General Data Protection Regulation
At PassPharma Ltd, we are serious about protecting and safely storing the personal data we collect from you. This notice aims to explain how we obtain and use your personal data in order to better support your learning journey, effectively provide services to you, and meet legal requirements.
If you have any questions or concerns after reading this notice, please don’t hesitate to contact us
Who we are
PassPharma Ltd is the data controller when it comes to the processing activities mentioned in this document. What this means is that PassPharma Ltd decides why and how to collect and process your personal data.
In this policy PassPharma Ltd is referred to whenever ‘we’, ‘our’ or ‘us’ is used.
Who you are
This policy notice applies to you if you have enrolled on a course or service provided by PassPharma, or registered as a mentor or expert witness for one of our learners. While this notice provides an overview of our data protection policy, more specific information about how your personal data is used and processed will be provided to you upon enrolment.
What information do we collect and how do we collect it?
Information that we collect from you
There are a number of ways we may collect information from you.
An example would be your initial application for the course. Data we would have collected from you at that time would include:
· Personal details
o Full name
o Contact details etc.
· Employment details
o Where you work
o Your work hours
o Your employer’s details etc.
· Personal Documents
o Photocopy of birth certificate
o Photocopy of driver’s licence
o Photocopy of passport
o Photocopy of previously obtained qualification(s)
o Photocopy of marriage certificate etc.
We may also have collected information about special categories of data such as your racial or ethnic origin, religious beliefs, sexual orientation etc.
Throughout your course, you may be asked to provide additional data during personal communication with you, such as during review calls with members of our staff or over email.
Information that is automatically collected
We will automatically collect information about your participation in our courses, your use of our website, and any assessment activities that you take part in.
We may automatically collect information when you browse our website; more information about this can be found in our section about Cookies.
We may also record telephone conversations as a means of improving the service that we provide to you. You will be asked for your permission before a telephone call is recorded.
Information that we collect from others
We may collect some information about you from other places. These include:
· The Learning Records Service (LRS). We use this service to check what prior qualifications you hold, to compare the qualifications on the LRS to those you declare on enrolment paperwork, as well as to confirm your Personal Learning Record (PLR) and add this information to your evidence pack;
· Your employer, to confirm your eligibility to enrol on to a PassPharma Training course and to check basic information including the spelling of your name, your employee number and the location and branch number of your workplace.
We always ensure that we have a lawful basis for processing the personal data that we collect. In this case the lawful basis for processing your data is that it’s necessary under your employment contract, or it’s necessary for us to comply with the law. If we need your consent to process any of your data, we’ll obtain this from you.
How will we use your personal information?
We’re committed to using your personal data responsibly and lawfully.
The majority of the information that we collect from you is used in order to deliver our services to you and support you in completing your course. It also allows us to meet our legal requirements as an education provider.
An example of this is using your contact information and the information automatically collected about how you are completing your course. This information would be combined to provide a review call to you which is part of the support we offer in completing your course.
If we do not collect this information from you, we may not be able to accurately or effectively provide the administration services and support that you will need in order to successfully achieve a qualification.
The information that we collect from you is all stored within the UK, with exception to surveys via SurveyMonkey and Mailchimp. The information you provide in these surveys is protected by the appropriate safeguards for non-EU data transfer.
In order to make sure that the information we collect from you is accurate, it is important that you contact us to advise us of any changes to your personal information.
Who will we share your information with?
There are a number of situations in which we would share your personal information with third parties.
We will share information about you and the progression of your course with your employer. This is a standard requirement that you will have consented to at the point of enrolment on your course. You do have the right to withdraw your consent for this, however there are legal requirements related to this sharing of information and withdrawing your consent may have a serious effect on your employment.
We ask our learners to undertake a CognAssist assessment for the purposes of identifying any additional learning needs. This helps PassPharma to provide bespoke support for the individual learner to ensure they receive the best possible opportunity to complete their course. All learners receive a copy of the assessment results for future usage when engaging with educational programmes.
Our learner management system
Our Learner Management System (LMS) and is where your course materials are accessed. Our LMS is hosted on the developer’s server. The developer’s servers are based in the UK.
How long do we keep your information for?
Our Retention Policy lists the type of data we process and for how long it is kept.
The length of time for which we will retain your data is worked out with reference to a number of factors, for example our purpose for collecting the information in the first place, and the legal obligations that we have.
What rights do you have over the personal information we hold?
You have rights over the information that we hold on you. Some of these rights will be newly enforceable under the General Data Protection Regulation (GDPR) on 25th of May, 2018. The UK has chosen to abide by the GDPR after our exit from the European Union. If you would like to exercise these rights, please contact us using the contact details listed at the end of this policy notice.
Under the GDPR, you have the right to:
· Access any personal information that we hold about you, which must be provided in a portable electronic format
· Correct any inaccuracies in the personal information that we hold about you
· Request that we stop sending you direct marketing communications
In particular situations, you have the right to:
· Have your personal information removed from the systems we use
· Change and restrict the way that we process your personal data
· Receive a copy of your personal data in an electronic data file
· Object to processing of your personal data by us
If you have concerns about the ways that we have processed or used your personal information, it is within your rights to complain to the Information Commissioner’s Office (ICO). More details on this subject can be found on the ICO’s website.
A cookie is a small file (typically letters and numbers) which may be placed on your computer when you access our website. A cookie cannot read your computer’s hard disk or make any information available to third parties. Through the cookie we can recognise your computer and browsing activity if you return to the website, allowing us to provide you with a better service. We also track user traffic patterns in order to determine the effectiveness of our website. We do not release this information to third parties.
If you would like more information on cookies click here.
We use Google Analytics which allows us to collect information about how you use our site. If you access our website directly (and not via an email) you’re visits will be tracked anonymously.
We use Google Analytics to understand how our website is being used in order to improve the experience for you. All user data is anonymous.
We use social buttons such as Twitter, Google, Facebook and LinkedIn to share or bookmark pages on our site or email updates. Those sites may collect information about your internet activity, including if your visit to our site (even if you don’t click on the button if you’re logged on to their site). You should check the privacy and cookies policy of each of these sites to see how they use your information and find out how to opt out and delete such information.
You are able to manage cookies. For more information click here. If you want to block all cookies all of the time you can set your computer preferences to do so. However, if you are a registered user of PassPharma you will need to allow “per-session” cookies in order to access password-protected sites.
Our website does not require you to input personal data to use it. You may however volunteer personal data such as your name and email address to request information, updates and our services. That information is required to deal with your query appropriately.
Please direct any queries about this policy or about how we collect and process your personal information to the contact details below: