Privacy Statement

Privacy Notice - Learning Pembrokeshire

This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data for the purposes ofLearning Pembrokeshire’s Adult and Community Learning courses.

Why we need your information (purpose of processing)

We collect and use your personal information so that we can administer and provide you with Adult and Community Learning courses.

When visiting the Learning Centre, where CCTV is in place, this is for the prevention and detection of crime and for staff safety. 

With your consent we will also use your personal information to contact you with newsletters and marketing relating to Learning Pembrokeshire. You can opt out of this arrangement at any time by contacting staff at the Community Learning Centre administering your course or by emailing learn@pembrokeshire.gov.uk

The information that you provide will be processed according to the UK General Data Protection Regulation and the Data Protection Act 2018 andWelsh Government’s Lifelong Learning Record Wales (LLWR).

We will also make any disclosures required by law and we may also share this information with other bodies responsible for detecting/preventing fraud/crime or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost effective way. In order to achieve this, information will be shared with our Audit Service within Pembrokeshire County Council and with The Auditor General for Wales (Audit Wales Privacy Notice).

We will not make any disclosures to third parties for marketing purposes.

Your data will be secure and confidential at all times and we will only collect the personal information that is required to provide you with our service.

What personal data is being collected?

The categories of personal data being collected are:

• Full name(s) and surname
• Date of birth
• Contact details – Residential address including post code
• Gender
• Domicile
• Images CCTV

Other optional categories for personal data collection are:

• Contact details – telephone number(s) and email address
• Surname at 16
• National identity
• Highest qualification level and highest Welsh language qualification level
• Welsh fluency
• Health and medical information
• Employment status
• Emergency contact information
• Ethnicity

What is our lawful basis for processing your personal data?

The UK General Data Protection Regulations (GDPR) requires specific conditions to be met to ensure that the processing of your personal data is lawful. These relevant conditions are below:

Article 6 (1)(b) Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract. This is in relation to enrolment on to our courses.

Article 6 (1)(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. This is in relation to the use of CCTV at our Learning Centre.

Article 6 (1)(a) Consent: you have given clear consent for us to process your personal data for a specific purpose. This is in relation to marketing and newsletters.

Some types of personal data are more sensitive than others, and need more protection. This is classed as ‘special category data’ and could include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic or biometric data, health and sex life and sexual orientation.

We process this type of special category data as it is necessary for reasons of:

Article 9 (2)(g) Substantial public interest in accordance with Welsh Government’s Lifelong Learning Record Wales (LLWR).

 (The relevant Data Protection Act 2018 conditions are – Schedule 1 Part 2: Statutory and government purposes & Equality of opportunity or treatment)  

Who will we share your information with?

We may need to share your personal data with internal departments, other organisations and third parties, this will include:

• Pembrokeshire County Council’s IT department
• Welsh Government via Lifelong Learning Wales Record (LLWR)
• Pembrokeshire College - Where online learning or blended learning is part of your chosen course, limited personal information from course enrolment is passed via integration to Learning Pembrokeshire’s Learning Zone which is hosted by Pembrokeshire College. This information (name and email address) is used for the purpose of enabling access to Learning Pembrokeshire’s Learning Zone for online learning and access to learning resources and to BigBlueButton. 
• Appropriate Awarding bodies if your learning activity is accredited e.g. Agored Cymru, British Computer Society (BCS), WJEC, etc.
• Externally contracted tutors where your training is not delivered by a tutor employed by Pembrokeshire County Council.

Pembrokeshire County Council has a duty to protect the public funds it manages. Therefore, the information that you have provided to us may be used for the prevention and detection of fraud and for auditing purposes both internally and externally.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting CIFAS 

How long do we keep hold of your information?

Pembrokeshire County Council will only keep your information for as long as is necessary, please see below for how long we will retain the information provided to us. CCTV images are kept for 30 days. Your information will be securely disposed of once it is no longer required.

Your Rights

Under the UK General Data Protection Regulation and Data Protection Act 2018, you have rights as an individual including:

• The right to Rectification – you have the right to ask to have your information corrected.
• The right to Restrict processing may apply – you may request that we stop processing your personal data however, this may delay or prevent us delivering a service to you.  We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
• The right to Object – this is not an absolute right and will depend on the reason for processing your personal information.
• The right to Erasure - you may request that we erase your personal data however, this may delay or prevent us delivering a service, or continuing to deliver a service. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
• The right to Data portability – you have the right to request transfer of your information without determent.
• The right to not be subject to Automated decision making and profiling.
• The right of Access – you have the right to ask us for copies of your personal data.  To make a request, please contact:

Access to Records

Pembrokeshire County Council

County Hall

Haverfordwest

SA61 1TP

Email: accesstorecords@pembrokeshire.gov.uk    Telephone: 01437 764551

Complaints or Queries

Pembrokeshire County Council endeavours to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring to our attention if they believe that our collection or use of information is unfair, misleading or inappropriate. 

This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below:

Data Protection Officer

Pembrokeshire County Council

County Hall

Haverfordwest

SA61 1TP

Email: dataprotection@pembrokeshire.gov.uk     Telephone: 01437 764551

If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office as the statutory body which oversees data protection law:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

SK9 5AF

Email: wales@ico.org.uk

Telephone No: 0303 123 1113

Our Contact Details as Data Controller are:

Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP.

Telephone number: 01437 764551 or enquiries@pembrokeshire.gov.uk

Our Data Protection Officer’s information is detailed above in the Complaints and Queries section.

 

Changes to this privacy notice

We keep our privacy notice under regular review.