Watson Martin Limited (Watson Martin) is a specialist training provider, delivering Human Resources, Learning & Development and Leadership & Management programmes and qualifications, soft-skills training and HR Consultancy, from offices across the UK. As an essential part of our business, we collect and manage client and non-client data. In doing so, we observe the UK data protection legislation, and are committed to protecting and respecting clients’ and non-clients’ privacy and rights. As such, we act as a “Data Controller” in respect of the information gathered and processed by us.
To ensure that you are informed about how we operate, we have developed this privacy notice, which details how we collect, manage, process, store and share information about you as a result of you visiting this site, enquiring about one of our programmes, enrolling on one of our qualifications, booking, attending or delivering one of our workshops or webinars, or engaging us to provide consultancy services. The privacy notice also provides you with information about how you can have control over the use of your data. If you have any comments or queries regarding our use of your data, please contact our Qualifications Manager at firstname.lastname@example.org or write to Watson Martin Limited, California House, 120 Coombe Lane, London SW20 0BA.
What Information Do We Collect?
In general terms, we collect information about you to enable us to:
- Administer our relationship
- Enable business development including sending newsletters, information updates and details of our workshops and webinars
- Process applications for employment
- Deliver requested information to you about our services and products
- Ensure correct invoicing and obtain payment
- Process and respond to any complaints
- Enable us to meet our legal and other regulatory obligations imposed on us
The information we need for these purposes is known as “personal data.” This includes your name, address (work or home), email address, telephone and other contact numbers, date of birth and financial information. We collect this in a number of different ways. For example, you may provide this data to us by email, via our website, over the telephone, or by letter.
We occasionally process sensitive classes of information, including physical or mental health details. We will seek your permission if we need to record any of your sensitive personal data on our systems.
How Do We Use The Information?
We use the data we collect from you for the specific purposes listed in the table below. Please note that this table also explains:
- The legal basis for processing your data, linked to each processing purpose; and
- In what circumstances your data will be shared with a third party organisation.
|Purpose for processing data||Legal basis for processing data||Third party organisations with whom data is shared|
|To administer our relationship with you, to provide services and respond to enquiries.||To meet the requirements of a contract.||None.|
|To ensure the correct invoicing of any training programmes or consultancy and obtain payment.||To meet the requirements of a contract.||Government VAT and tax inspectors, external auditors, internal auditors.|
|To register your qualification with the awarding body (CIPD, CMI, IAM) and to provide evidence of completion of modules.||To meet the requirements of a contract.||Qualification awarding body i.e. CIPD, CMI or IAM.|
|To provide feedback on your progress to your employer, where they have paid for your programme.||To meet the requirements of a contract.||Your employer (only where they have paid for your programme).|
|To provide access to our online learning portal (VLE).||To meet the requirements of a contract.||Third party website support (Xelium)|
|To communicate with you regarding related qualifications and webinars.||Legitimate interest in marketing our goods to existing customers||None.|
|To provide enquirers support by telephone.||To fulfil contractual obligations this includes taking action before entering into a contract.||None.|
|To process and respond to complaints.||To meet a legal obligation.||None.|
Under the terms of data protection legislation, you have the following rights:
Right To Be Informed
Right To Access
You have the right to ask us for a copy of any personal data that we hold about you. This is known as a “Subject Access Request.” Except in exceptional circumstances (which we would discuss and agree with you in advance), you can obtain this information at no cost. We will send you a copy of the information within 30 days of your request. To make a Subject Access Request, please write to our Qualifications Manager (details above).
Right To Rectification
If any of the information that we hold about you is inaccurate, you can either contact us on 020 7932 2760 or contact our Qualifications Manager (details above).
Right To Be Forgotten
From 25 May 2018, you can ask that we erase all personal information that we hold about you. Where it is appropriate that we comply, your request will be fully actioned within 30 days.
Right To Object
You have the right to object to:
- The continued use of your data for any purpose listed above for which consent is identified as the lawful basis for processing i.e. you have the right to withdraw your consent at any time.
- The continued use of your data for any purpose listed above for which the lawful basis of processing is that it has been deemed legitimate.
Right To Restrict Processing
If you wish us to restrict the use of your data because
(i) you think it is inaccurate but this will take time to validate,
(ii) you believe our data processing is unlawful but you do not want your data erased,
(iii) you want us to retain your data in order to establish, exercise or defend a legal claim, or
(iv) you wish to object to the processing of your data, but we have yet to determine whether this is appropriate,
please contact our Qualifications Manager.
Right To Data Portability
If you would like to move, copy or transfer the electronic personal data that we hold about you to another organisation, please contact our Qualifications Manager (details above).
Is The Processing Of Information Likely To Cause Individuals To Object Or Complain?
Watson Martin is not aware of any justifiable reasons that would constitute a legitimate reason for objecting or complaining about the way we process or control information.
How Long Will We Retain Information For?
Watson Martin will typically retain information for a period of seven years. This is due to regulatory and audit requirements.
None of the information that we collect, process or store is transferred outside of the European Economic Area (EEA).
Data Privacy And Security At Watson Martin
- We follow ICO recommendations to ensure that personal or sensitive data held on our IT systems is secure.
- Should any personal data need to be transferred to third party systems (for reasons above) this is encrypted.
- We have data back up processes in place, and agreed with third party suppliers, to ensure that you have reasonable access to your data at all times.
Cookies And Links To Other Websites
We may also use analytics tools provided by Google, Inc. (“Google”) or other similar providers. Analytics tools serve cookies through our website and collects aggregated data on an anonymised basis about users and visitors’ use of the website. The data collected enables us to understand aggregated user or visitor activity and how we may improve our website or charitable offering. This data is collected and used on an anonymised, aggregated basis only and does not enable any user or visitor to be personally identified.
In addition, we may also use marketing automation tools. These companies serve cookies to profile users or visitors’ interests and activity. We may use data collected through these cookies to serve users or visitors with information, new articles and advertising tailored to their specific needs and requirements.
You have the right to refuse or disable cookies served through our website although, if you choose to do so, certain functionality may become unavailable to you. As the means by which you may do this vary from browser to browser, we recommend that you visit your browser’s help menu for further information. We respect your right to choose whether or not to accept cookies. Please note that if you do not set your browser and e-mail settings to disable cookies, you will be indicating your consent to receive them. If you wish to find out more about cookies and clear gifs, you may like to visit www.allaboutcookies.org, an independent third party resource that explains what cookies and clear gifs are and how you may manage them. Please note that we are not responsible for, and have no control over, the content of this third party website. Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Right To Cancel And Refunds
You can cancel any services you order via the website within 14 days of your order being accepted, except that where the services are provided within 14 days of the order being accepted, your right to cancel ceases once provision of the services starts. You should send any notice of cancellation of an order immediately to email@example.com Please give full details of the order when you notify us of your cancellation. Where you cancel an order in accordance with these terms and conditions, we will refund to you any sums paid for that order within 30 days of receipt of your cancellation.
General Questions and comments regarding this Privacy Notice are welcomed and should be sent to our Qualifications Manager (details above). You can also contact our Qualifications Manager if you have any concerns or complaints about the ways in which your personal data has been handled. Alternatively, you have the right to lodge a complaint with the Information Commissioner’s Office who may be contacted at www.ico.org.uk