Training privacy policy - RSP UK

Introduction

RSP UK Suction Excavators Ltd (registered at Unit 1, High Barns Farm, Bedford Road, Roxton, Bedfordshire MK44 3ET with company number 10181073) (“RSP“, “we“, “us“, “our“) treats the protection of personal data as of paramount importance.

The purpose of this Privacy Policy is to inform you on what basis and for what purpose we process personal data which we collect from you in relation to training courses and/or other training based services provided or organised by us.

Who is responsible for data processing?

RSP is responsible for the processing of your personal data and is registered as a controller with the UK Information Commissioner’s Office (“ICO“) under registration number ZA319196.

RSP has appointed a data protection officer who can be contacted by email at datenschutz@rsp-germany.com. Please see the “How to contact us” section below for further contact details.

What is personal data

Personal data is any information that relates to an identified or identifiable natural person (a data subject). Identifiable means any natural person who can be identified, directly or indirectly, in particular by association with an identifier such as a name, a customer number, location data or other special features.

What personal data do we collect

When you correspond with us by post, phone, email or otherwise or fill in a form or similar document provided by us in relation to our training services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data including full name, title, date of birth, national insurance number, spoken language, passport sized photograph (if you have not completed a Health Safety & Environment Test since April 2012), a copy of your Large Goods Vehicle licence (if you are sitting one of our Large Goods Vehicle courses) and where required, information used to verify your identity, such as passports, driving licences, EU identity card, work ID card, student ID card, bank or building society statements, utility bills or tax bills;
  2. Contact Data including telephone number, email address, home address, work address and the name of the organisation that you work for and next of kin details including name and telephone number;
  3. Booking Data including EUSR number, CPCS number and health details if applicable (for example, details of any allergies, dietary requirements, learning, reading, hearing or writing difficulties and/or disabilities which we should know about to enable us to put in place appropriate measures); and
  4. Training Data including voice recordings, a transcript of the voice recording and video footage where required.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to allow you to attend a training session).

How do we use your personal data?

We will only use your personal data when the law allows us to. We have set out below in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Purpose / ActivityCategory of personal dataLawful basis of processing
To process your booking for a training course and to facilitate you attending a training course.Identity Data
Contact Data
Booking Data		Performance of a contract with you in accordance with Article 6(1)(b) of the UK GDPR.

We process special category personal data on the basis of your consent in accordance with Article 9(2)(a) of the UK GDPR and/or for reasons of substantial public interest in accordance with Article 9(2)(g).
To manage our relationship with you which will include notifying you about changes to our terms and conditions or privacy policy.Identity Data
Contact Data		Performance of a contract with you in accordance with Article 6(1)(b) of the UK GDPR to manage our relationship with you.
To send you reminders about the expiration of your training qualifications.Identity Data
Contact Data		Legitimate interests in accordance with Article 6(1)(f) of the UK GDPR to send you reminders about the expiration of your training qualifications.
To ask you to complete a feedback form or survey.Identity Data
Contact Data		Legitimate interests in accordance with Article 6(1)(f) of the UK GDPR to study delegates feedback to allow us to improve our training services.
To contact your next of kin in an emergency.Identity Data
Contact Data		Legitimate interests in accordance with Article 6(1)(f) of the UK GDPR to enable us to assist you in the event of an emergency.
To record and/or video a training session and/or examination where required by an external training provider / examiner and for quality assurance / monitoring purposes.Training DataPerformance of a contract with you in accordance with Article 6(1)(b) of the UK GDPR to enable us to provide you with the training qualification.

Legitimate interests in accordance with Article 6(1)(f) of the UK GDPR to meet the requirements of external training providers / examiners and to ensure our services meet the required standards.

 

How long do we retain your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting our data protection officer using the details above.

Where do we store your personal data

We will store your personal data on secure servers located in our office in Roxton, Bedfordshire, England. The data from our servers is encrypted at the point of backup and transmitted to data storage devices located at our IT provider’s offices in Tamworth, Staffordshire, England. Our IT provider will not be able to access your personal data.

Who do we share your personal data with?

We may share your personal data with the following parties:

  1. third party service providers including external training providers such as the Construction Industry Training Board (CITB), the National Open College Network (NOCN), the Energy & Utility Skills Register (EUSR) and Suction Excavator Solutions;
  2. professional advisers acting as processors or separate controllers including lawyers, bankers, auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
  3. third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy; and
  4. external agencies, regulators, authorities and organisations (including police agencies and the relevant local authority) for the purpose of complying with applicable legal and regulatory obligations.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Is the use of automated decision making or profiling carried out?

We do not use automated decision-making or profiling in relation to the training services that we provide.

International transfer of personal data

We will not share your personal data to countries located outside the UK.

Your data protection rights

You have the following rights in relation to the personal data we hold about you. if you would like to exercise any of these rights, please contact us using the details set out under the “How to contact us” section below:

  1. Access: you have a right to request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
  2. Rectification: you have a right to request correction of the personal data that we hold about you that is inaccurate. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  3. Erasure: you have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object: you have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Restriction: you have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
    • where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Portability: you have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw Consent: you have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
  8. Make a Complaint: you also have the right to make a complaint at any time to the ICO which is the UK Data Protection Supervisory Authority (please see contact details at www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, please contact us in the first instance.

If you wish to exercise any of the rights set out above, please contact our data protection officer using the details above.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Security of your personal data

We take appropriate steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information over the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of the data sent to us over the internet and every transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access whenever possible.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Changes to this privacy policy

If we change this Privacy Policy, we will post the changes to our website or send you an email so that you always know what information we collect, how we use it, and under what circumstances we may disclose it. This Privacy Policy was last updated on 18 May 2022.

How to contact us

If you have any questions or comments about this Privacy Policy or the handling of your personal data, please contact us:

  1. by email at training@rsp-uk.co.uk;
  2. by post at Training, RSP UK Suction Excavators Ltd, Unit 1, High Barns Farm, Bedford Road, Roxton, Bedfordshire MK44 3ET; or
  3. by telephone at 0844 543 4575.