City & Guilds businesses privacy notice

City & Guilds businesses privacy notice version 1, 9 April 2024

Introduction

City & Guilds and its subsidiary companies (City & Guilds business) share personal data to ensure delivery and improvement of its current and future services as well as customer experience. We also use personal data to identify collaborative opportunities across our customer base and to tailor our service offering to customers and learners. 

Sharing and handling of personal data is always considered alongside our legal responsibilities and contractual obligations. City & Guilds businesses follow a consistent approach to data handling and security through business wide policies and procedures and appropriate contractual measures.

Who are we?

For over 140 years we have worked with people, organisations, and economies to help them identify and develop the skills they need to thrive. We understand the life changing link between skills development, social mobility, prosperity, and success.

We partner with our customers to deliver work-based learning programmes that build competency, to support better prospects for people, organisations, and wider society. We create flexible learning pathways that support lifelong employability, because we believe that people deserve the opportunity to (re)train and (re)learn again and again – gaining new skills at every stage of life, regardless of where they start.

City & Guilds London Institute 

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). Our registered address is Giltspur House, 5-6 Giltspur Street, London, EC1A 9DE (City & Guilds, we, us, or our).

City & Guilds Training

Through our training providers Gen2, Intertrain, City & Guilds Training – Electrical, and our trusted partner network, we’re transforming training. We collaborate with industry to design, develop and deliver leading training solutions that lead to jobs and close skills gaps, through training programmes that set the standard in technical skills and provide learners with the skills and competency to do the job. And by breaking down barriers to learning we help employers attract and retain talent whilst ensuring employees fulfil their potential.

If you have any queries about this Notice or the way in which City & Guilds business processes your personal data, or would like to exercise 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.

How we get personal information?

We may collect and process data through your interaction with us, for example through you sending us an email, connecting with our services, or interacting or communicating with us in any way via our technologies and services. 

We may also collect and process your data if you:

• complete a form on our website(s);
• complete any research initiatives, surveys, or feedback; 
• correspond with us by phone, email, or in writing.
• attend an event organised by us or other organisations.
• complete a course or e-learning module offered by us.
• report a problem or incident. 
• sign up to receive our communications.
• updated your preferences.
• created an account with us via one of our platforms.
• enter a contract with us to receive products and/or services,
• requested a call from our customer support or sales teams.
• interact with our content via platforms such as our website(s) or LinkedIn.
• requested information via a third-party advert expressing an interest in our products and services. 

What personal data we collect about you?

We may collect information that includes your name, email address, internet protocol (IP) address, phone number, postal address, in addition to other details that may include behavioural, location, occupational or other information of a demographic nature.

For example, if you visit any of our City & Guilds subsidiary website(s), we may automatically collect the following personal data and/or 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; and
• information about your visit to our website(s), 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 and similar tracking technologies (e.g. pixels and web beacons) to analyse behaviour, track movements around the website(s) and other channels such as email clicks and opens, provide targeted advertisements, and gather demographic information. 

If you are a tutor, apprentice, or learner, we may also receive personal data about you from a related centre, customer, employer, employer provider, or training provider, when they register to receive products and/or services from us.

Personal data about other people

If you provide personal data to us about any person other than yourself, such as your relatives, next of kin, advisers or suppliers, you must ensure that they understand how their personal data will be processed, and that they have given their permission for you to disclose it to us and for you to allow us, and our third party service providers, to process it

Special category data

We may also collect and/or be provided with special category data, such as data about your physical or mental health or condition. For example, we may collect and/or be provided with special category data to enable us to administer requests for reasonable adjustments, or in relation to an investigation, complaint, or appeal.

How do we use your personal data?

When we ask you to supply us with personal data, we will make it clear whether the personal data we are asking for must be supplied so that we can provide any products and/or services to you, or whether the supply of any personal data we ask for is optional.  

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, offering more personalised experiences, and sales opportunities across our business.

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

Contract performance: we may process your personal data to fulfil a contract, or to take steps linked to a contract, including to:

• provide products and/or services to you.
• take steps in advance of providing a product of service to you.
• communicate with you in relation to the provision of contracted products and/or services; and
• provide you with administrative support such as account creation, security, and responding to issues.

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

• communicate with you in relation to any issues, complaints, or disputes.
• develop, improve, and deliver more personalised marketing and advertising for products and/or services offered by us or another member of the City & Guilds businesses.
• 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.
• improve the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our website(s), content and other methods of communication.
• perform segmentation and analytics on sales/marketing data, determining the effectiveness of promotional campaigns. 
• 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 provide you with newsletters, surveys, or information about our awards and events, offers, and promotions, related to products and/or services offered by us or another City & Guilds subsidiary business, which may be of interest to you. 

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’ or ‘update your preferences’ link in an email from us. 

Note that you have the right to object to the processing of your personal data based on 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 personal data with consent for certain marketing activities via electronic means (email etc),  

With respect to special category data, we may also process such data if necessary for, for compliance with legal responsibilities (such as reasonable adjustments), 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 and other professional advisers, consultants, and professional experts.
• service providers contracted to us in connection with our website(s) or provision of information, products, and services, such as providers of IT services and customer relationship management services.
• Other Awarding Organisations as members of the Joint Council for Qualifications (Contact our members - JCQ Joint Council for Qualifications)
  our digital credential partner platform and
• analytics and search engine providers that assist us in the improvement and optimisation of our website(s). 

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 the UK international data transfer agreement and/or the EU standard contractual clauses, as applicable.

We may share your personal data with companies within the City & Guilds business, including City & Guilds companies registered in the UK and outside of the UK.

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.

How long will we keep your personal data?

We will keep your personal data for the duration of any contract between us. Thereafter, we will keep personal data in order to:

• provide information about your relationship with City & Guilds business.
• 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.
• provision of replacement certificates and confirmation of qualifications and license to practice.  

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 business 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 data protection requirements and good practice to uphold data subjects’ rights and freedoms with respect to personal data.

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

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(s) and other technologies; 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 the 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 not to be subject to solely automated decisions

In certain circumstances you have the right not be subject to solely automated decisions that may have a legal or similar effect, this includes profiling. This right may arise when solely automated processing does not have meaningful human involvement, including application of Artificial Intelligence and other forms of automated processing. If you would like to know more about how we ensure such rights for data subjects 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, machine-readable 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 set 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 via our website(s), 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 website 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 Website and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Notice.