Privacy Policy

At Smart Choices Training we are committed to protecting and respecting your privacy.

This policy explains who we are, what, when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

In this policy where we use the words personal information we use these words to describe information that is about you and which identifies you as an individual.

Who are we?

Smart Choices Training is an online learning and compliance business, helping businesses to learn more about modern slavery prevention with measurable results.

Bagshaw Consultancy Services Limited, trading as Smart Choices Training, is a company incorporated under the laws of England (registered number 9527486) having its registered office and address for service at 6 Hawthorn Road, Bollington, Cheshire, SK10 5JN. We are registered as a data controller with the UK Information Commissioner’s Office (ICO).

For the purposes of data protection law, Smart Choices Training is the data controller in respect of the personal information it collects and uses as part of our activities. We may also be a data processor in some instances.

If you are providing personal information to us relating to a third party (for example, an administrator providing information on behalf of a work colleague) you automatically confirm that you have the consent of the third party to share such personal information with us.  

How do we collect information about you?

Information is provided to SMART CHOICES TRAINING by:

1. Filling out an enquiry form on http://www.smartchoicestraining.co.uk
2. Correspondence by phone, email or in person
3. Requests to join our social media channels such as Facebook, LinkedIn and Twitter
4. Register to listen to our webinars or attend an event
5. Surveys to support continuous improvements in customer or learner experience
6. Purchasing or completing one of our online programmes, products or services

What information do we collect?

We may collect the following personal data:

The information that you provide to us may include: your name, postal address, email address, telephone number, mobile number, payment information, online identifiers including IP address or cookie identifier, business activities (where it amounts to personal data) and your password to access your individual accounts.

Where you complete an online course, we will collect information including your name and email address, the date and time you accessed the course, length of time it took you to complete the course, your answers, feedback and a record of your completion of the course.

As with all your data, you can ask us to delete or modify this information at any time. Please see further information about your privacy rights below.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

1. to comply with our legal and regulatory obligations;
2. for the performance of our contract with you or to take steps at your request before entering into a contract;
3. for our legitimate interests or those of a third party; or
4. where you have given consent.

 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The list below explains what we use (process) your personal information for and our legal basis for doing so:

1. Enquiries and Feedback:We use personal information submitted to us when you make an enquiry or when you provide feedback to us for our legitimate interests of engaging with potential customers and identifying how we can improve our services.
2. Business Contacts:We use personal contact details of business contacts (including agents, contractors and individuals that represent our suppliers and business partners) for our own legitimate interests of running our business.
3. Business Information: In limited circumstances we may collect business information which identifies the activities of a living person for our legitimate business interest in providing your client or customer with information about your business practices.
4. Financial Information: Where we process your payment directly, we collect financial information for the purposes of processing your order and entering into a contract with Smart Choices Training.
5. Course Access Information: We collect information about when and how you access our courses for the purposes of confirming your completion of a course and our legitimate interest in ensuring proper functioning of the course material.
6. Technical Information: The technical information gathered from the use of our website (including through our use of cookies) which may include personal data, is used for our legitimate interest of ensuring that our website is functioning properly and to help us make business decisions about the information to be provided on our website.
7. Marketing:We may use your personal information to send you updates about our services, including exclusive offers, promotions or new courses. We have a legitimate interest in processing your personal information for marketing purposes. This means we do not usually need your consent to send you marketing communications. However, where consent is needed, we will ask for this consent separately. You have the right to opt out of receiving marketing communications at any time (please see “How to unsubscribe from marketing communications” below). We will always treat your personal information with utmost respect and never share it with other organisations for marketing purposes.

How long do we keep your data?

If you submit your details as a prospective customer, we’ll store this data for one year.

If you purchase a product, we’ll store your data for 7 years after the completion of the course. We need to hold your data to confirm when and what course you completed.

Technical information about your visit to our website may be kept for the following retention periods:

1. Google unique visitor tracking – 26 months.
2. Google analytics session – 30 minutes.
3. Google referral – 6 months.

For more information about how long we keep your data, please contact us at the details above.

How do we keep your data secure?

We take your privacy and security very seriously, and take appropriate measures to ensure that your data is protected from misuse.

We have an ongoing programme of improvement and development in order to protect your personal data from unauthorised access, accidental loss and/or destruction.

We use the following security measures to protect your data:

• Industry standard secure sockets layer (SSL) technology, to protect personal information, as well as the use of specific logins and secure passwords
• Our web servers and database servers are held in a securely managed data centre and are further protected with a personal firewall and inherent security layers
• firewalls, anti-virus, secure file transfers as used where required
• encryption of emails is used where required
• office security
• access to personal data is granted on an “as-needed” basis
• an incident and disaster recovery protocol framework is in place to help us manage any data security breaches

Please be aware that communications over the internet, such as e-mails/instant messaging, are not secure unless they have been encrypted. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

Who do we share your data with?

In order to provide and improve our services, we may share relevant information with the following third parties. All of our third parties are trusted and take appropriate measures to ensure your data is secure.

1. Txtlocal Ltd (who we use in some circumstances to manage our communications with you);
2. Google LLC (who collect survey data); and
3. Our professional advisers where required.

Technical information gathered about your use of our website may be shared with Google Analytics. We work with Google Analytics to automatically collect information including: IP address; MAC (Media Access Control) address; unique identifier or other persistent or non-persistent device identifier; device software platform and firmware, mobile phone carrier and geo location data to help us understand your use of our website such as how often you return, what parts of the website you visit, how you use the website and how long you spend on the website. This third party provider is prohibited from using our data for any other purposes.

Where you are completing a course at the request of a customer or client, information obtained within that course including the date of completion (or non-completion) and your answers will be provided to that customer or client. This information may be anonymised or may indicate your individual company’s responses.

We can disclose your personal information to other third parties, for example:

1. In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
2. If substantially all of our assets are acquired by a third party (or are subject to a reorganisation within our corporate group), personal information held by us will be one of the transferred assets; and
3. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation. 

Your rights regarding your personal data

Under data protection laws, you have many rights regarding your personal data. These include the right to:

1. fair processing of information and transparency over how we use your use personal data (as contained in this policy)
2. require us to correct mistakes in your information which we hold
3. require us to delete your personal information in certain situations
4. receive a copy of the personal information you’ve provided to us in a structured, commonly-used and machine-readable format
5. object at any time to processing of personal information concerning you for direct marketing
6. object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
7. object in certain situations to our continued processing of your personal information
8. otherwise restrict our processing of your personal information in certain circumstances
9. claim compensation for damages caused by our breach of any data protection laws

For full information on your rights, including how and when they apply, please contact us or seek guidance from the ICO.

You can exercise any of these rights by emailing hello@smartchoicestraining.co.uk, by phoning 0161 327 2435 or by writing to Smart Choices Training, 6 Hawthorn Road, Bollington, Cheshire, SK10 5JN and providing the following information: 

1. Your name
2. Your postal address
3. A telephone number where you can be reached
4. A photocopy of your passport or driving license
5. Your signature and the date of the request
6. Signed authority from the individual whose data is required if you are applying on their behalf

How to delete or modify your personal information

If for any reason you’d like us to delete or modify your data, or opt-out of any communications, you can do this for free. Contact us at hello@smartchoicestraining.co.uk and we’ll meet your request within one month.

However, you should be aware that we may not be able to delete your personal data if there is a legitimate reason for us to continue to hold your data; for example, we may continue to hold personal data where we are under a legal obligation to do so, or where such information may need to be used by us in the exercise or defence of any legal claim.

 How to request a copy of your personal information

You can ask us for a copy of the information we hold on you at any time, free of charge, by contacting us on hello@smartchoicestraining.co.uk.  We’ll respond without undue delay and at the latest within one month of receipt unless we confirm otherwise.

How to unsubscribe from marketing communications

To opt-out of our emails or other marketing communications, click the ‘unsubscribe’ button at the bottom of any email or text “STOP” in response to any marketing text message we send you.

How to make a complaint

We’ll do our best to resolve any complaint or question you have about the data you store with us.

If you believe we’ve breached data protection laws, you have the right to lodge a complaint with the relevant supervisory body where you work, live, or where the alleged breach occurred.

In the UK, this is the ICO, which can be reached here or by phone on 0303 123 1111.

Cookies

Cookies are very small text files that are stored on your device when you visit some websites or mobile apps.  They’re used by many website owners, including ICS Learn.

We use cookies to collect information about how and when you arrive on our website, the pages you view when you’re on the site, how long you spend on each page, and actions you take on the site (for example, scrolling or downloading a course guide). You can find out more under ‘Cookies’ below.

We may also collect technical data such as IP address, login information, browser type and version, time zone setting, browser plug-in types and version, operating system, and platform, page response times, download errors, and phone numbers used to contact us.

We use this information to tailor and target our communications and adverts to your interests; analyse and enhance the effectiveness of our website and marketing campaigns; better understand our students and prospective students; and improve the student journey.

We may combine this information with other details you’ve submitted to gain a more detailed picture of our student journey and to provide you with a personalised service that meets your needs.

We may also receive information from third parties that we work with, for example: business partners; subcontractors in the technical, payment and delivery services; advertising networks; analytics providers; and search information providers.

You won’t receive marketing from third parties as a result of sharing your data with us.

How we use cookies

We use cookies both to measure and improve the performance of our site. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of the website which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

The cookies we use are ‘analytical’ cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily.

Third Party Cookies

We use a number of web analytics and social media tools to measure and enhance visitor interaction on our site. If you already use these platforms their cookies may be set through our website. Data may then be collected by these companies that enables them to serve up adverts on other sites that they think are relevant to your interests. You can use your web browser settings to manage and reject third party cookies.

Opting out of cookies

When you visit our site for the first time, you’ll be invited to review this policy and accept our use of cookies. Clicking ‘Continue’, clicking on the page or closing the panel will confirm that you’re happy for us to use cookies in this way.

You can turn off cookies in your browser settings, but it’s important to note that if you do, you might not be able to use all of the services on our website.

How and when we may change this policy

We will keep this policy under review and any changes made from time to time will be posted on this page.

Please check back regularly to keep informed of updates or changes to this privacy statement.