Privacy Policy

Captiva Learning Limited (The Company) is a Registered Training Provider which provides apprenticeship training services. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or from another source.

The Company must have a legal basis for processing your personal data. For the purposes of providing you with apprenticeship training we will only use your personal data in accordance with the terms of the following statement.

1. Collection and Use of Personal Data

A. Purpose of processing and legal basis

The Company has collected your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with apprenticeship training. This includes for example, assessing your suitability for those training course, updating our databases with any relevant information.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:

• Your consent

• Where we have a legitimate interest

• To comply with a legal obligation that we have

• To fulfil a contractual obligation that we have with you

B. Categories of data

The Company may collect personal and sensitive personal data about you. This may include the data items listed below, and if necessary, additional information may also be collected:

Personal data:

• Identification

• Right to work documentation

• National Insurance Number

• Email addresses

• Computer IP addresses

• Nationality

• Ethnicity

• Marital Status

• Qualifications

• Employer information

Sensitive personal data:

• Health information

• Nationality

• Biometrics (where used for ID purposes)

• DBS Information – Obtaining copy of DBS certificate

C. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Providing outstanding professional learning opportunities for all career pathways within education.

• Advice and Guidance with the apprenticeship scheme and how it works

• CPD (Continuing Professional Development) tracking and documenting the skills, knowledge and experience that the learner will gain both formally and informally as they work, beyond any initial training. It's a record of what you experience, learn and then apply to your day to day practices

• Offer additional services from the Company

We may periodically send you information that we think you may find interesting, but we will only do this where we believe there is legitimate interest in doing so, and where we believe the information will be of positive benefit to you. We take your privacy very seriously, so if you do not wish to continue to receive this information then please let us know by unsubscribing.

D. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

• Our IT providers

• University of Roehampton / University of Buckingham - Learner data as required

• Department of Education - ESFA for the apprenticeship levy

2. Overseas Transfers

The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of apprenticeship training to Apprentices. We currently do not operate this service outside of the UK.

3. Data Retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. Where the Company has obtained your consent to process your personal sensitive data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your sensitive personal data.

4. Your Rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;

• The right of access to the personal data the Company processes on you;

• The right to rectification of your personal data;

• The right to erasure of your personal data in certain circumstances;

• The right to restrict processing of your personal data;

• The right to data portability in certain circumstances;

• The right to object to the processing of your personal data that was based on a public or legitimate interest;

• The right not to be subjected to automated decision making and profiling; and

• The right to withdraw consent at any time.

Where you have consented to the Company processing your sensitive personal data you have the right to withdraw that consent at any time by contacting the data protection officer at: dataprotectionofficer@captivalearning.com

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

5. Source of the Personal Data

The Company sourced your personal data and sensitive personal data by the following means:

• Provided by the apprentice

• Applications received via email

• Applications received from company website

• Referrals from other sources

6. Cookies

The Captiva Learning website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. We use both session and persistent cookies on the Captiva Learning website.

We use cookies to distinguish you from other users of our website and remember specific information about you that enables us to provide you with a better user experience when re-visiting our website. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

By continuing to browse the site, you are agreeing to our use of cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

7. Data Protection Registration

We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is ZA256926.

The website is owned and operated by Captiva Learning Ltd.

We are registered in England and Wales under registration number 10021355, and our registered office is at 4 Cam Road, Stratford, E15 2SN. 15.3 Our principal place of business is at 4 Cam Road, Stratford, E15 2SN.

8. Complaints or Queries

If you wish to complain about this privacy notice or any of the procedures set out in it, please contact: dataprotectionofficer@captivalearning.com

You also have the right to raise concerns with Information ICO Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.