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Learner & Employer Privacy Policy

Our contact details

Name: Focus Training (SW) Ltd
Address: 69 St Modwen Rd, Plymouth, PL6 8LH
Phone Number: 01752 348980
E-mail: data@tftg.org
DPO: Mark Trewin
DPO Email: DPO@tftg.org

Policy last updated: 30 July 2025


The type of personal information we collect

We currently collect and process the following information:

  • Personal identifiers, name, gender, date of birth, email, telephone and postal contact details
  • Emergency contact details, including next of kin
  • Bank account details
  • Employment information; Employer contact details, location of workplace
  • Learner information; assessments, professional memberships, qualifications and grades.
  • Special Category Data, including, ethnicity, trade union membership, health data including dietary and accessibility requirements, biometric data including photos and CCTV footage.


How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • Recruitment

“Legitimate Interest” is the lawful basis for processing your data.

  • Education and Learning
    “Contract” is the lawful basis for processing your data.
  • Employment Support
    “Contract” is the lawful basis for processing your data.
  • Safeguarding Data
    “Vital Interest” is the lawful basis for processing your data.
  • Special Category Data is processed under article 9,
    for learning and funding (“Contract” is the lawful basis),
    and for archiving, research and statistics (“Legal Obligation” is the lawful basis).

We use the information that you have given us to manage your ongoing learning with us including supporting and working with your employer.

Employment support could include such data about; absence, health and safety, payments, administration of contract, dealing with legal disputes or to prevent fraud.

We do not undertake any automated processing of your personal data.

We will use pseudo-anonymisation for analysis and statistical reporting when allowed.

We may share your data with;

Your employer as detailed in your Learner Contract

The Education and Skills Funding Agency and the Department for Education.

Any awarding bodies as detailed in your Learner Contract

Any trade bodies as relevant to your qualification and detailed in your Learner Contract

If requested: The Office for Standards in Education (Ofsted) and The Quality Assurance Agency for Higher Education (QAA)

In exceptional circumstances safeguarding concerns may be shared with the relevant authorities on a strictly need to know basis.

We will also share your data with;

Our information technology support provider: Flotek 

Our back-office system provider: Microsoft 365 

Our

Our back-office system OneFile

Our booking system AccessPlanIt

Our communications platform provider: WhatsApp  

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

  • We have a legitimate interest in helping you find employment.
  • We have a contractual obligation to manage your learning.
  • We have a legal obligation to provide records to awarding bodies, trade bodies and the UK Government.

 

How we store your personal information

Your information is securely stored and regularly backed up.

We keep your;

Learner Record for 7 years after the end of your Learner Contract. We will then dispose your information by secure deletion, only retaining statistical data.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

You are not required to pay any charge for exercising your rights. However, we may charge a reasonable fee if your request for access is unfound or excessive. Alternatively we may refuse a request for access in such circumstances.

If you make a request, we have one month to respond to you.

Please contact us if you wish to make a request.

 

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

By email:  data@tftg.org 

By post: Data Protection Officer, Focus Training, 69 St Modwen Rd, Plymouth PL6 8LH 

 

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk