The Forklift Training Centre Limited © 2018 All rights reserved. — The Forklift Training Centre Limited - Company Registered England 7467533
INTRODUCTION
The Forklift training centre limited needs to gather and use certain information about individuals.
Information can be held by The Forklift training centre limited relating to customers, suppliers, instructors, business contacts, course delegates, employees and other people that the organisation has a relationship with or may need to contact.
2.0 PERSONAL DATA HELD AND REASONS FOR PROCESSING
The Forklift training centre limited holds electronic data required to:
Carry out its day to day functionality.
Produce a certificate for an individual who has attended a course.
Produce ‘delegate reports,’ when requested, by a company wanting to have details of their employees who have been on a course provided by JM Safety Training Limited.
Share the individual’s details with the appropriate accrediting body for the type of training undertaken.
Process sales invoices to companies or individuals for services or training materials provided by JM Safety Training Limited.
Process purchase invoices for services or materials provided to JM Safety Training Limited.
The Forklift training centre limited holds electronic data on individuals in its accounting package, Office 365.
The Forklift training centre limited records and stores data on paper forms required to:
Carry out its day to day functionality, to test delegates who attend its courses.
To produce a certificate for an individual who has attended a course.
The Forklift training centre limited holds information in its Computer system.
Data can be collected/stored for:
The company and company contacts with whom the The Forklift training centre limitedSales Teams and other departments communicate.
The individual contacts, employed by these companies, who attend a training course.
3.0 DATA COLLECTION AND STORAGE
Data held on the Computer system consists of
Company contacts
The company whom the individual is employed by
Name
Job title and role within the company
Contact’s phone numbers
Contact’s company email address
Company address
Opt in / opt out of which type of marketing communications
Individual’s data
Company whom the individual is employed by
Name
Employee Number
Date of birth
Course dates
Course details
Scores
Passed / failed
Individuals’ data is collected through the completion of forms known as test sheets and course evaluation forms. These forms are completed by the individual on the course and by a sub-contracted instructor who is authorised as a sub-processor by JM Safety Training Limited.
The forms will include a statement explaining why we need to collect the data and with whom we share it.
Data collected is used to create a certificate for the individual (delegate) which is then either sent to the contact at the individual’s workplace or a central contact, dependent upon the terms agreed in the contract between the company and JM Safety Training Limited.
Individual’s data shared to the following people / organisations
With the company that ordered the training in the form of a certificate and / or badge. This information will only include:
Name
Employee number
Truck details (for the truck used during testing)
Dates of training
Instructor / Examiner that carried out the training / testing
Tracking online activity
The Forklift training centre limited track activity on their website and engagement with their online marketing via cookies and marketing analysis tools, for example Google Analytics. Data retention controls are in place to periodically remove user data over time.
Cookies are also used on the The Forklift training centre limited website to track shopping basket contents and remember where users are in the order process. Users can disable any cookies stored on their computer, but this may limit the functionality of the The Forklift training centre limited website.
The following are necessary for the website to function properly - the The Forklift training centre limited website will:
remember what is in your shopping basket
remember where you are in the order process
remember that you are logged in and that your session is secure. You need to be logged in to complete an order
The website will not share any personal information with third parties.
4.0 SHARING OF DATA
It is a function of all training companies that they share data about who has been trained with the appropriate accrediting body.
The individual’s data is shared with the appropriate accrediting body as required by Health and Safety Law. This will include:
Name
Date of birth
Course start date
Course end date
Length of course
Duration of course
Test date
Instructor / Examiner name and registration number
Course type
Truck type
All the data that we hold on individuals who have done courses with us is classed as low risk. We hold no financial records or home addresses for these individuals.
5.0 ACCURACY OF DATA
COLLECTION OF NEW CONTACTS AND ACCURACY OF DATA
The Forklift training centre limited will endeavour to accurately collect the data it needs and provide clear and transparent justification for doing so, referenced at the point of collection, including a privacy policy that is accessible via the website or the App (once developed).
New contacts and sales leads must be constantly brought in to the company to ensure survival and growth.
The Forklift training centre limited aim to bring in new contacts through the following ways, although this is not an exhaustive list
Website
Cold calling
Visits
Leads across company groups
Leads through trade union groups
Marketing – online and trade magazines
Trade shows
The Forklift training centre limited will only market to / contact companies where we believe content will be of legitimate interest to the company / individual but will always provide them the opportunity to opt out via links contained in every email.
The Forklift training centre limited does not use purchased leads to build up its contact database.
6.0 DATA SECURITY AND DATA BREACHES
The Forklift training centre limitedwill protect itself to the best of its ability against data breaches through staff training and by keeping its IT systems up to date with the latest anti-virus, ransomware and firewall protection, and by complying with the latest best practice for data storage and protection. JM Safety Training Limited’s website will also be tested against hackers ensuring that there is no ‘backdoor’ entry to gain access to the IT system and individual’s data. If The Forklift training centre limited do suffer a personal data breach, the Data Protection Leader will notify the ICO and the affected parties within 72 hours of the breach. The Forklift training centre limited consider a breach to be an occurrence involving a loss of data which presents a risk to the rights and freedom of any individuals involved, and could result in:
Discrimination
Damage to reputation
Financial loss
Loss of confidentiality
Any other significant economic or social disadvantage.
7.0 DISCLOSING DATA FOR OTHER REASONS
In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies without consent of the data subject.
Under these circumstances, The Forklift training centre limited will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
8.0 PROVIDING INFORMATION
The Forklift training centre limited aims to ensure that individuals are aware that their data is being processed and that they understand:
How the data is being used
How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
This is available on request. A version of this statement is also available on the company’s website.
9.0 RIGHT TO BE FORGOTTEN
Due to the nature of the industry in which The Forklift training centre limited operates, we believe in the Right to be Forgotten.
Attendees of a course: if an individual employed by a company requests the right to be forgotten, The Forklift training centre limited will first check with the company to ensure that they approve this data removal from their training records. Once approved, the data can be removed from the CRM.
CRM Contact: if a contact no longer wishes to be contacted then we can remove that individual’s data from the CRM. If we have provided training for their company then we cannot delete their company record from our CRM as individual training records will be associated to it.
Tracked online activity: anyone who would like records of their online activity removed can request to do so by emailing the Data Controller.
10.0 DELETING DATA
If a contract ends between The Forklift training centre limited and the customer, The Forklift training centre limited can provide all the personal data that they hold about the customer and the individuals within the organisation, if requested.
The Forklift training centre limited will not delete the associated training records as this data may be requested as evidence of training if for example, an individual has an accident.
Personal data for people who have attended one of our courses has to be stored and recorded to meet standards set by the Health and Safety Executive. The industry standard for keeping this data is a minimum of 7 years. After 7 years all paper copies of the personal data collected will be shredded on-site by an approved shredding company. Electronic data is stored back to 2010. Our customers use this data to prove compliance to the standards set within the ACOP L117
11.0 If you have a complaint
If you have a complaint regarding the use of your personal data then please contact us by:
Writing to: Unit 2-2 Warrington road Widnes WA80 TD or email to: info@forkliftexpert.uk
And we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioners Office (lCO), you can contact them on 01625 545745 or 0303 123 1113. You also have the right to judicial remedy against a legally binding decision of the ICO where you consider that your rights under this regulation have been infringed as a result of the processing of your personal data.