City & Guilds Customer Privacy Notice

Introduction

City & Guilds is committed to data security and the fair and transparent processing of personal data. This privacy notice (Notice) sets out how City & Guilds, a City & Guilds business, or ILM, a City & Guilds business treat the personal data which you provide to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (EU GDPR), the UK GDPR and the Data Protection Act 2018 (DPA).

This notice applies to:

1. individuals employed by centres delivering City & Guilds’ or ILM qualifications or providers offering ILM recognised programmes; and

2. individuals employed by customers receiving end-point assessment services from City & Guilds, in connection with the provision of learning, training, assessment, and/or certification products and/or services (staff members).

If you are a staff member, please read this notice carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data (process), your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

Who are we?

For the purposes of applicable data protection law, including the UK GDPR and the DPA, City & Guilds is the ‘controller’ of the personal data you, as a staff member, or a centre, provider or customer, provide to us.

The City and Guilds of London Institute is a charity incorporated by Royal Charter, with registered charity number 312832 (England and Wales) and SC039576 (Scotland). ILM, a City & Guilds Business, (City & Guilds, we, us, or our). Our registered address is Giltspur House, 5-6 Giltspur Street, London, EC1A 9DE.

The City & Guilds businesses includes City & Guilds, and its associated companies (including City & Guilds International Limited) and businesses (including ILM).

You can read more about the City & Guilds companies at our dedicated page.

We work closely with our associated companies including processing of personal data, see our other companies’ privacy notices for more information.

If you have any queries about this notice, the way in which we process personal data, or about exercising any of your rights, you may send an email to dp@cityandguilds.com or write to Data Protection, City & Guilds, Giltspur House, 5-6 Giltspur Street, London, EC1A 9DE.

What personal data do we collect?

Personal data you provide to us

We collect and process the personal data that you, a centre, employer, employer provider, training provider or customer, provide to us, which may include your name, email address, address, telephone number, date of birth, National Insurance Number, bank account details, work history, and reference details, as necessary.

We may also receive personal data about you if you use any of the other websites which we, or another company within the City & Guilds business, or the other services and/or products which we, or another company within the City & Guilds business, provide. You can find out more about the City & Guilds business on our dedicated page. See our other companies’ privacy notices for more information.

Special category data

In some circumstances, we may also collect and/or be provided with special category data, such as data about your physical or mental health or condition, to enable us to administer requests for reasonable adjustments, or in relation to an investigation, complaint, or appeal. Such data should only be collected and/or provided to us if you have provided your explicit consent or if we are otherwise permitted to receive and process it under applicable data protection law (including as set out below).

How do we process your personal data?

Legitimate interests: we may process your personal data where it is necessary to pursue our, or third parties’, legitimate interests, including:

to provide learning, training, assessment, and/or certification products and/or services to centres, employers, employer providers, training providers, customers, learners and apprentices;
provide you with a certificate, credential, or other record of learning;
arrange for a digital credential to be issued to you when you have successfully completed a course or e-learning module, attended an event, or in recognition of an achievement;
to undertake administration in relation to products and/or services;
to contact you directly in relation to our quality assurance processes, investigations, complaints, and appeals; and
to prevent and detect crime and/or assist with the apprehension or prosecution of offenders.

We may also process your personal data in pursuance of our legitimate interests to contact you directly in relation to new and existing products, services, news, awards and events offered by City & Guilds, or another member of the City & Guilds businesses.

Where you do receive such marketing communications from us, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.

You have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your rights.

Where required by law: we may also process your personal data if required by law.

Consent: we may process your special category data when we have obtained your explicit consent to do so.

With respect to special category data, we may also process such data if necessary for reasons of substantial public interest, including for the prevention or detection of unlawful acts or in compliance with, or to assist third parties to comply with, any regulatory requirements relating to the investigation of unlawful acts, dishonesty or malpractice.

Who do we share your personal data with?

We may share your personal data with trusted third party service providers including:

legal advisors, auditors, and other professional advisers, consultants, subject matter experts and other professional experts;
service providers contracted to us in connection with provision of the products and/or services such as providers of learning, training, assessment, and/or certification or credentialing products and/or services, IT services, and customer relationship management services;
our digital credential partner platform and
analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will ensure that there is a contract in place with such third party service providers, which includes obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them, and which upholds your rights and freedoms with respect to personal data.

Where a third party recipient is located outside the UK, European Economic Area or any other approved country or territory, we will ensure that the transfer of personal data is protected by appropriate safeguards, including international data transfer agreements in the UK, and the use of standard data protection clauses adopted or approved by the European Commission when applicable In some circumstances we share personal data within the City & Guilds business, including City & Guilds companies registered in the UK and outside of the UK to maintain and improve current and future services, customer engagement, and sales opportunities across our business. We work closely with our associated companies including processing of personal data, see our other companies’ privacy notices for more information.

Any shared access of personal data is subject to restrictions both legally and contractually.

We may also share personal data (including any special category data) with law enforcement or other authorities or agencies if required by law or where we otherwise deem it necessary in pursuance of our legitimate interests. This may include, without being limited to, responding to requests for information from such authorities or agencies, or sharing information with them in connection with our quality assurance processes, investigations, complaints, or appeals.

You should be aware that, where personal data is shared with a public authority, it will become subject to the Freedom of Information Act 2000 (FOIA) and may potentially fall within the scope of any future FOIA request made to such public authority.

How long will we keep your personal data?

We will keep your personal data for the duration of the contract between us and a centre or customer. Thereafter, we will keep per - provide information about your relationship with City & Guilds; personal data in order to:

respond to any questions, complaints or claims made by you, on your behalf or about you;
comply with any relevant third party record retention requirements (e.g. those of a regulator); and
comply with any contractual, legal, audit, and other regulatory requirements, or any orders from competent courts or authorities.

We will also keep personal data relating to our quality assurance processes, investigations, appeals and complaints, in order to comply with applicable contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

City & Guilds keeps personal data for no longer than as is necessary for the above purposes.

How do we protect your personal data?

We take all reasonable steps to ensure that both we and our third party service providers protect your personal data. This includes ensuring that our staff are aware of their information security obligations, providing training, and limiting access to your personal data to staff who have a genuine business need to know.

We also take reasonable steps to protect your personal data from loss or destruction and 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.

Furthermore, our project management and change control process includes structured assessment of information security and data privacy risks. This process aims to ensure that all proposed system changes of City & Guilds from time to time fully align with the data protection requirements and good practice to uphold data subject’s rights and freedoms with respect to personal data.

Note that where you as a staff member have a username or password (or other identification information) which enables you to access certain services or parts of our website, you are responsible for keeping this password confidential. We ask you not to share passwords with anyone.

Further note that unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

Under applicable data protection law, you have various rights with respect to our processing of your personal data:

Right to Access

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of request. Please note that there are exceptions to this right. We may be unable to make all data available to you if, for example, making the data available to you would reveal personal data about another person, if we are legally prevented from disclosing such data, if there is no basis for your request, or if your request is excessive.

Right to rectification

We aim to keep your personal data accurate, current and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal data is no longer necessary for the purposes for which it was collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data be erased, please contact us using the contact details provided below.

Right to object

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Right to restrict processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the personal data, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted.

If you would like to make such request, please contact us using the contact details provided below.

Right to data portability

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another ‘controller’, in a commonly used, machinereadable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to make such request, please contact us using the contact details provided below.

Please note that applicable data protection laws sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Contact

If you have any queries about this notice, the way in which City & Guilds processes personal data, or about exercising any of your rights, you can send an email to dp@cityandguilds.com or write to Data Protection, City & Guilds, Giltspur House, 5-6 Giltspur Street, London, EC1A 9DE.

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint with the applicable supervisory authority or seek a remedy through the courts. Please visit the UK Information Commissioner’s Office for more information on how to report a concern.

Changes to our Notice

Any changes we may make to our Notice in the future will be posted on this page and, where appropriate, notified to you, a centre, provider or customer, by email.

Please check back frequently to see any updates or changes to our Notice.

- Customer Privacy Notice Version 2, 14 February 2024

City & Guilds Customer Privacy Notice

Introduction

Who are we?