Date: OCTOBER 2020
Reviewed By: Caroline Bartle
Reason for Review: Policy Review
Next Review: FEBRUARY 2021
1. Who are 3 Spirit UK?
3 Spirit UK works to improve the standards of social care services through education. Our responsibility is to ensure that services uphold human rights, which involves working proactively to protect the confidentiality of our society’s most vulnerable. We also work to enable people to understand that potential breaches in confidentiality can impact on an individual’s dignity and safety. We are committed to these practices which we extend wholeheartedly to our clients. We pride ourselves on being a valued and principled business.
3 Spirit UK are committed to protecting the privacy of your data and fair processing of your personal information. We will use this information to monitor and improve the services which deliver.
We may sometimes share your data with third parties, for example with a Local Authority who has commissioned training delivered by 3 Spirit UK, to assess the quality of our service.
Please be assured to know that 3 Spirit UK will take all reasonable steps to ensure that your data is collected, stored and transmitted in a safe and secure manner.
2. What are your Rights?
You have the right to access any personal information that 3 Spirit UK processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
Access to your Personal Information
You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection officer Caroline Bartle at firstname.lastname@example.org
3. Type of data we collect?
When you visit our website we will collect information from cookies. Cookies help us to recognise your personal preferences so that we can help you get to the things that you want. Cookies also help the page to load quicker and are made up of a small file with numbers and letters.
When you sign up for free infographics and or newsletters, we will ask for your name, company details, email address and phone number. We will also ask you what sector you work in. This is so that we can target the information that we send to you, to make sure that it is relevant to you.
We automate most of our certificates and handouts. We do this so that we can focus our resources on the delivery and reduce the environmental impact on the planet. This maybe split over a period of time so that it is possible to process a large volume of data. We will ask for your name, email address, where you work and your phone number.
When we register you for qualifications we need to ask for some personal identification. This is to make sure that you are the person you say you are and to ensure that we are providing the certificate with the correct spelling to the right person. We will not keep a photocopy your ID but we will check it.
When you register for a qualification we will ask for your name, address, email details, NI number, ethnic origin and support needs.
Business to Business
We will collect basic information about your company if we are providing a service to you. This will include your company name, contact details, address and finance contact lead. We do not keep financial records. We do keep basic information about the type of service and number of clients. We may also keep inspection reports that are publicly available or training proposals that we have developed for you.
We do not keep any specific information about the clients that our organisations support and we have very specific policies in training to ensure that the clients in receipt of support have their anonymity protected. We do not share any internal operational information that we come across when in the process of fulfilling the contract, other than where consent has been provided.
4. Why do we collect your data?
We collect your data to personalise and improve our Service for you. The specific purposes for which we collect your data include:
Marketing purposes Online Course Delivery
To deliver our courses online, we use the Zoom and Microsoft Teams platforms, which collect personal customer data ahead of and post course delivery. We use the data collected by those platforms to create course attendance reports and to help with admin.
To learn more about the Zoom and Microsoft Teams platforms, please click below:
- Zoom: https://zoom.us/security
- Microsoft Teams: https://docs.microsoft.com/en-us/microsoftteams/security-compliance-overview
Course Handouts and Evaluations
When learners complete courses with us, we usually have handouts and resources to provide to them. In order to manage this, we ask candidates to sign up to our Keap platform or our Learning Management System (Powered by LearnWorlds) specifically for the purpose of receiving their course handouts and evaluations.
Any personal data that is provided to us for the above reason is stored on
While the above platforms facilitate for the distribution of evaluations, the management of evaluations as a whole is undertaken by the Survey Monkey platform. This platform collects your personal data, alongside your evaluation of the course. We store this data for quality control purposes, and we do give candidates the option to consent for their data to be used for marketing purposes.
To find out more about Survey Monkey, click here https://www.surveymonkey.co.uk/mp/data-security-and-compliance/
To facilitate the certification of candidates for their attendance of courses, we use a third-party platform called Diploma Safe. Diploma Safe offers us the automatic means of sending out certificates to learners, and is essential to our admin processes.
To find out more about Diploma Safe, click here https://diplomasafe.com/privacy-policy/
The personal data provided by you on our online enquiry web forms will be used for the purposes of processing your enquiry e.g. making contact regarding training, sending out a newsletter or letting you know about any offers. You can unsubscribe at any time.
Any personal data that is provided to us for the above reason is stored on a third party secure platform ‘Keap’. To see Keap, please visit https://keap.com/legal/privacy-policy
Qualification Process Purposes
This is so that we can lawfully carry out our duties which include providing you with a targeted learning experience in a way that meets your needs. Some of this data is categorised as ‘sensitive data’ we have therefore worked to ensure that this information is kept safe.
Your information will be passed onto three main parties:
1. Lead contractor that holds the funding
2. The funding body (skills funding agency)
3. Qualification Awarding bodies
We have worked with these agencies to ensure that they have systems in place to keep your information safe.
Once you start on your programme we keep the information we have about you on an E portfolio called Onefile.
We may process your personal data to provide you with certain types of marketing communication that we believe will be relevant and of interest to you. This helps us provide you with a more personalised Service. This kind of activity is permitted by our ‘legitimate interest’ (for more information on legitimate interest, please see Section 8 of this Policy). We will always endeavour to make these communications relevant and unobtrusive, and you are able to object to marketing communication from us at any time. We will only provide marketing information to you when you have given us explicit permission to do so.
We may collect and analyse data such as website logs in order to improve the quality of our Service. You do not have to disclose any of the above data to us. However, if you choose to withhold certain data, we may not be able to provide you with our Service.
Impact Analysis Purposes
This information is collected only to send you your resources and to ask you further down the line if the training has had an impact on your practice. You can choose here to opt in for further information and offers. However, if you don’t opt in, we won’t send you any information that you have not asked for. You can unsubscribe at any time, however, if you unsubscribe within the first 24 hours you may not receive your certificate.
5. How is your data secured?
All the data that you provide to us online is encrypted on our secure servers. All Emails and other electronic data that do not go through our websites are held on secure local office computers. We restrict access to your data to specific employees of 3 Spirit UK who have an important business-related reason for handling it. Our communications are encrypted using the TLS (Transport Layer Security) technology protocol.
6. How long do we keep your data?
Depending on what purpose your data is used for, the length of time we keep it may vary. Either way, we will only hold your data as long as necessary to serve the purpose it is used for. Please contact us to access our more comprehensive Data Retention Policy.
On occasions, we are legally required to keep the data obtained for regulatory purposes. We will only ever keep the data required by law and for the period state in legislation.
When legitimate interest no longer apply, we will remove your data from our system. For more information on legitimate interest, please see Section 8 of this Policy.
In situations where you give us specific consent to process certain kinds of data, you are able to withdraw that consent at any time. We will then stop processing your data and, if the retention period and/or legitimate interest retention period does not apply, we will also erase your data from our system.
We may retain any data mentioned above for a longer period, if required to protect the rights, property or safety of 3 Spirit UK or of the Service provided by us or our partners.
7. Who do we share your data with?
In some circumstances, we may disclose your data. For example, if access is requested by a court of law, or if there are safeguarding concerns. We will also share your personal data with third parties only when it is necessary for the fulfilment of the Service.
We will never sell your personal data to other organisations.
We work with partners who help us to complete your transactions. If they are based outside the EEA, we will share your personal data with them only when they apply essential safeguards, or if it has been established by EU institutions that the relevant country has an appropriate data protection regime in place, or when we otherwise ensure that the appropriate level of protection is applied for data processing.
The following are some purposes for which we may share your data with third parties:
- To fulfil the contract between you and 3 Spirit UK: We may share your data with third parties, such as our partners and intermediaries, when they are necessary for the fulfilment of the Service.
- When required by law: We may share your data when required by law, for example for the purposes of security, taxation and criminal investigations.
- For marketing and communication: We may share your data with third parties such as providers of customer service tools, marketing campaign tools, email communication tools, analytics software (for marketing purposes) and data visualisation tools (for analytical purposes).
- If we sell or buy any business or assets, we may be obliged to share your personal data with the prospective seller or buyer.
8. Legitimate Interest
Legitimate interest is a specific legal jurisdiction for the collection and processing of your personal data. It applies when we have reasonable grounds to collect and/or process your personal data to improve our Service, as long as this does not infringe on your rights.
We believe that if you are a recent client or an on-program learner of 3 Spirit UK, it is in your interest to receive occasional information about our Service. We may therefore send you communications about ours services or promotions that we believe are relevant for you based on your previous use of the Service. If we notice that you are having problems using our Service, we may on our own initiative decide to contact you, in some cases by phone, to offer help.
You can object to data processing based on our legitimate interest at any time by contacting our data protection officer Caroline Bartle at email@example.com
9. Changes to this Privacy Notice