Who We Are

Polaris Learning Limited (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Polaris Learning Limited’s registered office is at Unit 12 Meadows Industrial Estate Station Road Oldmeldrum AB51 0EZ and we are a company registered in Scotland under company number SC295434 We are registered on the Information Commissioner’s Office Register; registration number Z954545X and act as the data controller/data processor when processing your data. Our designated Data Protection Officer/Appointed Person is Helen Rush who can be contacted at the above Address.

Information That We Collect

Polaris Learning Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that we collect is: –

• Name
• Date of Birth*
• Home Address*
• Personal Email*
• Business Email*
• Home Telephone Number*
• Mobile Telephone Number*
• National Insurance Number*
• Special Category Data (e. health/medical information, details about religion, sexuality etc)*

*We only collect this information if it is required for funding or qualification bodies.

We collect information in the below ways: –

Hard Copy Forms and Electronic Forms.  We do not collect any personal data from our website via Cookies.

How We Use Your Personal Data (Legal Basis for Processing)

Polaris Learning Limited takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

• We collect your personal data in the performance of a contract or to provide a service and to ensure that information is completed and can be sent out to your preferred address
• We collect and store your personal data as part of our legal obligation for business accounting and awarding body criteria
• In relation to qualifications, we have a legal obligation to share your personal data with Skills Development Scotland who are the funding body for the MA programmes and require us to collect the information, ILM and City & Guilds.

We will occasionally send out marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests

Your Rights

You have the right to access any personal information that Polaris Learning Limited processes about you and to request information about: –

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

The qualification bodies that we may need to provide this information to are:

SDS

City and Guilds

ILM

SQA

Privacy Statements of Qualification Bodies

Candidates will be registered promptly in keeping with awarding body regulations and records will be kept securely under the Data Protection Act. Information will only be retained where necessary for awarding body and funding body compliance and will only be accessed by the centre manager and programme staff for reasons of programme management.

No information will be released to any other person or organisation.

It is a good idea to read the full Privacy Notices of the qualification bodies and you can do this by visiting their sites below:

ILM candidates:           https://www.i-l-m.com/privacy/learnerpersonaldata

City & Guilds:              https://www.cityandguilds.com/help/privacy-statement

SQA:                            SQA’s Privacy Statement

Special Categories Data (if applicable)

Owing to the products or services that we offer, Polaris Learning Limited sometimes needs to process sensitive personal information (known as special category data) about you, to meet Scottish government criteria and awarding bodies. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.

Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Safeguarding Measures

Polaris Learning Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: –

Logins Encryptions, restricted access, IT authentication, firewalls, anti-virus/malware on all IT equipment and staff training.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Awarding Bodies / Funding Bodies however, as this information is required for us to provide you with our services/deliver your products/legitimate interests, we will not be able to offer some/all our services without it.

Legitimate Interests – for Business Clients

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

Legitimate Interests Example

Polaris Learning Limited will occasionally send you specific products/services/promotions by email/SMS/post that have been identified as being beneficial to our customers and in your interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.

Consent for Learners or Candidates (Completing training or qualifications with us)

Occasionally, Polaris Learning Limited would like to contact you with the specific products/services/promotions that we provide.

If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting Polaris Learning Limited directly.

How Long We Keep Your Data

Polaris Learning Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 7 years after which time it will be destroyed.

Cookie Notice

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org.

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.

However, we do not use Cookies in this way and we cannot identify you from the Cookies, as we only use Cookies to gather general statistics on website usage.

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