Goldcrest Academy is committed to protecting your privacy and maintaining the security of any personal information received from you in accordance with requirements of General Data Protection Regulation (GDPR) and applicable data protection law which changes on 25 May 2018. The purpose of this policy is to explain to you what personal information we collect and how we may use it. Information is collected when you:
- Visit the Goldcrest Academy Limited website – https://goldcrestacademy.co.uk;
- Register for, order, purchase, access or use any Goldcrest Academy products or services (in any medium, physical or digital);
- Use of any Goldcrest Academy social media channel
- Send personal data to Goldcrest Academy by any other means
Who is the Data Controller?
Goldcrest Academy Limited, our registered office address is: 4th floor Radius House, 51 Clarendon Road, Watford WD17 1HP – please note all communication related to data protection must be sent to the address details provided below.
Contact details for the Data Protection Officer
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
How do we collect personal data about you?
Data may be collected about you when you:
- contact us for course information by email, telephone or via the website
- create an account on our website
- speak with client, service or academic team members
- request marketing material to be sent to you
- subscribe to our newsletter
- complete a survey or give us feedback
- enter a competition or promotion
- subscribe, register, view or take part in any Goldcrest Academy webinar
- place an order with us online
- complete a CIM membership application
- submit work for feedback (lesson activities, assignment plan, close to final working draft)
- take exams or other forms of assessment
- submit requests for deferral for CIM assessments
- raise any issues with your tutor
- When you report a problem with Goldcrest Academy’s website or any of its services
Your personal data
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped below:
Contact data – includes billing address, delivery address, postal address, email address, telephone numbers (work, mobile).
Identity data – this includes first name, birth name (where relevant), last name, birth date, CIM membership number (as appropriate or advised during the course by you to us), marital status, title, date of birth and gender.
Eligibility data – includes education/academic history, records of qualifications and/or training and references, experience for course entry level purposes.
Employment data – this is relevant, where your place on a course or programme is funded by your employer/future employer and includes name of employer, job title, work contact details (email address, telephone number and postal address) and employment start and end dates.
Audio data – telephone calls may be recorded for training and quality improvement purposes. Recordings are kept for six months and access is restricted to Directors of Goldcrest Academy Limited.
Profile data – username and password for the Goldcrest Academy website and VLE, orders or purchases made by you, enquiries submitted, feedback survey responses.
Marketing and communication data – your communication preferences and to receive marketing offers from Goldcrest Academy.
Student data – the CIM qualification and unit(s) that you are studying with Goldcrest Academy, cohort year(s), record of attainment, feedback from tutors, emails sent from you to Goldcrest Academy, emails sent from Goldcrest Academy to you, your CIM membership number, applications for deferrals, concerns or complaints made by you or about to you to Goldcrest Academy, feedback on lesson activities.
Technical and usage data – includes information about your Website visits to Goldcrest Academy, including your IP address, login data, browser type, time zone, location, operation system and platform, other technology/devices you use to access the website. Usage data would include URL clickstream to and from the website, search terms, pages viewed, download errors, dwell time, page interaction information and methods used to browse away from the page/site.
Transaction data – invoice information, payment history, details of products/services purchased.
Do you collect any special category data?
In some circumstances we may collect, use or store information that is ‘special categories’, these are set out below:
We ask that you let us know if you require reasonable adjustments for health or disability which may impact on your completion of CIM or other assessments or where a CIM emergency deferral is required.
Information about any disabilities or learning needs
This information is collected so that any reasonable adjustments can be made to accommodate students with disabilities and also to ensure that any learning needs are supported (for example extra time in exams). This information is voluntary and it is the personal responsibility of the student to let us know of any disabilities or learning needs and to provide the necessary reports promptly for submission to the Awarding Body.
Deferral or emergency deferral requests
This information is required by CIM to assess your needs. The form is self-completion by the student and is sent, along with supporting information from you, to CIM. CIM will communicate their decision directly to the student.
What information do we collect about you and the lawful basis for this?
We will only use your personal data when the law allows us to, this includes legitimate interest, performance of contract and compliance with legal or regulatory obligation. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you an appropriate service/product and a secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests, this may include:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation;
- We need to establish, exercise or defend our legal rights;
- Where we have your consent.
In situations where we are relying on your consent as a legal basis for processing your personal data, you may withdraw your consent to this processing at any time by contacting Goldcrest Academy.
If you are a student of Goldcrest Academy or attend a short course, we will have a contract in place with you for the course or qualification you are undertaking. Therefore, the lawful basis for processing your personal data will be to perform our contract with you.
In the event that we have a contract with your employer or prospective employer, for example, to deliver a bespoke course or programme to a group of employees, Goldcrest Academy will process your personal data as necessary for our legitimate interests, ie the delivery of services to your employer. In this situation we will not have a contract with you as an individual, as a contract will exist between Goldcrest Academy and your employer.
Who do we share your information with?
We will only share your data with third parties for the purpose of delivering our services, fulfilling any contracts we enter with you, where required by law or to enforce our legal rights. In the instance of qualifications, third parties would include CIM (The Chartered Institute of Marketing).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and will only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not disclose your details to third parties for the purpose of receiving communications from them, unless you specifically opt-in to this type of communication.
Only a limited number of providers and only when necessary, will we share your information with various, screened providers, who will act as data processors. These may include:
- Email service providers
- Payment processing providers
- Website hosting providers
- IT service providers
- Mailing house and print/fulfilment providers
- Book shop
Your information would only be disclosed to a limited number of providers who are conducting business on Goldcrest Academy’s behalf and only for an agreed purpose. Data would only be used for this purpose and deleted on completion.
There may be situations where you specifically request that we provide confirmation of course completion or student data for reference purposes, to future employers or education providers. There may be situations where we believe it is not appropriate to give a reference and we reserve the right for refusal.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.
Verification of qualification requests
From time to time it may be necessary to verify past qualifications, for entry onto new unit or course levels. For this purpose, Goldcrest Academy will ask you to complete a consent form for this purpose. The verification request would only be shared with the CIM and the student.
Profiling and automated decision making
We do not undertake any automated or automated decision-making processes. The CIM administer an online diagnostic test which assists with study entry level and this adds to a holistic view of the student, alongside information arising from the personal data you provide to us and discussion on appropriate course level.
We aim to provide you with options for ongoing marketing communications. If you agree to receive marketing communications from us, you are able to change your mind at any time and can contact us by email to update your marketing preferences.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you have provided us with your details when you entered a competition or signed up for a promotion and you have not opted out of receiving that marketing.
Third party marketing – we will ask you for opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us to stop sending you marketing messages or communications at any time by following the opt-out links on any marketing sent to you or checking/unchecking relevant boxes to this effect.
Where you opt out of these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.
Change of purpose
We may process your personal data without your knowledge or consent, where this is required or permitted by law.
Please note that you do not have to consent to cookies, but it may impact on the experience of the website and your access to information. For instructions on how to disable cookies, please find useful guidance here. Any information collected in this way can be used to identify you unless you change your browser settings. For further information on cookies please visit cookiesandyou.com.
Virtual Learning Environment
Goldcrest Academy offers a Virtual Learning Environment (VLE) to students. The VLE is accessed by Goldcrest Academy employees in order to deliver courses to students. Within the VLE, the following data is in operation for login purposes – email account (goldcrest) and password. No personal data is stored or hosted on the VLE.
Submitting assessment work
Students are invited to submit work by email or to submit work via Dropbox or similar technology – this is a personal choice. Students area able to anonymise their work and personal data when submitting work for marking and feedback.
Submitting assignments to CIM
CIM have established processes and procedures for the submission of student assignment work, which includes hard copy (printed), digital copy and digital direct upload. Final course work must be submitted to Goldcrest Academy first or in accordance with submission guidance which is provided to students.
Security of your information
Goldcrest Academy take appropriate technical and organisational processes to protect your data from risks such as loss or unauthorised access, destruction, use, modification, or disclosure of data. We limit access to your personal data to those employees, CIM and other third parties who have a need to know. They will only process your personal data on our instructions and they will be subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone.
We will keep hold of your data no longer than necessary and to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirement. In practice, we will retain information as follows:
Enquiries – we will retain your information to enable us to respond and complete your enquiry and for twelve months further. After this we will delete your information.
Students – we will retain your personal data during the course and for five years following course completion.
Purchases – for six years from the end of the period as this is a legal obligation
The length of time we retain data for other purposes may depend on any contractual arrangements in place with you, legal obligations we may have, the existence of your consent or our legitimate interest as a business.
Your legal rights
Subject to certain limitations, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
The right to be informed – this means that you have the right to request a copy of the information that we hold about you and how that information is used.
The right of access – this means that you have the right to request a copy of the information that we hold about you.
The right to rectification – this means that you have the right to ask us to rectify or delete your information or restrict processing, should you have concerns over its accuracy. Please note that we may need to verify the accuracy of the new data you provide to us. Please note that this right does not apply to exam or assessment marks/results.
The right to erasure – this means you have the right to ask us to delete or remove personal information. Please note that this may mean we will not be able to contact you. We may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
The right to restrict processing – this means that you can request that Goldcrest Academy restrict the processing of your personal data, based on your individual circumstance, where this processing is based on legitimate interest of Goldcrest Academy, where it involves direct marketing or where it may have been obtained for research or statistical purposes.
The right to data portability – for newsletter only subscribers, this means that your data is portable and can be transferred to another data controller. However, if the information compromises the confidentiality of a third party, we may be unable to provide you with some or all of your personal data. For students, where our legitimate interests exist, the right to data portability does not apply.
The right to object to processing of your personal data, where we are relying on a legitimate interest (or those of a third party). In some cases, we may have compelling legitimate grounds for processing your information which override your rights and freedoms.
The right to withdraw consent – you may withdraw consent to the use of your information at any time by emailing firstname.lastname@example.org
For further details on your rights, please visit: https://ico.org.uk/for-the-public/.
Accessing your data
No fee is usually required. To facilitate your request, we may need to have specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have a right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response. It is our aim to respond to all legitimate requests for personal data within one month. It may, on occasion, take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may need to charge a reasonable administrative fee for you to access personal data (or to exercise any other rights) should your request be clearly unfounded, repetitive or excessive. Alternatively we may refuse to comply with your request in these circumstances.
Keeping us updated
In order to maintain the accuracy of our database, you can update, amend or remove your personal details by emailing us at email@example.com or by writing to the Data Protection Officer at Goldcrest Academy Limited, The Bothy, Albury Park, Albury, Surrey GU5 9BH.
If you have any questions about privacy, please contact the Data Protection Officer at firstname.lastname@example.org in the first instance so we may assist you.