1.1 This policy references the Education and Training Foundation (“ETF, we, us, our”), a registered charity (registration no: 1153859) and company limited by guarantee (company registration number (England and Wales): 08540597).
1.3 The ETF may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
(2) What personal data we collect
2.1 Our data sharing relationships are:
- Teamtailor, who operate our recruitment service (“the Service”) as the processor of data for the ETF as the Data Controller (“Controller”)
- it is to provide you with a service or information including any benefits and services provided by third parties as set out above. The ETF requires all such third parties to treat your personal information as confidential and to comply with all applicable UK Data Protection Legislation (including the General Data Protection Regulation and Data Protection Act 2018) and Consumer Legislation in place at any given time
- you have given your explicit consent to do so
- where it is necessary to comply with an order from a statutory body which is empowered to require us to release your data; or to comply with any legal obligation; or to enforce or apply any of our terms which you are subject to; or to protect the rights, property, or safety of ETF, our staff or others
- the ETF is acquired by a third party, in which case personal data held by it will be one of the transferred assets.
- our contractors and sub-contractors, acting as our Data Processors and Sub-Processors in accordance with our instructions, for the provision of the Service
- authorities or legal advisors, in case criminal or improper behaviour is suspected
- authorities, legal advisors or other actors, if required by us according to law or the authority’s injunction.
2.2 We may process personal data that you provide to us directly (for example, through the websites that we operate, correspondence, phone, email, social media etc), via third parties who you have given permission to pass on your information, and from publicly available sources or otherwise.
2.3 Data provided by yourself may include;
- when you make an application through the Service or otherwise, adding personal data about themselves yourself either personally or by using a third-party source such as Facebook or LinkedIn
- when you use the Service to connect with our staff, adding personal data about themselves yourself either personally or by using a third-party source such as Facebook or LinkedIn
- provides identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure.
- We collect data from third parties, such as Facebook, LinkedIn and through other public sources. This is referred to as “Sourcing” and be manually performed by our employees or automatically in the Service
2.6 The information you give us may include, but is not limited to, names, e-mails, pictures and videos, information from Facebook and LinkedIn- accounts, answers to questions asked through the recruiting, titles, education and other information that you or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.
2.7 At the time of providing this personal information we will be clear of the purpose it is being collected, how you can subsequently ask for your data to be amended and how you can ask for it to be deleted.
(3) Our ‘lawful basis’ for collecting information
3.1 We have a number of legal reasons (or the ‘lawful basis’) that mean we can use (or ‘process’) your personal information, including consent, legitimate interest and public task (there are six in total). These are outlined in the following sections. Sometimes more than one lawful basis will apply when we process your personal data. You can find out more about this from the ICO here.
3.2 Legitimate interest: means we can process your personal information if: we have a genuine and legitimate reason; we are not harming any of your rights and interests; and you would not be surprised or likely to object to receiving the communication. We will process the personal information you have supplied to us to manage recruiting. This is what we consider to be our ‘Legitimate interest’. When processing your data in this way, we will also carefully consider and balance any potential impact on you and your rights.
3.3 Consent: means we can process your personal information if consent can be freely given and you have real choice and control over how the we use your data. You must be able to give your consent through opting in and we must provide you with a clear explanation of why we want your data and what we’ll do with it. ETF seeks consent from individuals for example to receive our regular newsletter.
3.4 As a User of the Service, you consent to the processing of your personal data with the purpose of us, as the Controller handling recruiting. You consent that personal data is collected through the Service, when you:
- make an application through the Service, adding personal data about yourself either personally or by using a third-party source as Facebook or LinkedIn, and that we may use external sourcing-tools to add additional information
- when you use the Service to connect to our recruitment department, adding personal data about themselves yourself either personally or by using a third-party source such as Facebook or LinkedIn.
(4) How we use information about you
4.1 The ETF will not sell or lease your personal information to third parties and we will only share your data with third parties when:
4.2 The ETF will complete due diligence on third parties we ask to process data on our behalf. As part of our contract management processes, we keep an overview of how your data is processed by third parties.
4.3 We will stop processing and or delete your personal data if you ask us to. Please contact us at email@example.com.
4.4 We retain your information as long as necessary for each purpose we use it. In some instances, we are obliged by law to keep it for a defined period and in this event, this negates your right to be forgotten. For example, we keep all financial transaction for seven years as outlined by the Companies Act 2006. At the end of specified retention periods we dispose of your data securely.
5.1 All information you provide to us is stored on secure servers. We adopt appropriate technical and organisational measures to protect the security of all personal data held by the ETF, including sensitive personal data. All payment transactions are encrypted and stored securely.
5.2 Although the ETF try to ensure your personal data is protected, we cannot guarantee the security of your data transmitted to our site; any transmission of data is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
(6) What are your rights
6.1 The General Data Protection Regulation (GDPR), gives everyone a number of rights. These are:
- Transparency over how we use your personal information (right to be informed)
- Request a copy of the information we hold about you, which will be provided to you within one month (right of access)
- Update or amend the information we hold about you if it is wrong (right of rectification)
- Ask us to stop using your information (right to restrict processing)
- Ask us to remove your personal information from our records (right to be ‘forgotten’)
- Object “opt-out” to the processing of your information for marketing purposes (right to object)
- Obtain and reuse your personal data for your own purposes (right to data portability)
- Not be subject to a decision when it is based on automated processing (automated decision making and profiling).
6.2 If you would like to know more about your rights under the data protection law see the Information Commissioner’s Office website.
6.3 You can change the way you hear from us or withdraw your permission for us processing your personal data by contacting firstname.lastname@example.org.
6.4 You also have a right to access the personal data that is stored about you. Any person wishing to exercise this right should complete a Subject Access Request Form and send the completed form to email@example.com. The form and further information can be found on the bottom of the ‘Contact Us’ page on the ETF website.
6.5 For any other queries related to your individual rights you can contact firstname.lastname@example.org.
(7) Links to other sites
7.1 Our website may contain links to other websites. ETF does not have any control over the content or security of other websites and cannot be responsible for your privacy and protection if you choose to visit these websites.
(8) Contacting us and who to complain to
8.2 If you wish to raise a complaint on how we have handled your personal data, you can contact us:
- In writing, to Gina Hobson, Data Protection Lead
- Education and Training Foundation
- 157-197 Buckingham Palace Road, London SW1W 9SP
- By email, to email@example.com
- By ‘phone, on 020 3740 8280.
Alternatively, you can complain directly to the Information Commissioner’s Office (ICO).
These contact details do not refer to complaints about the recruitment process. Our full complaints procedures can be found in the ETF Complaints Policy and Procedure.