DATA PROTECTION AND PRIVACY POLICY

Introduction

Stellar Learning is a trading name of Collins Automation Ltd. Stellar Learning specialises in the provision of individual and organisational learning and development (L & D) solutions.

Our data processing is limited to the information necessary to provide services to our customers and individual clients.

Collins Automation Ltd is registered and fully compliant with the Information Commissioner’s Office (ICO) which is reviewed annually.

Data Controller

The Data Controller is Stella Collins, Creative Director of Collins Automation Ltd

Access to Data

Data users, with access to relevant electronic and paper records, are limited to:

  • Stella Collins, Director
  • Kayleigh Clark, Operations Manager
  • Any network member providing services under the Stellar Learning trading name.

Customers and Clients

For the purposes of this policy, data subjects will be:

  • A ‘customer’, representing an organisation who contracts with Stellar Learning for the provision of group or individual services
  • A ‘client’, representing an individual who contracts directly with Stellar Learning to receive one-to-one services, or is an individual within a contracting customer’s organisation.

Relevant Data

  • Relevant data to be processed will mainly include, but will not be limited to, the following:
  • Training needs analysis information on intending course delegates, provided by the delegates
  • Names / job titles / sections worked in / e-mail addresses of intending course delegates
  • Names / work phone numbers / e-mail addresses of individual clients
  • CVs and personal information forwarded by clients to Stellar Learning for information purposes during a coaching intervention
  • Electronic records of coaching interventions with clients, which are copied to the clients
  • E-mails between Stellar Learning, its customers, and its clients, before, during, and after, a learning and development intervention
  • Success stories and references provided by customers and clients
  • Confidential organisational data provided by customers to enable Stellar Learning’s understanding of the customer’s business
  • Records – phone, conversations, meetings – relating to the conduct of the business with the customer or client
  • Visual recordings of interventions with customers and clients, such recordings being made with the explicit consent of the customer and individual clients
  • Audio recordings of interventions with customers and clients, such recordings being made with the explicit consent of the customer and individual clients.
  • It is not anticipated that sensitive personal data in connection with individuals will be collected, nor will any type of telecommunication be monitored or intercepted.

Retention of Relevant Data

Retention periods of data will vary with the data in question:

  • Training Needs Analyses – up to one year after the intervention
  • All records relating to an ongoing contract with a customer – up to three years after the termination of the contract
  • All records relating to the provision of one-to-one services – up to two years after the cessation of the intervention
  • Success stories and references may be held indefinitely, with the removal of customer and / or client identifying information.

Confidential data will be shredded and / or incinerated on disposal.

Processing of Data

All data will be processed in line with the eight principles contained in The Data Protection Act 1998, as applicable.

Confidentiality

The confidentiality of its customers and clients is of paramount importance to Stellar Learning. The following will be ensured, either directly by the Director, or by the network members, providing services under Stellar Learning’s name:

  • The rights to confidentiality, for all parties, will be established at the onset of every new business relationship, and 1-1 or group intervention
  • Any form of discussion about a customer or client experience (with a group or individual for learning purposes, or with a mentor as part of coaching supervision) will not include any identifying details, unless explicit consent has been given by such customer or client in advance. This includes where customers are paying for coaching interventions for individual staff within their organisation
  • Any agreement to publish identifiable data about a customer or client, for example success stories and references in marketing publications or on a website, will be with the explicit consent of the customer or client in advance.

References

The Data Protection Act 1998
The Human Rights Act 1998
The Public Interest Disclosure Act 1998
The Telecommunications (Lawful Business Practice) Regulations 2000

Last reviewed: May 2018