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Legal & Privacy

Privacy Policy

This policy explains how Achievers Training College Ltd (ATC) handles personal information when you visit achieverstrainingcollege.co.uk, make an enquiry, apply for learning, enrol, communicate with us or complete assessment. ATC is the training provider. Highfield is the awarding organisation for applicable regulated programmes. Highfield Vault is a third-party platform used only where applicable; ATC remains responsible for learner support, assessment, internal quality assurance (IQA) and centre records.

Website draft — legal and operational review required.

This document is a substantial working draft for ATC. Confirm the bracketed or course-specific details and obtain appropriate legal and operational review before relying on or publishing it as an approved policy.

Effective

Draft for ATC confirmation before publication

Last updated

[Policy date: To be confirmed by ATC before publication]

Review

Review at least annually and sooner if legislation, awarding requirements, services or delivery arrangements change.

Owner

Achievers Training College Ltd (ATC)

Version

0.1 draft

Purpose and scope

Purpose

Explain how ATC handles personal information openly, fairly and securely, and how people can exercise their data protection rights.

Scope

Website visitors, enquirers, applicants, learners, employers, placement contacts, tutors, assessors and anyone whose information ATC receives for learning, assessment, safeguarding or administration.

Responsibilities

ATC

Use information only for a clear purpose, apply an appropriate lawful basis, keep records accurate and protect information with proportionate controls.

Staff and contractors

Access only the information needed for the role, follow confidentiality and incident-reporting instructions, and complete any required data protection training.

Individuals

Provide accurate information, tell ATC about changes and use the published contact route for rights requests or concerns.

How the policy works

  1. Record the purpose, source, lawful basis, recipients and retention requirement for each material use of personal information.

  2. Give the relevant privacy information when information is collected or obtained, including where an approved third-party platform is used.

  3. Restrict access, investigate suspected incidents and notify affected people or authorities where required by law.

  4. Log and respond to rights requests using an identity check and timescale confirmed by ATC before publication.

Who this notice is for

This notice applies to website visitors, prospective learners, enrolled learners, employers, placement contacts, tutors, assessors and people who contact ATC. It should be read with any privacy notice shown by a third-party platform or service that ATC uses. Those providers remain responsible for their own processing under their own notices.

Information we may collect

Depending on your interaction with us, we may collect your name, contact details, date of birth, address, application and enrolment information, identification or eligibility information, employer or placement details, learning support needs, payment details, attendance, engagement, assessment evidence, feedback, results, certificates and communications with ATC. We may also receive information from an employer, placement provider, awarding organisation or authorised representative where this is necessary to support delivery, quality assurance or certification.

  • Website enquiry and application forms; applications and enrolment records; learner support and reasonable adjustment requests; assessment submissions, observations, professional discussions and feedback; emails, calls and other correspondence; technical and usage information needed to keep our site and learning services secure.
Information use at a glance
Information or activityWhy it may be neededDetail to confirm
Website enquiryRespond to your request and keep a record of the conversationContact fields; enquiries not leading to enrolment are typically kept 6 months
Application or enrolmentAssess suitability, set up learning and communicate requirementsRequired fields; unsuccessful applications typically kept 6 months (up to 12 where reconsideration is possible)
Assessment or supportDeliver, assess and support learning fairlyAccess limited to those who need it; assessment records typically kept 5 years from certification, or longer where required by our awarding organisation

Documents you upload

Where an application requires supporting documents — such as photographic identification, proof of address or qualification certificates, or, for staff applications, right-to-work evidence — you may upload them within the online application form. Our forms are provided by Jotform, which acts as our data processor and stores form data only in the European Union (Germany), with backups remaining in-region. Achievers Training College Ltd is the data controller for that information, and Jotform’s own privacy notice also applies to its processing.

When you submit an application, we download your submission and its attachments into your learner or staff record, which is the authoritative record of your application. The copy held by our form provider is a working copy only; we delete it within 30 days of confirming the transfer into our records, or within 30 days of the application closing if it does not proceed. Deletion from our form provider is carried out by us and is not automated; deleted submissions are purged and are not recoverable.

We keep application documents only for as long as our Data Retention Policy requires, and then delete them securely. Typical periods are set out in the retention table in this notice, and may be longer where our awarding organisation requires it.

Jotform uses sub-processors, including cloud storage providers and other service providers listed in Jotform’s privacy notice. Jotform relies on the EU–US Data Privacy Framework and its UK Extension for transfers to the United States; where a sub-processor falls outside that framework, we rely on the UK International Data Transfer Addendum.

Where an application includes special category information (such as health or disability information, or equality monitoring data) or criminal offence information (such as a DBS check), we process it under the additional conditions in Article 9 or Article 10 UK GDPR and Schedule 1 to the Data Protection Act 2018, in accordance with our Appropriate Policy Document.

Why we use information

We use personal information to respond to enquiries, process applications, create and maintain learner records, deliver learning, arrange assessment, verify authenticity, provide support, communicate important course information, issue or request certification, meet contractual and legal duties, safeguard learners, prevent fraud and improve our services. We may use de-identified or aggregated information for reporting, quality improvement and planning.

Lawful basis and sensitive information

ATC will use an appropriate lawful basis under UK data protection law, such as taking steps at your request before a contract, performing a learner agreement, complying with a legal obligation, pursuing legitimate interests or relying on consent where consent is required. Information about health, disability, safeguarding, equality or support needs may be treated as special category or otherwise sensitive information. We will only use it when a lawful condition applies and where it is needed to provide safe, fair and accessible learning.

Awarding organisations and learning platforms

For an applicable regulated programme, Highfield is the awarding organisation and ATC may share relevant learner, assessment and certification information with Highfield where required. Highfield Vault is a third-party platform used only where applicable, including for the Level 3 Adult Care programme where confirmed. It is not owned by ATC and does not replace ATC learner support, assessment, IQA or centre records.

Provider details to confirm before publication
Provider or platformConfirmed roleDetails to confirm
HighfieldAwarding organisation for applicable regulated programmesApplicable programme scope, data-sharing arrangements and provider notice [To be confirmed by ATC before publication]
Highfield VaultThird-party platform used only where applicableCourse access, data-processing arrangements and provider notice [To be confirmed by ATC before publication]
JotformEU data centre, Germany (confirmed). Third-party form provider for public learner and staff applications, including document uploads. Acts as processor for ATC, which is controllerJotform receives and holds submitted form data and attachments; ATC downloads them for filing in the relevant master record under its Data Retention Policy, and purges the Jotform submission within 30 days of filing or of the application being closed. Automated deletion is disabled, so deletion is carried out manually by ATC. Sub-processors and DPF UK Extension transfers are described in Jotform’s privacy notice, with the UK International Data Transfer Addendum relied upon where a sub-processor falls outside that framework.
PostHog or other analytics providerOnly if non-essential analytics are enabled after consentProvider, settings, lawful basis, consent tool and retention period [To be confirmed by ATC before publication]

Cookies and email communications

This website currently uses only strictly necessary cookies required for basic operation. We do not currently use non-essential analytics or marketing cookies. If conditional PostHog or another analytics service is enabled, it must not load until ATC has a suitable cookie banner or consent tool with a clear opt-in for non-essential analytics. This notice and the Cookie Policy must then be updated with the confirmed provider, settings and retention period. If you contact us or enrol, ATC may send service messages about applications, learning, assessment, payments, safeguarding or policy changes. Marketing messages will only be sent where permitted, and you can opt out.

Sharing information

We may share information with tutors, assessors, internal quality staff, employers or placement partners where needed for learning and assessment; Highfield where required for applicable regulated programmes; and approved technology, hosting, communications and support providers acting on our instructions. Provider roles, contracts and processing details must remain visible for confirmation in the provider table above. We may also share information with professional advisers, insurers, regulators, law enforcement or safeguarding agencies where required or permitted. ATC does not sell learner information.

Retention and security

ATC keeps personal information only for as long as it is needed for the purpose collected, legal and awarding requirements, dispute handling, safeguarding, financial records and legitimate business needs. The retention periods below reflect ATC’s retention schedule; ATC reviews the schedule periodically, and once retention expires information is securely deleted or anonymised. We use proportionate access controls, secure systems, staff responsibilities and procedures for handling incidents. No online transmission or storage can be guaranteed completely secure, so please use care when sending sensitive information.

How long ATC typically keeps information
Information or recordsTypical retention
Applications and enrolment records — unsuccessful applicantsTypically 6 months; up to 12 months where reconsideration of the application is possible
DBS checksCertificates are not copied; the number, date and result are recorded only. Retained while the check is active plus 6 months
Right-to-work documentsDuration of engagement plus 2 years, in line with Home Office requirements
Identity documentsDuration of engagement plus 6 months
Assessment records and portfolio evidence (Level 2–5 diplomas)5 years from certification, or longer where required by the Highfield centre agreement. The agreement check remains open; no assessment records are deleted while it is unresolved.
Certificates and achievement records6 years
CPD and short-course attendance recordsTypically 3 years; 6 years where used as employer compliance evidence
Staff and associate trainers — unsuccessful recruitment6 months
Staff and associate trainers — personnel filesDuration of engagement plus 6 years
Safeguarding recordsTypically 10 years after case closure; child-related records until the person’s 25th birthday or 10 years from last contact, whichever is later
Complaints records6 years from closure
Website enquiries not leading to enrolmentTypically 6 months

Your rights

Subject to legal exceptions, you may ask for access to your information, correction of inaccurate information, deletion, restriction, objection, data portability, or withdrawal of consent where processing relies on consent. You can also complain to the Information Commissioner’s Office (ICO). Requests should be sent to info@achieverstrainingcollege.co.uk with “Data protection request” in the subject line. Emily Douglas is the current data-protection contact for ATC and uses this email route. The identity-verification process and response arrangements remain [To be confirmed by ATC before publication].

Questions and changes

If you have a privacy question, contact Emily Douglas at info@achieverstrainingcollege.co.uk. Office telephone: 0330 520 0554. Company line: Achievers Training College Ltd (ATC) · Highfield Approved Centre No. 14591. Registered office: 3 Boardman House, 64 Broadway, Stratford, London E15 1NT. We may update this policy when our services, providers or legal obligations change. The effective date shown above should be updated when this draft is approved.