Information other than personal information (“non-personal information”)
2.3.1 Website information
When an individual visits AW’s website, some of the information that is collected about their visit is not personal information, because it does not reveal their identity. AW use this information to help us improve our services. AW may aggregate this information for our own statistical purposes. Provided that it remains anonymous, AW may disclose that aggregated information to third parties or publish it for marketing or research purposes.
2.3.2 Site visit information
AW may record an individual’s server address, the date, time and duration of their visit, search terms they used, the pages they viewed, any documents they downloaded and the type of device, browser and operating system they used.
A cookie is a small string of information that a website transfers to an individual’s browser for identification purposes. The cookies AW use do not identify individual users.
Most internet browsers are set to accept cookies. If an individual prefers not to receive them, they can adjust their internet browser to reject cookies, or to notify them when they are being used. Rejecting cookies can, however, limit the functionality of AW’s websites.
3. HOW IS PERSONAL INFORMATION COLLECTED?
3.1 Methods of collection
AW will collect personal information by lawful and fair means as required by the Privacy Act. AW will also collect personal information directly from an individual where this is reasonable and practicable.
AW collect personal information in various ways, including:
i. directly from the individual in person, over the phone, through written communications (either on paper or electronic) or by you completing forms or answering questions on AW’s websites;
ii. from third parties, including an individual’s employer, direct marketing database providers, government agencies, AW related companies and their authorised representatives;
iii. from AW’s own records of an individual’s use of our services.
3.2 Collection notices
Where AW collect personal information directly from an individual, we will take reasonable steps to notify them of certain matters in a collection notice. AW will do this at or before the time of collection, or as soon as practicable afterwards.
Where AW collect information about an individual from their authorised representative, we will take reasonable steps to make sure that they are made aware of the collection.
If an individual provides to AW personal information about someone else (as their authorised representative), we rely on them to inform the representative that they are providing their personal information to AW and to advise them that AW can be contacted for further information.
3.3 Quality of information
When entering any information, it is important that an individual makes sure that it is accurate and up to date. They are responsible for the quality of the information they enter and must update it as and when it is necessary.
As and when an individual cease to use AW’s systems, it is important that they ask AW to remove any data that we hold.
4. WHY COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?
The main purposes for which AW collect, hold, use and disclose personal information are:
i to identify the individual and verify their identity;
ii to communicate with the individual about AW services;
iii to provide AW services to individuals, including:
• facilitating their enrolment in online training;
• facilitating their access to online training materials;
• facilitating their communications with others via AW’s website; and
• obtaining payment for AW services;
iv for purposes required or authorised by or under law;
v to help AW improve our services;
vi for any other purposes that the individual has consented to.
4.2 Direct marketing
4.2.1 Where AW have an individual’s express or implied consent, or where we are otherwise permitted by law, AW may use their personal information to send them information about the services AW offer, as well as other information. AW may send this information by mail, email, SMS and telephone.
4.2.2 Opting out – An individual can opt out of receiving these communications at any time, in the following ways:
i. if they have an online account via AW’s website, they can update their communications preferences by logging in to their account and following the instructions on AW’s website;
ii. contact AW (see section 10 below) and tell us;
iii. use the unsubscribe facility that AW include in our commercial electronic messages (i.e., email or SMS) to opt out of receiving those messages.
5. TO WHOM IS PERSONAL INFORMATION DISCLOSED?
5.1 AW may disclose an individual’s personal information to any of the organisations that we deal with in the ordinary administration of our business for the purposes set out in section 4 above, including:
i. their employer, (or, if they are a contractor, their head contractor);
ii. financial institutions;
iii. AW’s service delivery partners, including:
• information technology service providers (including cloud services providers);
• mailing houses, postal, freight and courier service providers;
• printers and distributors of client communications;
• external business advisers (such as recruitment advisers, auditors, quality control officers, lawyers and people carrying out legally required inspections).
• Professional bodies such as CPD or IAM for Certificate provision
5.2 In each case, AW may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from the individual.
5.3 AW may de-identify and aggregate the personal information of individuals and others for our own statistical purposes. Provided that it remains permanently deidentified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
5.4 If an individual applies for a job with AW, we may discuss their application with their nominated referees.
5.5 If an individual has an online account via AW’s website, they can access and change their privacy settings by logging in to their account and following the instructions on AW’s website. Depending on the privacy settings they chose, some of the personal information in their user profile may be disclosed to other users.
5.6 If an individual posts comments or otherwise communicate publicly with other users via AW’s website, any information about them that they include in the communication may be stored on the website and accessed by other users. For this reason, AW encourage individuals to use discretion when deciding whether to post any information that can be used to identify them.
6. CROSS BORDER DISCLOSURE OF PERSONAL INFORMATION
6.1 It is AW’s current policy not to disclose personal information to third parties located overseas.
6.3 When transferring data overseas, AW will do it via a secure method and only to nations the meet EEA data legislation. Only authorised personnel will be able to view said data and only for the business and service requirements that are listed in other parts of this document
7. DATA QUALITY AND SECURITY
AW hold personal information in various ways, including in electronic databases, email contact lists, and in paper files held in secure premises. Paper files may also be archived offsite in secure facilities. AW take reasonable steps to:
i. make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
ii. protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure;
iii. destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs.
The steps AW take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.
7.2.1 Payment security
AW process payments using PayPal/WorldPay/BACCS and on-line technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.
7.2.2 Website security
While AW strive to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that an individual discloses on-line and they disclose that information at their own risk. If an individual is concerned about sending their information over the internet, they can contact AW by telephone or post (see section 10 below).
An individual can also help to protect the privacy of their personal information by maintaining the confidentiality of their account (including their password), and by ensuring that they log out of their account on our website when they have finished using it. In addition, if an individual becomes aware of any security breach, they should inform AW as soon as possible.
8. HOW CAN INDIVIDUALS ACCESS AND CORRECT THEIR PERSONAL INFORMATION?
8.1 Individuals can request access to the personal information that AW hold about them and request corrections by contacting AW’s Privacy Officer (see section 10 below).
8.2 If an individual has an online account via AW’s website, they can access and change some of their personal information by logging in to their account and following the instructions on our website.
9.1 If an individual has a complaint about how AW has handled their personal information, they should contact our Privacy Officer (see section 10 below).
9.2 Our Privacy Officer will endeavour in the first instance to deal with the individual’s complaint and take any steps necessary to resolve the matter within a week.
9.3 If the complaint can’t be resolved at first instance, AW will ask the individual to complete a Privacy Complaint Form.
9.4 Complaints process
i. AW will endeavour to acknowledge receipt of the Privacy Complaint Form within 5 business days of receiving it and to complete our investigation into the individual’s complaint in a timely manner.
ii. In most cases, AW expect that complaints will be investigated, and a response provided within 30 days of receipt of the Privacy Complaint Form. In the event our investigation may take longer, we will let the individual know.
iii. If the individual is unhappy with AW’s response, they can refer their complaint to the Information Commissioners Office (see here for further information).
10. FURTHER INFORMATION
10.1 Individuals should contact AW if they have any queries about the personal information that we hold about them or the way we handle that personal information. AW’s contact details for privacy queries are set out below.
Privacy Officer: June Lancaster
Mail: Asset Wisdom Ltd, Commer House, Station Road, Tadcaster LS24 9JF
E Mail: Info@asset-wisdom.com
Telephone: 01937 557875
11. CHANGES TO THIS POLICY