The General Data Protection Regulation is intended to strengthen and unify data protection for all individuals within the European Economic Area (EEA) and includes the European Union (EU). AccessCentral Ltd has been proactive in ensuring that our systems, policies and procedures are up-to-date and in line with these regulations in order to continue to provide highest level protection and uphold the privacy of our customers, employees or anyone else whom we hold data on. As such, the contents of this document may change. Please make sure you check this document regularly for any changes.
1.1 Who are we?
AccessCentral Ltd are a Student Finance registered assessment centre. Providing assessments to both students and the workplace. We help identify support needs that are arising as a result of an individual having a disability. Our team have been involved in supporting out clients for over 20 years.
1.2 What is Personal Data?
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
1.3 What types of information do we collect and process?
We may collect personal details including names, addresses and contact details, as well as education and employment details where pertinent to providing you with goods and services. Details of your training and goods and services you have or may receive will be collected, where required. Additionally we may collect information regarding your physical or mental health if it is relevant to the services we provide. Furthermore, if you are an employee or partner of AccessCentral Ltd, we will collect financial details in order to carry out our transactions with you.
The types of data we may collect and process includes:
- personal details – including living arrangements;
- business activities of the person whose personal information we are processing;
- financial details – including any bursaries or financial support you are entitled to
- training details;
- education and employment details;
- goods and services;
We may also process sensitive classes of information that may include:
- diagnoses and/or assessments by registered practitioners or other health professionals of your physical and/or mental health;
- the date your disability was last assessed;
- assessments by assessors at the Centre;
- a Statement of Special Education Needs issued by a Local Authority (where relevant)
- your needs assessment report;
- the fact that you receive a disability allowance;
- letter of award of support;
1.4 Who is the information processed about?
We collect and process information from the following:
- professional advisers and consultants;
- complainants and enquirers;
1.5 Why do we collect or process this information?
We process personal information to enable us to provide education and training to our customers and clients; to promote our services, to maintain our own accounts and records and to support and manage our employees.
AccessCentral Ltd collects data in order to fulfil contractual, legal or legitimate obligations. If you are a customer, AccessCentral Ltd collects information in order to provide services to you. This may include information required to carry out training, assessments or installations of hardware and software. We may process financial information in order to undertake the financial requirements of services rendered. If you are an employee of AccessCentral Ltd, we will collect information in order to comply with employment law, process finances and maintain or fulfil contractual obligations related to your employment. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
1.6 How will AccessCentral use the information we hold about you?
AccessCentral Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
1.7 Where do we get this information from?
Information we hold on you will either have been provided to us by either yourself or one of our partners. All data provided to us will have been collected from you with your knowledge and consent. We will only ever be given data essential for us to provide our services, or contractual, legal or legitimate obligations to you.
Consent is required for AccessCentral Ltd to process your data, but it must be explicitly given. By consenting to this Privacy Notice you are giving us permission to process your Personal Data specifically for the purposes identified. When asking for your personal data, we will always tell you why and how the data will be used.
You can withdraw your consent at any time by contacting AccessCentral Ltd’s DPO, either at firstname.lastname@example.org or by the details on our contact page (https://accesscentral.co.uk/contact-us/).
Your information will not be sold or rented to third parties, and we do not share any of your data with third parties for marketing purposes.
We may pass your information to third party service providers, subcontractors or associated organisations working on behalf of AccessCentral Ltd as well as other companies within the same group. When we use third-party service providers, we disclose only the personal information necessary to deliver the service. We have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
If you are an employee of AccessCentral Ltd, we may share information to current, past or prospective employers, employment and recruitment organizations and financial organizations with your consent.
We will seek your consent if we are required to provide any information about you to any further third parties not mentioned, and will only do so if necessary, providing only what information is necessary, unless we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
Where necessary, we may share information with:
- business associates and other professional advisers;
- educators and examining bodies;
- current, past or prospective employers;
- family, associates and representatives of the person whose personal data we are processing;
- employment and recruitment agencies;
- financial organisations;
- suppliers and service providers;
- persons making an enquiry or complaint;
- other companies in the same group;
- Central Government;
1.10 Retention of Information
AccessCentral Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
AccessCentral Ltd will process your data for as long as is required to fulfil any contractual, legal or legitimate requirements to you. Furthermore, AccessCentral Ltd will hold any medical/health data for up to 18 months after your assessment date, unless there is a legal or contractual or legitimate requirement for us to hold your information for longer. We destroy all paper files 18 months after your assessment report. We keep your assessment report for up to 7 years, in case you need to be assessed again for another course or work in the future. This is kept in electronic format and is encrypted on a UK based server.
1.11 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review – in the event that AccessCentral Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in ‘Complaints’ below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
1.12 What if I am unsure about my rights?
If you would like to find out more information about your rights regarding your data and privacy, please visit www.ico.org.uk if you are based in the United Kingdom or www.eugdpr.org if you are in the European Union.
In the event that you wish to make a complaint about how your personal data is being processed by AccessCentral Ltd, or how your complaint has been handled, you have the right to lodge a complaint directly with AccessCentral Ltd’s Data Protection Officer. Please see the Contact Us section of this document for more information.
You retain the right to lodge a complaint directly to the supervisory authority. For more information, please visit ico.org.uk.
On occasion, it may sometimes be necessary to transfer personal information overseas. When this is needed, information is only shared within the European Economic Area (EEA). Any transfers made will be in full compliance with all aspects of the data protection act.
1.15 What security is in place to protect the loss, misuse or alteration of your information?
At AccessCentral Ltd, the security of your data is important to us. When you give us personal information, we take steps to ensure that it is treated securely. Your information is stored securely on our on-site servers or a UK-based, encrypted cloud service, and we are constantly taking steps to monitor and improve our security. Any data sent or stored remotely is encrypted.
Any physical copies of your data are stored securely and destroyed using a secure confidential waste disposal company.
1.16 Under what circumstances will AccessCentral contact me?
Our aim is not to be intrusive and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure. As part of our on-going mission to ensure our level of service meets are clients need, we may from time to time ask for feedback on our performance, or circulate information that we feel may be of direct interest to you, based on the service type we have provided you.
1.17 Can I find out the personal data that the AccessCentral holds about me?
At your request, AccessCentral Ltd can confirm what information we hold about you and how it is processed. If AccessCentral Ltd does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of AccessCentral Ltd or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
1.18 What forms of ID will I need to provide in order to access this?
When making a request to see what information we hold on you, you will be required to provide documentation to confirm your identity. This is to protect your data from being accessed illegitimately. The following forms of identification are suitable:
- Valid UK or EU Passport;
- Drivers Licence or Provisional Drivers Licence;
We may contact you by telephone to verify your identity and also ask a number of security questions to confirm your request.
1.19 Are you 16 or under?
We are concerned with the privacy of children aged 16 or under. If you are aged 16 or under‚ your parent/guardian’s will need to give us permission before you provide us with your personal information.
Links to other Websites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies of the owners and operators of that third-party site, and recommend that your check the policy of that site.