This statement explains what the Academy does with the personal information you provide us.
- How the Academy uses your information
- How Government Departments use your information
- Third Parties we whom we share data
- The Legal basis for collecting your information
- Parents, Carers and Guardians
- Sharing information with Local Authorities
- Where your information is kept
- How long your information will be kept for
- Access to your information and correction
- Websites and Cookies
- Other websites
- Call Tracking and Monitoring
- Changes to our privacy notice
- How to contact us
We collect information about you when you contact us to enquire about a course, make an application to join a programme of learning, book an appointment for a service or treatment as a model, buy a product, apply for a job, whether contact is online, on paper, by email or over the phone.
From time to time you will be asked to tell us personal information about yourself (e.g. name and email address etc.) in order to become a student or a client, to use Academy systems and services and so on. At the point of collecting the information we aim to clearly explain what it is going to be used for and who we may share it with. Unless required or permitted by law, we will always ask you before we use it for any other reason. We would only use it for marketing with your prior consent.
Any sensitive personal information will never be supplied to anyone outside the Academy without first obtaining your consent, unless required or permitted by law. We comply with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR), including removing your personal information from our systems when it is no longer required and ensuring that all personal information supplied is held securely.
Whenever you provide such personal information, we will treat that information in accordance with this statement, current legislation and our Data Protection Registration (Registration Number: ZA028379). We also aim to meet current best practice.
Individuals whose personal information the Academy holds have certain rights under the law. More information can be found on the Information Commissioner’s website.
This section explains how the Academy uses the personal information that you give us on the enrolment form.
How the Academy uses your information
The information will be used for purposes relating to education, training, employment, general advice services, well-being and research. The Academy may share non-sensitive personal information about you with other organisations, for example the Local Authority (see below) for the purposes set out below. We do not share your information for purposes that are incompatible, such as product marketing.
Sensitive personal information you provide (e.g. disability or ethnicity) may be used by the Academy for the purposes of equality of opportunity, support for your studies and to minimise risk. It may also be used anonymously for statistical purposes. The Academy will ask your permission before sharing sensitive information with other organisations, unless the sharing is permitted by law and necessary.
How government departments use your information
We pass most of the information to government agencies to meet funding arrangements. The Academy is a Data Processor for the Education and Skills Funding Agency. This means that the Academy will pass most of the personal information and some of the sensitive information you provide to the Education and Skills Funding Agency and the Department for Business, Innovation and Skills (BIS). Where necessary it is also shared with the Department for Education (DfE).
The information is used for the exercise of functions of these government departments and to meet statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009. It is also used to create and maintain a unique learner number (ULN) and a Personal Learning Record (PLR).
The information provided may be shared with other organisations for purposes of administration, the provision of career and other guidance and statistical and research purposes, relating to education, training, employment and well-being. This will only take place where the sharing is in compliance with the Data Protection Act 1998.
You may be contacted after you have completed your programme of learning to establish whether you have entered employment or gone onto further training or education.
You may be contacted by the English European Social Fund (ESF) Managing Authority, or its agents, to carry out research and evaluation to inform the effectiveness of the programme.
Further information about use of and access to your personal data, and details of organisations with whom the data is regularly shared are available at: http://www.gov.uk/government/publications/sfa-privacy-notice
Third Party Suppliers with whom we may share data
We will also pass on some of your information to The Awarding Organisations we work with including but not limited to City & Guilds, VTCT, NCFE and ITEC.
We will also share your data with Pellcomp Limited (PICS) which is the data MIS system we use to capture your learner and employer data in order to comply with the information requirements of The Skills Funding Agency.
We will also share your data the marketing companies we work with including but not limited to Digital NRG, Tutch Media, Absolute Creative and Digital NRG.
We have rigorous data protection and security policies in place with all our suppliers, they are bound by the same General Data Protection Regulations. We will not share your information with any other third party without your consent except to help prevent fraud, or if required to do so by law.
The legal basis for collecting the information
Most of the information on the application or enrolment form is collected because it is necessary for your enrolment as a student or is required by law. You must provide it in order to enroll at the Academy.
The information we collect is based on your consent, and you may withdraw your consent without this affecting your status as a student: emergency contact details and parent/carer contact details.
Parents, carers and guardians
Under the GDPR (General Data Protection Regulation), young people aged 16 and over can decide for themselves and give consent for the processing of their personal information. Parental consent is not required. There may be exceptions in regards of students with severe learning difficulties, and those who are otherwise unable to decide for themselves.
For learner applicants under the age of 16, we will only keep and use their personal information with the consent of a parent, carer or guardian. When you make an application for course information online as a school leaver you should only do so with parental consent.
The Academy has found that it is very beneficial to the young person’s progress as a student if the Academy is able to engage with the parents (or guardian/carer). Therefore, it is very important that we have the parents’ details recorded on our systems.
When a student is in Further Education, parents/carers/guardians (or any other third party) are not automatically entitled to the student’s information. We can only release information about our students if we have their consent for this recorded on the Academy system. Students are asked for their consent for sharing information with parents/others on the enrolment form or when enrolling face-to-face.
Students can also inform the Academy later on of who the Academy may discuss with about their Academy matters. Students may withdraw their consent the same way which they gave it.
In general, we can only share information if we have the person’s consent, or there is a particular piece of legislation or agreement allowing us to share it without consent.
Participation in Learning: Sharing information with Local Authorities
This section applies to:
- 16 and 17-year olds
- Vulnerable 18-year olds (‘vulnerable’ is defined locally by individual Local Authorities)
· 18-25-year olds with an Education Health Care Plan (EHCP)
The Education and Skills Act 2008 (the Act) places duties on Local Authorities (LA’s) to promote the effective participation in education or training of all 16 and 17-year olds resident in their area, and to make arrangements to identify young people resident in their area who are not participating. It is part of the LA’s duties to secure sufficient suitable education and training provision for all 16-19-year olds, and to encourage, enable and assist young people to participate in learning.
Under the Act, it is the Academy’s duty to provide relevant information about their students to the LA of each student’s residence, when requested to do so, and notify local LA’s when a young person leaves learning at the Academy. All educational institutions are required to share information with LA’s as part of their duty under the Act.
Section 72 of the Act provides the legal basis for sharing information between LAs and educational institutions.
Link to relevant section is referenced here: www.legislation.gov.uk/ukpga/2008/25/section/14
When you give us your information we will use your details to inform the LA where you live about the learning that you are participating in so that they are able to report monthly to the Department of Education and deliver their duties listed above.
Please note that some of the services for young people provided by the LA to fulfil their duties are provided by commissioned external contractors and organisations and they are required to use the same security standards as the LA.
We would like to send you information about courses and services which may be of interest to you. We will ask for your consent to receive marketing information. If you have consented to receiving marketing, you may opt out at a later date.
You have the right at any time to stop us from contacting you for marketing purposes or giving your information to third party suppliers of products or services. If you no longer wish to be contacted for marketing purposes, please email [email protected] or [email protected].
WHERE YOUR INFORMATION IS KEPT
Your information is stored within the European Economic Area on our secure servers or servers used by The Skills Funding Agency, Pellcomp Limited, Awarding Organisations and our marketing companies.
HOW LONG YOUR INFORMATION WILL BE KEPT FOR
Unless you request otherwise, we will keep your information to contact you no more than a maximum of 1 year.
We will keep information about you as required by The Skills Funding Agencies a such as your enrolment information and funding eligibility criteria for a period of 7 years, which we are required to do so as a condition of funding.
We will keep information about you as required by the relevant Awarding Organisations for a period of 5 years.
If you have been a model at the Academy after a year we will delete all your personal information, except for your name, relevant client history (eg allergy test records which we keep for 4 years).
See our Data Retention Policy for further information, including employee data.
The information we collect about employees, the purposes it is used for and who it will be shared with is set out in our employment contracts and employee handbook.
Information about unsuccessful job applicants will be deleted within six months unless we inform you and you consent to us holding your information for twelve months. Thereafter it will be deleted.
ACCESS TO YOUR INFORMATION AND CORRECTION
You have the right to request a copy of the personal information that we hold about you. This will normally be free, unless we consider the request to be unfounded or excessive, in which case we may charge a fee to cover our administration costs. If you would like a copy of some or all of your personal information, please contact the Managing Director.
We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or remove information you think is inaccurate.
You have the right to ask us to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it.
HOW TO ACCESS YOUR DATA
You can make a subject access request to find out what data is held and how it is used. You may make a subject access request before exercising your other information rights.
You can make a subject access request verbally or in writing. If you make your request verbally, we recommend you follow it up in writing to provide a clear trail of correspondence. It will also provide clear evidence of your actions.
You can find more information on how to make an application for information by following the link below:
Websites and Cookies
This section applies to anyone accessing the Academy websites.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org
Session cookies will remember your selections as you browse the site. These cookies are for the browsing session and not stored long term. No personal information is collected by these cookies.
Google Analytics cookies help us to make the website better for you by providing us with user statistics, for example: which pages are the most visited; how a user navigates the site. No personal information is collected by these cookies.
During the course of your study you may be asked to use third party websites or services or access linked content (e.g. YouTube, Padlett, Kahoot) which may collect personal data about you. That site’s own privacy notice will explain you how they use your data.
CALL TRACKING AND RECORDING
We use telephone tracking numbers to link a user’s call to the marketing channel that they originated from. This is done using cookies, you can choose to decline cookies if you would prefer not to be tracked.
We may record calls for training or monitoring purposes only.
The CCTV system and the images produced by it are controlled by The London Hairdressing Apprenticeship Academy Limited who are responsible for how the system is used and for notifying the Information Commissioner about the CCTV system and its purpose (which is a legal requirement of the Data Protection Act 1998.1
We, The London Hairdressing Apprenticeship Academy Limited have considered the need for using CCTV and have decided it is required for the prevention and detection of crime and for protecting the safety of learners and our customers. It will not be used for other purposes. We conduct an annual review of our use of CCTV.
CCTV images are retained for 10 days on a secure hard drive and automatically deleted on a rolling basis. We only record images to support the safety and security of our employees, learners of all ages, models and clients. Non-authorised members of staff do not have access to the CCTV images retained on the secure drive and all drives are password protected.
CCTV signs are displayed prominently around each academy and located in close proximity to the camera so that they are visible to all persons.
We adhere to the ICO Code of Practice details can be found at:
CHANGES TO OUR PRIVACY NOTICE
We keep our privacy notice under regular review and we will place any updates on this webpage. This privacy notice was last updated on 25th May 2018.
The Academy as a corporate body is the data controller under the Data Protection Act, and the Board of Directors and the Education Board is therefore ultimately responsible for implementation.
HOW TO CONTACT US
Please contact us if you have any questions about our privacy notice or information we hold about you:
- By email – [email protected]
- Or write to us at The London Hairdressing Apprenticeship Academy Limited, Paramount House, 17-21 Shenley Road, Borehamwood, Hertfordshire WD6 1AD.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern: www.ico.org.uk/concerns/handling