Privacy Policy

APPRENTIFY GROUP LIMITED (“NETCOM TRAINING”) PRIVACY NOTICE 

Important information about Apprentify Group Limited: 

ICO Registration number: ZA122513 

Netcom Training Limited is a part of Apprentify Group Limited (company number 11448437). 

Apprentify Group Limited (“we,” “us,” “our”) is a group of companies that includes Apprentify Limited -company number 10286725, Netcom Training Limited – company number 07678031, Upskilla Limited – company number 14871748 and IODA Limited – company number 03352708 (collectively referred to as “the Group”). This privacy notice applies to all entities within the Group and describes how we collect, use, and share your personal data when you interact with us as part of our recruitment services, training programmes and apprenticeship training and associated services. By working with or engaging with any company within the Group, you acknowledge and accept the practices described in this notice. 

Apprentify Group Limited takes its data protection and privacy responsibilities seriously. This ‘Privacy Notice’ explains how we collect, use and share personal information in the course of our business activities, including: 

Key principles of GDPR.
Our privacy policy embodies the following key principles; (a) Lawfulness, fairness, and transparency, (b) Purpose limitation, (c) Data minimisation, (d) Accuracy, (e) Storage limitation, (f) Integrity and confidence, (g) Accountability. 

Contact Details 

What personal information we collect, use, and why 

Lawful bases and data protection rights 

Where we get personal information from 

Direct marketing, profiling and automated decision making 

How we protect and store your information 

How long we keep information 

Who we share information with 

Sharing information outside of the UK 

How to complain 

1. Contact Details 

Email: dataprotection@apprentify.com  

Telephone: 0121 450 9300 

Post: Netcom Training Limited, Icentrum, Holt Street, Birmingham, B7 4BB. 

1. What personal information we collect, use and why 

The Apprentify Group entity responsible for your personal information will be the member of Apprentify Group that originally collects information from or about you. This will be explained at the point at which your personal information is first collected by that Apprentify Group entity, for example where you or the business you work for engages us to provide a service or where we engage you to provide a service to us. 

You can find out more about Netcom Training at https://www.netcomtraining.co.uk  or by contacting us using the information in the contact us section. 

If you no longer wish to receive any Marketing material, you can unsubscribe by emailing info@netcomtraining.co.uk. 

We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. 

You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third-party site. 

Applicants for roles we are recruiting for on behalf of employers. 

We may collect or use the following information for recruitment purposes: 

• Personal information: names and contact details for applicants, gender, pronoun preferences, address, email address, date of birth. 

• Professional information: CV, cover letter, employment history, educational background, skills and certifications 

• Identification: identification details such as a passport or driving licence, immigration status, right to work, national insurance number. 

• Background checks: details of any criminal convictions (e.g. DBS, Access NI or Disclosure Scotland checks), references 

• Special category data supplied by individual: Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities), racial or ethnic origin and other information that may be collected for equal opportunity monitoring. 

Learners or apprentices participating in our training programmes: 

We may collect or use the following information for student education and welfare: 

• Personal information: names and contact details for applicants, gender, pronoun preferences, address, email address, date of birth. 

• Professional information: CV, cover letter, employment history, educational background, skills and certifications, exam results and qualifications 

• Identification: identification details such as a passport or driving licence, immigration status, right to work, national insurance number. 

• Welfare information (includes family and home life circumstances and history) 

• Attendance and reason for absence data, progression updates, exam results and qualifications 

• Information relating to compliments and complaints 

• Special category data supplied by individual: Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities), racial or ethnic origin and other information that may be collected for equal opportunity monitoring. 

Employers or business partners engaging with us: 

We may collect or use the following information to ensure the smooth operation of apprenticeship or training programmes, compliance with legal requirements, and effective communication between all parties involved: 

• Contact details: name, address, email address, phone number. 

• Identification details (apprentices): date of birth, national insurance number, ULN number 

• Employment details: job title, employer name, employment history, work location 

• Educational background: qualifications, training history 

• Demographic information: gender, ethnicity, disability status (if applicable) 

• Feedback and performance data: performance reviews, feedback from training sessions 

• Financial information- billing information: bank account details, billing address, payment history, funding information: government funding or grants received, employer contributions to training costs, contracts or agreements related to payment for training services. 

• Communication records: emails and other correspondence, records of meetings and calls 

Individuals making enquiries about our services: 

We may collect or use the following information to help ensure that we can provide personalised and efficient service to potential clients or partners 

• Contact details: name, address, email address, phone number. 

• Professional information: employer name, current job title 

• Enquiry details (if includes personal identifiers): nature of the enquiry, specific services of interest, preferred contact method 

Visitors to our websites or individuals interacting with us via other communication channels. 

We may collect or use the following information to improve user experience, respond to enquiries and provide customer support, analyse website traffic and user behaviour, personalise marketing and communication efforts and ensure security and prevent fraud: 

• Contact details: name, address, email address, phone number. 

• Online identifiers: IP address, domain name, cookies and tracking data, browser type and version, device information 

• Behavioural data: pages visited, time spent on each page, clickstream data 

• Location data: geolocation information (if enabled) 

Communication channels (e.g. email, phone, social media) 

• Contact information: name, email address, phone number, social media handles 

• Communication content: messages sent via email, chat, or social media 

• Call recordings (if applicable) 

• Interaction history: records of previous interactions, customer service enquiries and responses. 

1. Lawful bases and data protection rights 

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. 

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website. 

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here. 

• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here. 

• Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here. 

• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here. 

• Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here. 

• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here. 

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here. 

If you make a request, we must respond to you without undue delay and in any event within one month. 

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice. 

Our lawful bases for the collection and use of your data 

Our lawful bases for collecting or using person information for recruitment purposes are: 

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 

• Legitimate Interest – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

• Sourcing candidates from professional networking sites 

• Evaluating candidates for job roles 

• Communicating with candidates throughout the recruitment process 

• Maintaining records relating to the hiring process 

• Conducting background checks where appropriate 

• Improving our recruitment processes and strategies 

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Our lawful bases for collecting or using person information for student education and welfare are: 

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 

• Legitimate Interest – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

• Ensuring efficient administration and management of the apprenticeship or training programme, including scheduling, resource allocation and communication with participants. 

• Meeting legal and regulatory requirements related to education and training, such as reporting to government bodies or accreditation organisations. 

• Assessing the effectiveness of the programme, tracking progress, and making improvements based on feedback and performance data. 

• Ensuring the safety and security of participants, staff, and facilities, including emergency contact information and health and safety records. 

• Managing financial aspects such as funding, grants, and payments related to the programme 

• Promoting the programme to potential participants and stakeholders, provided this does not override the individual’s rights and freedoms 

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

• Legal obligation – we have to collect or use your information so we can comply with the law or legal requirements such as funding rules. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 

Our lawful bases for collecting or using person information for engaging with employers or business partners are: 

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 

• Legitimate Interest – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

• Identifying and recruiting suitable candidates to fill job vacancies and meet workforce needs. 

• Providing training and development opportunities to enhance employees’ skills and competencies, ensuring the remain effective and productive in their roles. 

• Ensuring employees meet industry standards and regulatory requirements through necessary training and certification programmes. 

• Improving overall business operations by equipping employees with the skills needed to perform their tasks more efficiently and effectively. 

• Enhancing the quality of products or services by ensuring employees are well-trained and capable of delivering high standards of service. 

• Increasing employee retention and engagement by offering career development opportunities and demonstrating investment in their professional growth. 

• Staying competitive in the market by fostering a culture of continuous learning and innovation among employees. 

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

• Legal obligation – we have to collect or use your information so we can comply with the law or legal requirements such as funding rules. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 

Our lawful bases for collecting or using person information for individuals enquiring about our services are: 

• Legitimate Interest – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

• Processing personal data to respond to enquiries and provide information about our services. 

• Sending relevant information about our recruitment or training programmes to individuals who have shown interest. 

• Collecting feedback from enquirers to improve our services and tailor them to meet the needs of potential participants. 

• Ensuring the security of our systems and preventing fraudulent activities. 

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Our lawful bases for collecting or using person information for visitors to our websites or individuals interacting with us via other communication channels are: 

• Legitimate Interest – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

• Understanding how visitors use our website to improve user experience and optimise content. 

• Responding to inquiries and providing support to resolve issues raised by visitors 

• Sending relevant marketing communications and personalising content based on user interactions and preferences. 

• Ensuring the security of our website and communication channels, and preventing fraudulent activities 

• Gathering feedback to enhance our services and better meet the needs of our audience. 

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

• Contract – if the interaction leads to the formation of a contract – we have to collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object. 

1. Where we get personal information from 

• Directly from you 

• Regulatory authorities 

• Other educational establishments 

• Publicly available sources 

• Previous employers 

• Market research organisations 

• Suppliers and service providers 

• Providers of marketing lists and other personal information 

• Third parties: 

• Cognism 

• SoPro 

• Market Location 

• Apollo 

• Google Analytics 

1. Direct marketing, profiling and automated decision making 

In this section, you can find out more about: how we use personal information to keep you up to date with our products and services. how you can manage your marketing preferences when and how we undertake profiling and analytics when and how we carry out automated decision making. 

How we use personal information to keep you up to date with our products and services 

We may use personal information to let you know about Apprentify Group Limited products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. 

How you can manage your marketing preferences 

To protect privacy rights and to ensure you have control over how we manage marketing with you: 

We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you; you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will find on all the email marketing messages we send you. Alternatively, you can contact us via the link provided at the top of this document. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below. We recommend you routinely review the preference settings within your Apprentify Group Limited account. 

Cookies 

Cookies are small text files that are placed on your computer by websites that you visit. They are used to identify your computer to a website’s server and help personalise the site for your use either in your current browsing session or on future visits to the site. They also improve site functionality – for example, by letting you navigate between pages efficiently. 

Some cookies are session cookies, which mean that they are created only for the time of your visit and are deleted when you leave the website. Other cookies (“persistent cookies”) remain on your device for a period of time specified in the cookie. Persistent cookies are activated each time that you visit the website that created that particular cookie so that the site remembers who you are when you return and can personalise the site for your use. 

Most browsers allow you to turn off cookies. If you want to know how to do this, please look at the help or settings menu on your browser. The help or settings menu of most browsers will tell you how to set your preference as to how you wish cookies to be treated – you should be able to set up your computer to accept all cookies or, if you prefer, to disable cookies completely. Switching off cookies may restrict your use of a website. You can find out more about cookies on www.allaboutcookies.org 

Cookies used on our website 

We use the following cookies on our website: 

Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features. 

Performance cookies: These cookies are used by Google Analytics to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This information cannot be used to identify who you are. Google stores the information collected by these cookies on servers in the United States. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. 

Functionality cookies: These cookies allow our website to remember choices you have made when using the website or they may be used to provide services such as watching video online. 

Certain cookies on this website are session cookies and others are persistent cookies. 

By using our website, you agree that we can place the types of cookies referred to above on your device. 

When and how we carry out automated decision making 

We may use automated decision-making processes to evaluate your application. This includes AI screening tools that assess your suitability for the role based on the information provided. 

Credit rating checks Employee performance analysis 

1. How we protect and store your information 

Security 

We at Apprentify Group Limited (“Netcom Training Limited”) have implemented and maintained appropriate technical and organisational security measures, policies, and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers; destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected. 

Storing your personal information 

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances, we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. 

In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings. 

WHERE WE PROTECT AND STORE YOUR INFORMATION 

Netcom Training Limited uses a Customer Relationship Management (CRM) system to manage our interactions with our customers, suppliers, and partners. This system enables us to keep track of the information that we collect about you and to use this information to provide you with the best possible service. 

We take the security of your personal data seriously and have put in place appropriate measures to prevent unauthorised access or disclosure of your personal information. We use encryption technology to protect your data, and we restrict access to your personal information to only those employees who need it to perform their job duties. 

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law. If you would like to know more about how we handle your personal data or if you would like to exercise your rights under applicable data protection laws, please see our full privacy policy or contact us using the details provided. 

1. How long we keep information 

We keep your personal information for as long as is necessary for the reasons we are using them for. How long, varies depending on our relationship with you.  

If this reason is related to funded learning, we may be required to keep your personal information for a period of between 6 – 7 years after the end of the year in which the final payment was made depending on funding body. 

If you make an initial enquiry with us, but do not progress onto a training programme with Netcom Training Limited, we will keep your contact details for a period of 12 months and seek your consent to continue contact with you beyond this period. You can request that we end contact at any point during this period. 

1. Who we share information with 

We have to share some of your information with other people and organisations such as Ofsted, our funders and referring agencies. This may include your personal contact details, your attendance and progression in training, your achievements or employment progress. The organisations and people we regularly share this information with are: 

• Ofsted (the Regulatory Body for Training & Education) 

• Department for Education (DfE) 

• Employers (potential and current) 

• Funding agencies such as the GMCA, WMCA, GLA etc. 

• End Point Assessment Organisations 

• Awarding Bodies who verify your qualification and award certificates 

• Suppliers of learner management systems 

• Job application sites 

• Referrers (e.g. Job Centres, Connexions, Partner organisations and all other referring agencies) 

• Parents and Guardians 

• Tutors and Development Coaches, including sub-contracted training providers, and other Netcom Training Limited staff such as people in Finance or Compliance Admin 

• Auditors and Inspectors 

• Examination Centres including remote proctoring service providers 

We may share your personal information with companies within Apprentify Group Limited to help identify and offer relevant training or employment opportunities, improve our services, and ensure a consistent experience across our group. All companies within Apprentify Group Limited are bound by the same data protection standards and safeguards, and your information will only be shared where necessary and proportionate for these purposes. We rely on our legitimate interests as a lawful bases for this data sharing, and we ensure that your rights and freedoms are not overridden.  

Netcom Training Limited uses a Digital Marketing Service Provider (Prospect Global Ltd, T/A SoPro). You can view their privacy notice on their website https://sopro.io . Although they are a data processor, none of your personal information will be shared with SoPro. 

There may be occasions when we are legally required to share information with statutory agencies such as the Police, Local Authorities, Courts or HMRC. This may be in relation to educational statistics, safeguarding risks, criminal or civil proceedings or fraud. Information can be shared without your consent in these circumstances. 

If we were to sell or transfer our business or part of our business this may involve the transfer of our operations and/or records to another organisation(s). As part of the sale or transfer, your personal data may be transferred to the new organisation(s) who will, under the terms of this Privacy Notice, be permitted to use this data for the purposes for which it was collected i.e. to enable enrolment and participation through to completion of training and apprenticeship programmes, to secure funding for your programme and to be provided as evidence during an audit by funding bodies and/or other Regulators, for example, Ofsted. 

1. Sharing information outside of the UK 

Netcom Training Limited’s operations are based in the UK, and we store our data within the UK or European Economic Area (EEA). We do not share your personal data outside of the EEA. 

1. How to complain 

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 

The ICO’s address:            

Information Commissioner’s Office 

Wycliffe House 

Water Lane 

Wilmslow 

Cheshire 

SK9 5AF 

Helpline number: 0303 123 1113 

Website: https://www.ico.org.uk/make-a-complaint