1. INTRODUCTION
Well Working Matters appreciates your business and trust.
Please read this Privacy Policy, providing consent to both documents in order to have permission to use our services.
2. DATA COLLECTED
PRIVACY NOTICE
The following privacy notice is to let you know how we promise to look after your personal data, your privacy rights, and how the law protects you. We hope that the information is clear and easy to understand, however if this is not the case, or you require any further clarity, please contact our Data Protection Officer Gill Halsey on 07824 387 683 or admin@wellworkingmatters.co.uk
Our Privacy Promise to you;
We promise;
- To keep your data safe and private
- To never sell your data
- To give you ways to manage and review the data which we hold
How the law protects you
As well as our privacy promise to you, your privacy is protected by law.
The Data Protection Act 1998 (DPA) governs all organisations who hold personal data on individuals. On 25th May 2018 the General Data Protection Regulation (GDPR) came into force. Our interpretation of this regulation is that the GDPR takes many of the core principles of the DPA, and modernises them in view of the shift in digital technologies and digital communication / storage. The GDPR aims to hold organisations more accountable for the protection of your personal data, and provide you with more rights as to how this is collected, used, retained and destroyed.
The law says that we are allowed to collect and use your personal data only if we have a reason to do so;
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it
In terms of the information we hold for you as a training provider, this is no different to that held for example by a school or college.
Why we hold personal data
We hold personal data on students and employers for the following reasons;
- Information we are required to collect by law or to claim funding
- Information we need to deliver your chosen course of study and monitor progress
- Additional information that will allow us to personalise our support to meet your individual needs
- Information we use for marketing, communications and advice. At no time will your personal data be passed to other organisations for marketing or sales purposes. Your employer may be contacted by Well Working Matters Ltd.
- Information we gather to provide facilities and ensure security (such as CCTV video)
The personal data we hold includes;
- Personal information (such as name, date of birth, Professional Registration details, address, emergency contact information)
- Special categories of data including characteristics information such as gender, age, ethnic group
- Progression information (such as modules in progression / achieved, examination results, individual learning plans, records of discussion, support requirements)
- Employment information (such as business name, contact, job description, start date)
- Here is a full list of all the ways that we may use or are required to share your personal information:
| What we use your personal information for | Our reasons | Our legitimate interests | Stakeholder |
| To return your information to the Education Skills Funding Agency (ESFA) and/or Scottish Qualifications Agency (SQA) | Our legal duty | We must report your progress to the agency each month to receive funding | Student |
| To check prior learning | Our legal duty | To ensure course relevance | Student |
| To register you with the relevant awarding body | Our legal duty | We must register you with the correct awarding body, after completing your qualification they will then issue your certificate | Student |
| To gather your views about us as a training provider | Our legitimate interest | We may from time to time contact students and employers to ask how well we are doing and improve our services | Student / Employer |
| To profile our performance as a provider, for example the success of students studying in a particular sector, or the difference between the success of male & female students | Our legitimate interest | We may group your information and carry out analysis as part of our quality assurance process. This is carried out with the intent of identifying any areas we are performing less well, and introduce improvements. | Student / Employer |
- Where we collect personal information fromWe initially collect information on you at the point in which you engage with Well Working Matters Ltd. For students this would be during the application process.We may also collect personal information;
- In emails and letters
- During telephone conversations
- At the induction process
- Through surveys
- Through third parties
- Awarding Bodies
- Government agencies & departments
Who we share your personal information with
Well Working Matters Ltd will never sell your data. Well Working Matters Ltd will only ever share your data with the required organisations to fulfil our legal duties as a training provider.
A complete list of those agencies/organisations are detailed as follows;
- National Institute of Disability Management and Research (NIDMAR) nidmar.ca
- International Disability Management Standards Council UK & Ireland (IDMSC) wcdmpuk&ireland.org
- Scottish Government (Health Improvement Division) if appropriate
- Scottish Qualification Agency (SQA), as appropriate sqa.org.uk
- Wickett Measurement Systems wickettmeasure.ca
If you choose not to give us personal information
We may need to collect personal information by law, or under the terms of our legal obligation as a training provider. If you choose not to give us this personal information, it may prevent us from meeting our obligations. This may result in us being unable to continue as your training provider.
If you have any concerns about the personal information we are asking you to share with us, or have any concerns regarding our intent, please contact our Data Protection Officer Gill Halsey on 07824 387 683 or at admin@wellworkingmatters.co.uk.
Well Working Matters Ltd will only share your personal data with bodies or organisations who fully comply with the GDPR framework. Any data collection that is optional would be made clear at the point of collection.
How long we keep your personal information
We will keep your personal information as long as you are engaged with Well Working Matters Ltd as a student.
After you stop being a student, we may keep your personal information for up to 10 years for one of these reasons;
- To respond to any questions or complaints
- To show that we treated you fairly
- To retain records according to the rules that apply to us.
Well Working Matters Ltd are required to keep data for a variety of legal, regulatory or technical reasons. In some cases, records must be maintained for auditory purposes by funding bodies. We will make sure that your privacy is protected and only use it for those purposes.
How to get a copy of your personal Information?
You can access your personal information by writing to us at this address;
Gill Halsey
Well Working Matters Ltd
85 Douglas Davidson Drive
Rattray
Blairgowrie
Perth & Kinross
PH10 7FG
If would like to discuss any general enquiries prior to making a request, please contact our Data Protection Officer Gill Halsey on 07824 387 683 or admin@wellworkingmatters.co.uk.
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think may be wrong or incomplete. Please contact us if you want to do this and we will take reasonable steps to check it accuracy and correct where necessary.
Sensitive Personal Data
Some of your personal data is deemed to be sensitive, examples of this may include;
- Details of any health problems, disabilities or individual learning needs.
- Information around gender reassignment
We would only share sensitive personal data with your express written permission, or if there is a special legal reasons (such as a request for information by a court).
How to complain
Please let us know if you are unhappy with how we have used your personal information. You can contact us at Well Working Matters Ltd, admin@wellworkingmatters.co.uk.
You also have the right to complain to the Information Commissioners Office.
Formats for sharing data
To request a copy of the personal data we hold, please contact us at Well Working Matters Ltd, admin@wellworkingmatters.co.uk.
You have the right to obtain your personal information in a format that can easily be re-used. You can also ask us to pass your personal information to other organisations in this format. We are happy to work with you to provide your information in an acceptable format, these may include large print.
Well Working Matters Ltd Promise
We promise;
- To keep your data safe and private
- To never sell your data
- To give you ways to manage and review the data which we hold
We hope that this document has assured you that we have taken all the necessary steps to protect your privacy, and that it is clear and easy to understand. If however you would like to discuss any concerns or queries regarding the content of this document, please contact our Data Protection Officer Gill Halsey on 07824 387 683 or at admin@wellworkingmatters.co.uk.
3. EMBEDDED CONTENT
Pages on this site may include embedded content, like YouTube videos, for example. Embedded content from other websites behaves in the exact same way as if you 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. Below you can find a list of the services we use:
The Facebook page plugin is used to display our Facebook timeline on our site. Facebook has its own cookie and privacy policies over which we have no control. There is no installation of cookies from Facebook and your IP is not sent to a Facebook server until you consent to it. See their privacy policy here: Facebook Privacy Policy .
We use the Twitter API to display our tweets timeline on our site. Twitter has its own cookie and privacy policies over which we have no control. Your IP is not sent to a Twitter server until you consent to it. See their privacy policy here: Twitter Privacy Policy .
YOUTUBE
We use YouTube videos embedded on our site. YouTube has its own cookie and privacy policies over which we have no control. There is no installation of cookies from YouTube and your IP is not sent to a YouTube server until you consent to it. See their privacy policy here: YouTube Privacy Policy.
4. COOKIES TO BE REVIEWED BY WWM
This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymized tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.
NECESSARY COOKIES (ALL SITE VISITORS)
- cfduid: Is used for our CDN CloudFlare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. See more information on privacy here: CloudFlare Privacy Policy.
- PHPSESSID: To identify your unique session on the website.
NECESSARY COOKIES (ADDITIONAL FOR LOGGED IN CUSTOMERS)
- wp-auth: Used by WordPress to authenticate logged-in visitors, password authentication and user verification.
- wordpress_logged_in_{hash}: Used by WordPress to authenticate logged-in visitors, password authentication and user verification.
- wordpress_test_cookie Used by WordPress to ensure cookies are working correctly.
- wp-settings-[UID]: WordPress sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
- wp-settings-[UID]:WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
5. WHO HAS ACCESS TO YOUR DATA TO BE REVIEWED BY WWM
If you are not a registered client for our site, there is no personal information we can retain or view regarding yourself.
If you are a client with a registered account, your personal information can be accessed by:
- Our system administrators.
- Our supporters when they (in order to provide support) need to get the information about the client accounts and access.
6. THIRD PARTY ACCESS TO YOUR DATA
We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. The only exceptions to that rule are for partners we have to share limited data with in order to provide the services you expect from us. Please see below:
7. HOW LONG WE RETAIN YOUR DATA
When you submit an enquiry through our Contact Form, its metadata is retained until (if) you tell us to remove it.
8. SECURITY MEASURES TO BE REVIEWED BY WWM
We use the SSL/HTTPS protocol throughout our site. This encrypts our user communications with the servers so that personal identifiable information is not captured/hijacked by third parties without authorization.
In case of a data breach, system administrators will immediately take all needed steps to ensure system integrity, will contact affected users and will attempt to reset passwords if needed.
9. YOUR DATA RIGHTS TO BE REVIEWED BY WWM
GENERAL RIGHTS
If you have a registered account on this website or have left comments, you can request an exported file of the personal data we retain, including any additional data you have provided to us.
You can also request that we erase any of the personal data we have stored. This does not include any data we are obliged to keep for administrative, legal, or security purposes. In short, we cannot erase data that is vital to you being an active customer (i.e. basic account information like an email address).
If you wish that all of your data is erased, we will no longer be able to offer any support or other product-related services to you.
GDPR RIGHTS
Your privacy is critically important to us. Going forward with the GDPR we aim to support the GDPR standard. For more details please see here: EU GDPR Information Portal.
11. RELEASE OF YOUR DATA FOR LEGAL PURPOSES
At times it may become necessary or desirable to Well Working Matters, for legal purposes, to release your information in response to a request from a government agency or a private litigant. You agree that we may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you, and release your information to, third parties where we believe that it is prudent to do so for legal reasons, such as our belief that you have engaged in fraudulent activities. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants.
Any passing on of personal data for legal purposes will only be done in compliance with laws of the country you reside in.
12. AMENDMENTS
We may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will update this page accordingly and require you to accept the amendments in order to be permitted to continue using our services.