Privacy and Cookies Policy
Effective Date: September 2023
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy and Cookies Policy
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: The CPD Certification Service Limited
Postal address: The Data Privacy Manager, The CPD Certification Service Limited, The Coach House, Ealing Green, London W5 5ER.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, always appreciate the chance to deal with your concerns before you approach the ICO so please contact us using the details above so that we can try to help you in the first instance.
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 and let us know if the personal information that we hold about you needs to be corrected or updated.
Third-party websites and links
THE DATA WE COLLECT ABOUT YOU
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 (which is called anonymous data).
We may collect, use, store, transfer and process different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, postal address, email address and telephone numbers.
- Financial Data includes payment card details.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, professional qualifications, reviews, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services, items you viewed or searched for, page response times, download errors, length of visits to certain pages (including how much time is spent on which pages), page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
- Marketing and Communications Data includes your preferences in receiving newsletters and marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services or open an account). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
- Direct Interactions. You may give us your Identity, Contact, Financial, Profile and Marketing and Communications Data and any other personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- register on our website and apply for our products or services (including requesting to have CPD materials certified by us);
- create an account on our website (or when an account is created for you);
- subscribe to our service, publications or newsletters;
- place an order on our website;
- request marketing to be sent to you;
- enter a survey; or
- correspond, give us feedback, report a problem with our website or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites we operate or websites employing our cookies. Please see the Cookies section below for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google, HubSpot and Hotjar, based outside the UK and advertising networks based inside the UK.
- Contact and Financial Data from providers of technical, payment and delivery services such as PayPal based inside the UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK and social media sites such as Twitter, Facebook and Instagram.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- 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 obligation.
- Where you have specifically consented to us using your personal data in a particular way (for example, when you consent to our use of non-essential cookies or to receiving our publications or newsletters). You have the right to withdraw consent at any time. Please see the “Opting out” section below for more information on how to unsubscribe from marketing.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us or unsubscribing via any link or instructions contained in the direct marketing communication you receive from us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where we rely on our legitimate interests as the legal basis for processing your personal data.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new member (including providing access to any portal we may provide)||(a) Identity
|Performance of a contract with you|
|To process and deliver the services including: (a) manage payments, fees and charges (including membership fees); and
(b) collect and recover money owed to us
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(b) asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how members use our products/services and to correspond with you so as to keep you up-to-date with any such changes)
|To administer and protect our business and this website (including troubleshooting, data and statistical analysis, research, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, to study how our members use our website, to develop our website and improve our business)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you (including making suggestions and recommendations to you about goods or services that may be of interest to you) and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how members use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Consent (to being sent marketing communications and where we obtain this information by using cookies or where otherwise required by law)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers/members for our products and services, to keep our website and software updated and relevant, to develop our business and to inform our marketing strategy)
Consent (where we obtain this information by using cookies or where otherwise required by law)
|For fraud detection, monitoring and prevention||(a) Identity
|Necessary for our legitimate interests (to prevent and detect crime and fraud)
Necessary to comply with a legal or regulatory obligation
|To enable you to partake in course feedback or provide references or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how members use our products/services, to develop them and grow and market our business)
|To receive and respond to enquiries from you about our products and services including potential members||(a) Identity
(c) Marketing and Communications
|Necessary for our legitimate interests (to engage with you and to facilitate the growth of our business) Necessary to comply with a legal or regulatory obligation|
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at email@example.com.
Please note that if you decide to opt out or unsubscribe it could take up to 72 hours to process the update through our systems.
When you visit our website, we collect some basic information such as your internet service provider’s domain name, which pages you accessed on our website, and when.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External third parties as follows:
- Service providers to the extent they need to process personal data to provide us with their services based inside and outside the UK and who provide IT, system administration and business support services (including payment processing providers such as PayPal, VISA and Mastercard and website hosting services such as Amazon Web Services (AWS) who provide application servers and cloud storage) and data analytics providers (such as Google Analytics, HubSpot and Hotjar) to help us understand how you use our services and to improve and optimise our website and your experience.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- Enforcement companies, based inside and outside the UK when we believe it is necessary to comply with the law or enforce our rights under our terms and conditions or in any contracts between us or to protect the rights, property or safety of The CPD Certification Service Limited, our employees or customers, our business partners or others. This includes exchanging information with the police or other investigatory or law enforcement authorities and companies and organisations involved in fraud protection.
- Certain third parties, based inside and outside the UK, where we have reason to suspect fraud or the commission of any other criminal offence offence. Such third parties may include business partners, law enforcement bodies, providers of fraud prevention and detection services, and recipients of fraud prevention and detection services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
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 and in accordance with our instructions.
INTERNATIONAL TRANSFERS AND WHERE WE STORE YOUR PERSONAL DATA
Our operations are principally based in the UK and the personal data that we collect from you is mainly processed, stored and used within the UK and in countries of the European Economic Area (EEA) However, in order to offer you the best service we can provide, we also work with service providers from other parts of the world. This means that the data we collect sometimes needs to be transferred, stored and used by companies operating outside the UK and/or EEA who work for us or one of our service providers to countries which may not provide the same level of protection as the UK and the EEA.
Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data which is equivalent to EEA and/or UK standards.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
- A derogation applies in accordance with data protection laws (for example, you have provided your explicit consent, or the transfer of data is necessary in order for us to exercise or defend a legal claim).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please note that, notwithstanding the steps we take, the transmission of information via the internet can never be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website.
Also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential and making sure it is not susceptible to being guessed. We ask you not to share a password with anyone.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our members (including Contact, Identity and Financial Data) for six (6) years after they cease being members for tax purposes. We also keep general enquiry data (which does not lead to a contractual relationship) for a period of up to two (2) calendar years after the enquiry has closed. This is to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect or defend our legal rights. After these respective time periods, we securely delete your personal data from our systems unless we have to retain it pursuant to any legal, regulatory, tax, accounting or reporting requirements to which we are subject.
In some circumstances you can ask us to delete your data: see “Your Legal Rights” section below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of your personal data, if it is inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances (also known as “the right to be forgotten”). Note, however, that this is not an absolute right and we may not always be required to comply with your request of erasure, for specific legal reasons.
- Request restriction of processing of your personal data which enables you to ask us to suspend the processing of your personal data in certain circumstances.
- Object to processing of your personal data in certain circumstances.
- Request a copy of certain personal data in a “portable” format (eg, a pdf file) and request that we transfer this copy to a third party.
- Right to withdraw consent at any time where we are relying on consent to process your personal data.
These rights are subject to certain limitations and exceptions and we will inform you of the relevant exemptions upon which we rely when responding to any request you make. For example, if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. The ICO website contains more detail on the rights mentioned above if you require any further information.
You may exercise any of the rights set out above by contacting us at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a 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.
What are cookies?
Managing and disabling cookies
You always have a choice over whether or not to accept cookies. When you first visit our website, we will ask you to consent to either our recommended settings, or choose which cookies to switch on.
You can manage cookies and chose to block or restrict cookies by selecting the appropriate settings in your internet browser. However, if you choose not to accept certain cookies, you may impair certain functionality on our website or may cause it not to work at all. Please note, strictly necessary cookies will always be set as they are essential for our website to operate. You can set your browser to block or alert you about these cookies but some parts of the website will then not work.
Types of cookies used and purpose
We use the following types of cookies on our website for the following purposes:
- Strictly necessary cookies. These are cookies that are required for the core functionality and operation of our website such as page navigation and cannot be switched off in our systems. They also include cookies that enable you to log into secure areas of our website. If you disable these cookies via your browser settings certain parts of the website will not function for you. These cookies do not store any personally identifiable information.
- Analytical/performance cookies and third party cookies. These cookies help us improve or optimise the experience we provide, improve the performance of our website and help us better understand our users experience and needs. They allow us to recognise and count the number of visitors to our website, to see how visitors move around our website when they are using it (including what links are chosen to click and how much time is spent on which pages) and see if you get any error messages. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We use Google Analytics, HubSpot and Hotjar on our website, which are third-party web analytics services to help us analyse how visitors use the website. Further information about these partners can be found here and via the link set out below in relation the individual cookies we use on our website.
- Functionality cookies. These are used to recognise you when you return to our website, for example by remembering the cookies you have consented to. This enables us to personalise our content for you and to check that certain functionality is working on our website.
- Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests and also show you relevant adverts on other sites. We may also share this information with third party service providers for this purpose so that when you are on another website, you may be shown advertising based on your browsing patterns on our website.
Click here to find more information about the individual cookies and other similar technologies we use on our website and the purposes for which we use them.
If you wish to opt-out of tracking by Google Analytics across all websites you can do so here https://tools.google.com/dlpage/gaoptout. If you wish to opt-out of Google Analytics for Display Advertising and customize Google Display Network ads in general please go to https://www.google.com/settings/ads or Google Analytics' currently available opt-outs for the web.
Further information about cookies