Privacy Policy
Introduction
This Privacy Policy has been prepared in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018.
This notice sets out the basis on which any personal data including special category personal data that we collect from you, or that you provide to us, will be processed by us. Personal data means information about you that may identify you from that data.
This policy ensures Baltic Apprenticeships meets the data protection principles which require information to be:
- Handled fairly and lawfully
- Kept and used for limited purposes
- Required for good reason
- Correct and up to date
- Not kept longer than necessary
- Handled confidentially
- Stored securely
- Not transferred to unapproved countries outside the European Economic Area
Who we are
Baltic Training Services Ltd (known as Baltic Apprenticeships) is a Training Provider who contracts with the Educations and Skills Funding Agency (ESFA), an executive agency of the Department for Education (DfE) to deliver apprenticeship and adult education training programmes.
Data controller statement
Baltic Training Services Ltd, (also referred to in this policy as “we” or “us”) registered office is Pioneer House, Pioneer Court, Darlington, Co Durham, DL1 4WD company number 05868493 is the Data Controller in respect of all data collected.
Your acceptance of this policy
By using our websites, social media pages or by providing your information, you understand that we will collect and use the information provided in the way(s) set out in this policy.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.balticapprenticeships.com/ (the site) you are accepting and consenting to the practices described in this policy.
We may make changes to this policy from time to time. If we do so, will post the changes on this page and they will apply form the time we post them.
What information do we collect from you or ask you to provide?
Personal information – such as your name, date of birth, National Insurance number, gender, contact details, details of your current situation with regarding to education, training or employment, qualifications and your future career aspirations.
Special categories of personal data – such as ethnic origin, physical or mental health or condition.
We will collect information you voluntarily provide us when you contact us with queries, complaints or customer feedback.
We operate call recording for training and quality purposes, any personal data disclosed during telephone calls to and from our offices will be collected.
If you visit our website, we may automatically collect the following information:
Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit to our website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Cookies
When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to.
The information does not usually directly identify you, but it can give you a more personalised web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.
Other sources of personal data
We may also use personal data from other sources, such as specialist companies that supply information, online media channels and public registers and public website domains.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Purpose of data
We need to collect, hold and process information about you in order to:
• Confirm your identify and keep in touch with you by post, email, text or telephone
• Help you find and prepare for employment and training opportunities
• Confirm your eligibility for training programme participation
• Register you on a training programme in accordance with the compliance requirements detailed in The Education & Skills Funding Agency Funding (ESFA) Funding & Performance Management rules and ESFA Individual Learning Record (ILR) guidance
• Understand your needs and provide you with the appropriate support
• Meet our statutory obligations including those related to equality & diversity
• Manage our employer customer account and provide you with details of our services
• Respond to queries, complaints or customer feedback
Legal basis for processing your data
Candidate Recruitment – Legitimate interest: To ensure that Baltic Apprenticeships match candidates wishing to seek an apprenticeship and learning opportunities and considering their interests, skills and abilities to match them with employer apprenticeship and employment opportunities.
Learner Enrolment and on programme participation – Legitimate interest: To ensure Baltic Apprenticeships deliver a programme of training in accordance with ESFA requirements which supports individuals and meets their learning and welfare needs. For special categories of personal data, this is processed as it is necessary for employment.
Employers – Legitimate interest: To ensure Baltic Apprenticeships supports your recruitment needs and that together we deliver a successful apprenticeship programme to our learners/employees.
Employers (Direct Marketing) – Legitimate interest: To ensure Employers are invited to support the Government’s Apprenticeships and Skills Policy in England. Apprenticeships are one of the initiatives the government has in place to improve the skills held by workers in England. Apprenticeships ensure the skills system is more responsive to employer needs.
Improving our service – Legitimate interest: To make sure that Baltic Apprenticeships continue to improve our service and provider the best and most effective service possible to our customers (candidates, learners and employers)
Who might we share your information with?
In some cases, we may need to share your data with some third-parties.
Candidate data will be shared with employers recruiting to fulfil an apprenticeship vacancy.
Learner data will be shared with the Education & Skills Funding Agency, Qualification Awarding Bodies, E-Portfolio Provider and End Point Assessment Organisations. These organisations will become Data Controllers on receipt of data. Your contact details will be shared with organisations who carry out destination surveys on completion of your apprenticeship. These organisations will be data processors.
Employer data will be shared with the Education & Skills Funding Agency.
Data will be visible to service providers who provide the mechanisms Baltic Apprenticeships use to collect and store data:
• Databases are provided by Perspective and Salesforce.
• Our E-portfolio provider is SMART Assessor
• Company Shared Drive Data and email service is provided by Aspire
• Documentation signature and exchange is provided by SignNow
• Apprentice Community provided by Hivebrite
How we protect your information?
Measures we have in place to protect your information include computer safeguards such as firewalls and data encryption and we enforce physical access controls to our buildings and files to keep data safe. We only authorise access to employees who need it to carry out their job responsibilities. Please note that we cannot guarantee the security of any personal data that you transfer to us by email, for example a CV you submit to us for a vacancy. CVs and Applications submitted via our website portal are secure.
How we store your information?
Baltic Apprenticeships maintains records of the geographical location of your personal data. This is either:
• Stored in the UK or
• Stored within the European Economic Area (EEA)
How long do we keep hold of your information?
Candidate/Learner and Employer data will be retained in accordance with our ESFA contractual requirements, this is currently until 31st December 2030.
Unplaced candidate data will be retained for a period of 12 months from date of last contact, excluding in Screening, Talent Pool, Client Interview and Work Trial candidates.
Automated decision making
Please be advised that no decisions are made using automated decision mechanisms.
Your rights under General Data Protection Regulation
You have a number of rights under data protection law. We will need to ask you for proof of your identify before we can respond to a request to exercise any of the rights set out below. We also may need to ask you for more information, for example to help us to locate the personal data that your request relates to.
Right 1 – a right to access your information
You have a right to ask us for a copy of your personal data that we hold about you. A request to exercise this right is called a “subject access request”. You make make a subject access request by emailing dataprotection@balticapprenticeships.com.
Right 2 – a right to object to us processing your information
You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing. This includes all of your personal data that we process for all of the purposes set out in this Privacy Policy. If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise we will cease processing your personal data.
You can exercise this right by emailing dataprotection@balticapprenticeships.com
Right 3 – a right to have inaccurate data corrected
You have the right to ask us to correct inaccurate data that we hold about you; on notification we will correct your personal data.
Right 4 – a right to have your data erased
You have the right to ask us to delete your personal data in certain circumstances, for example, if we no longer need the data for the purpose set out in this Privacy Policy. You can exercise this right by emailing dataprotection@balticapprenticeships.com.
Right 5 – a right to ask us not to market to you
You can ask us not to send you direct marketing, you can exercise this right be emailing dataprotection@balticapprenticeships.com.
Right 6 – a right to have processing of your data restricted
You can ask us to restrict processing of your personal data in some circumstances, for example, if you think the data is inaccurate and we need to verify its accuracy.
How to contact us
If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can contact us at dataprotection@balticapprenticeships.com.
What if you have a complaint?
You have a right to complain to the Information Commissioner’s Office (ICO) which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data. You can find out how to do this by visiting www.ico.org.uk.
Policy review
This policy will be reviewed annually or when changes are required.