INTRODUCTION

Welcome to the Edvanza UK Ltd (“Edvanza”) Privacy Notice.

Edvanza respects your privacy and is committed to protecting your personal data.

This privacy notice is provided in a layered format so you can click through to a specific privacy policy.

This website is not intended for children (aged under 13 years) and we do not knowingly collect data relating to children on this website. However, where Edvanza processes personal data of children in its business operations, we ensure that appropriate safeguards and consents are obtained from parents or caregivers as applicable and that we follow relevant guidance under applicable laws in relation to the processing of children’s data. You may contact dpo@edvanza.com > for further information about this.

It is important that you read the privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

IMPORTANT INFORMATION AND WHO WE ARE

DATA CONTROLLER

Edvanza (also referred to in this notice as “we” or “us”) is registered as a data controller of your personal data with the Information Commissioner’s Office (our notification number is ZA00000), and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at:www.globaluniversitysystems.com.

Edvanza address in England and Wales is30 Holborn, Buchanan House, London, England, EC1N 2HS.

OUR DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of data controller legal entity: Edvanza UK Ltd  

FAO Data Protection Officer

Email address: DPO@edvanza.com

Postal address: 30 Holborn, Buchanan House, London, England, EC1N 2HS

You have the right to make a complaint at any time to the Information Commissionaire’s Office (ICO) in the United Kingdom, for data protection issues. For data protection issues in other countries, you have the right to complain at any time to the supervisory authority for that country.

We would always prefer that you come to us to help address any concerns of a privacy nature however before you go to other applicable supervisory authority, so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated January 2021 and historic versions, if any, can be obtained by contacting us.

We may from time to time change the detail in this notice. Any changes we may make in the future will be posted on this page. Please check back frequently to see any such updates or changes.

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.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO at DPO@edvanza.com.

Contractual necessity means processing your data where it is necessary for the performance of a contract to which you are a party or to take preliminary pre-contractual steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Types of personal information

Description

Marketing Data

Details about your preferences in receiving marketing communications from us

Consents Data

Any permissions, consents or preferences that you give us, including your name, marital status, title, date of birth and gender

Usage Data

Information about how you use our website, products and services

How we use your information

Cookies

Our website www.edvanza.com For more information on our cookies use, please read our cookies statement on our website.

Generally

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for

Our reasons

Our legitimate interests

  • To provide you with information you may ask for
  • Consent
  • Legitimate interests
  • To fulfil enquires you might make of us
  • To allow you to register for updates or for notifications of blog posts on our website

  • Consent
  • Legitimate interests

  • To provide you with information that you may request from us

  • To allow you to register for events that we may be hosting

  • Consent
  • Legitimate interests

  • To hold events, such as seminars, webinars, open days or corporate hospitality to promote our business and its services

  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Legitimate interests

  • To provide efficient client care and services

  • To ensure that our technology operates efficiently and without error

  • To assess which of our services may be of interest to you and to tell you about them

  • To develop new products and services and improve existing ones

  • To manage our relationship with you which will include notifying you about changes to our privacy notice and our website terms and conditions

  • Legitimate interests

  • Contract performance
  • To provide efficient client care and services

  • To keep you updated about changes in the legal terms that apply to the use of our website
  • For record keeping and firm management

  • To manage the systems that contain our marketing database

  • To manage marketing preferences and keep our records up to date

  • Legitimate interests

  • For data management for marketing and business development purposes

  • To improve our systems and services

  • To seek feedback

  • To seek your consent when we need it to contact you

  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  • Legitimate interests

  • Consent

  • To improve our marketing strategy and the services that we provide

  • Sharing information with third parties - to facilitate data-gathering to improve our educational services, our website, and our marketing efforts.

  • Legitimate interests

  • For the purposes of Edvanza  legitimate business interests such as managing and developing its business.

Registering with Edvanza

When you register on the Edvanza Website, when you create, manage, and update your User profile, and when you purchase/participate on Online Courses on the Website, we and third parties working with us will collect the following information:

· Name, email address, age (required)

· Home address, date of birth, telephone number, country of nationality (required for certain courses)

· Other personal data if you choose to register for an Edvanza account via third party sites including Facebook and Google, and have provided your personal information on those platforms

· Data relating to your use of our Website and enrolment on Online Courses

· Information provided from third party sources, such as our Partners who may invite you to a certain course.

· Information provided by you when you correspond with us (including via surveys)

· Credit/debit card information

Registering as a Learner

When you are participating on an Online Course, we and third parties may collect and store the following additional information:

· any data and documentation you submit in order to verify your identity where required (collected by our third-party identity verification vendors who may store your information for the sole purpose of identification verification)

· any email communications with Edvanza to seek user support or to send queries related to the Course

· responses you voluntarily provide to Edvanza, the Course educators, or third parties in questionnaires, surveys, or user research that you participate in related to the Course.

· comments you voluntarily post while participating in online discussions with the Course educators and other Learners during the Course run

· any content submitted by you during the Course, such as written assignments, quizzes, and examinations, and the results of any assessments

· educators, or third parties in questionnaires, surveys, or user research that you participate in related to any course

Where we collect your personal information from

We may collect personal information about you from the following sources:

· Directly from you

· Cookies – see our cookie statement which can be accessed from our website

· Analytics providers, such as Google Analytics

· Publicity available data, such as Social Media

Who we share your information with

We may share your personal information with the following third parties:

· Our agents and service providers who we use to help us with marketing.

· Event organisers (if we are organising an external event which you are attending).

· The police and other law enforcement agencies.

· Relevant regulators, including the UK’s Information Commissioner’s Office in the event of a personal data breach.

· Other companies owned or jointly owned by Global University Systems.

· Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.

· Your employer or sponsor if you are a sponsored on a course, or with your explicit consent.

· Other educational institutions which Edvanza partners or collaborates with to deliver, study programmes, or any associated services.

· External debt collection agencies, in relation to student debts where Edvanza’s own recovery attempts have proven unsuccessful.

The purposes for which we process your personal data and the legal basis

When you register as a user, we process your personal data for the purposes of which you register. Generally, we process personal data for the following reasons:

(a) Consent:where you have given clear consent to process your personal data for a specific purpose.

(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 with you.

(c) 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 your personal data which overrides those legitimate interests.

We only process data for specified purposes and if it is justified in accordance with data protection law.

How long we keep your personal information

Where we use your personal information for marketing purposes we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).

Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing we will add your details to a suppression list which ensures that we remember not to contact you again.

For further information as to how to withdraw your consent or to ask us to stop other marketing activities see Withdrawing consent using your information and Objecting to how we may use your information.

If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.

International transfers

As a global company we work with agents and service providers who may process your personal information on our behalf outside the UK. If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at: DPO@edvanza.com.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

• To gain access to your personal data.

• To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed.

• To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest.

• To object to the processing of your personal data for marketing purposes.  You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.

 • To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.

• To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.

• To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply. 

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.

Exercising your rights, queries and complaints  

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at:DPO@edvanza.com

Clients of Edvanza (including employer clients)

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information

Description

Identity Data

ID information including your name, marital status, title, date of birth and gender

Contact Data

Where you live and how to contact you

Financial Data

Your financial position, status and history, including bank details and credit rating

Transactional Data

Details about payments to and from you and other details about services you purchase from us and we purchase from you

Communications Data

What we learn about you from letters, emails and conversations between us

Publicly Available Data

Details about you that are publicly available, such as on Companies House or elsewhere on the internet

Consents Data

Any permissions, consents or preferences that you give us

Usage data

Information about how you use our website, products and services.

Special category Data

Some types of personal information are defined as special. We will only collect and use these types of information where we need to and if the law allows us to:

  • Racial or ethnic origin
  • Political opinions, religious or philosophical beliefs
  • Trade union membership
  • Genetic or biometric data used for ID purposes
  • Health data
  • Sex life and sexual orientation
  • Criminal convictions data

How we use your information

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for

Our reasons

Our legitimate interests

  • To receive the products or services you provide to us
  • To provide you with services and fulfil our contractual obligations
  • To provide you with other products or services that you may acquire from
  • To provide advice or guidance about our products or services
  • Contractual performance
  • Legal obligation
  • Legitimate interests

  • To exercise our rights under contract and provide you with services agreed
  • To exercise our rights under contract and provide you with our products and services
  • To keep our records up to date, including your client file
  • To run our business in an efficient and proper way. This includes managing financial administration, business capability, planning, communications, corporate governance and audit
  • To improve our products and services and develop new ones
  • Contractual performance
  • Legitimate interests

  • Consent
  • Legal obligation
  • To manage credit control and debt recovery
  • To bill for the services we provide and deal with funds transfers
  • For financial reporting
  • To manage complaints and claims
  • To be efficient about how we manage our relationship with you and fulfil our responsibilities generally
  • To improve our efficiency and provide clients with new or improved products and service
  • For procurement purposes, including supplier due diligence, background checks and the assessing of tenders
  • To carry out credit checks
  • Legitimate interests

  • To carry out supplier due diligence
  • To ensure our contracts provide us with best value
  • To assess the financial worthiness and reliability of those with whom we deal
  • For marketing and business development activities, including seeking new business, promoting our business and events management.
  • Consent
  • Legitimate interests
  • To develop our relationship with you and others
  • To attract new business
  • To promote our business
  • To hold events, such as seminars or corporate hospitality to promote our business and its services
  • To seek your consent if we need it to contact you
  • For the prevention of crime and public safety, including through the use of CCTV
  • Legal obligation
  • Legitimate interests
  • To manage the risk of crime and safety for us, our employees and our clients
  • To develop and improve how we deal with crime
  • To report criminality or the suspicion of criminality for the wider benefit of society
  • To be efficient about how we fulfil our responsibilities generally

Where we collect your personal information from

We may collect personal information about you from the following sources:

· Directly from you or the organisation for whom you work

· Companies or individual that tell you about us

· Publicly available resources, such as Companies House

· The internet and social networking sites such as LinkedIn

· Third parties with whom we deal with during the course of carrying on our business

· Market researchers

· Intermediaries with whom you are also a client

· Credit reference agencies and fraud prevention agencies

Who we share your information with

We may share your personal information with the following third parties:

· Agents and service providers that we use during the course of providing services,

· Our professional advisors

· Other suppliers to the GUS Group

· The police and other law enforcement agencies where it is necessary to do so for the purpose of providing you with our services, or where we have a legal or regulatory obligation to do so

· Relevant regulators, including the Information Commissionaire’s Office (ICO) in the event of a personal data breach

· Other companies owned or jointly owned by GUS

· Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business

If you choose not to give your personal information

If you choose not to give us your personal information, it may delay or prevent us from being able to comply with our own legal obligations. It may also result in us being unable to, or refusing to, engage you or your organisations as a client.

Automated decisions

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

How long we keep your personal information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general terms, we will hold information for so long as you continue to provide us with products and services and for an additional period of 6 years thereafter.

International transfers

As a global company we work with agents and service providers who may process your personal information on our behalf outside the UK. If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at: DPO@edvanza.com.

Suppliers to Edvanza Privacy Notice

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information

Description

Identity Data

ID information including your name, marital status, title, date of birth and gender

Contact Data

Where you live and how to contact you

Financial Data

Your financial position, status and history, including bank details and credit rating

Transactional Data

Details about payments to and from you and other details about services you purchase from us and we purchase from you

Communications Data

What we learn about you from letters, emails and conversations between us

Publicly Available Data

Details about you that are publicly available, such as on Companies House or elsewhere on the internet

Consents Data

Any permissions, consents or preferences that you give us

How we use your information

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for

Our reasons

Our legitimate interests

  • To receive the products or services you provide to us
  • Contractual performance
  • Legal obligation
  • Legitimate interests
  • For company management
  • To maintain access and control records
  • For incident/breach reporting, management and investigation
  • To fulfil our contractual obligations
  • Contractual performance
  • Legitimate interests
  • To comply with our contractual obligations to you and your organisation
  • To properly manage the risks and liabilities associated with the contracts we are party to
  • To comply with laws and regulations that apply to us
  • To protect our reputation
  • To enforce the terms of our contract with you
  • Contractual performance
  • Legitimate interests
  • To ensure that we benefit from the terms of the contracts we have entered into and properly manage the risks and liabilities associated with them
  • For procurement purposes, including supplier due diligence, background checks and the assessing of tenders
  • To carry out credit checks
  • Legitimate interests
  • To carry out supplier due diligence
  • To ensure our contracts provide us with best value
  • To assess the financial worthiness and reliability of those with whom we deal
  • For financial administration, including calculating and managing payments, benchmarking, calculating fees and interest and collecting and recovering money that is owed to us
  • Contractual performance
  • Legitimate interests
  • Our legal duties
  • To meet our contractual obligations to you or your organisation
  • To ensure that we benefit from the terms of the contracts we have entered into and properly manage the risks and liabilities associated with them
  • To comply with laws and regulations that apply to us
  • To establish, enforce and defend legal claims
  • Legal claims
  • Legitimate interests
  • To comply with laws and regulations that apply to us
  • To respond to questions or complaints
  • To maintain records to evidence matters that may be in dispute
  • To manage our business properly
  • For corporate activity, such as a sale, transfer, merger or re-organisation of our business
  • Consent
  • Contractual performance
  • Legitimate interests
  • To manage our business efficiently and properly in accordance with normal business practices, legal requirements and to optimise its value for shareholders
  • To ensure that we run our business in accordance with good business principles and meet corporate governance, accounting and audit standards
  • For the prevention of crime and public safety, including through the use of CCTV
  • Legal obligation
  • Legitimate interests
  • To manage the risk of crime and safety for us, our employees and our clients
  • To develop and improve how we deal with crime
  • To report criminality or the suspicion of criminality for the wider benefit of society
  • To be efficient about how we fulfil our responsibilities generally

Where we collect your personal information from

We may collect personal information about you from the following sources:

· Directly from you or the organisation for whom you work

· Companies or individual that tell you about us

· Publicly available resources, such as Companies House

· The internet and social networking sites such as LinkedIn

· Third parties with whom we deal with during the course of carrying on our business

· Market researchers

· Intermediaries such as other companies who know you

Who we share your information with

We may share your personal information with the following third parties:

· Agents and service providers that we use during the course of providing services

· Our professional advisors

· Other suppliers to the GUS Group

· The police and other law enforcement agencies

· Relevant regulators, including the Information Commissionaire’s Office (ICO) in the event of a personal data breach

· Other companies owned or jointly owned by GUS

· Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business

If you choose not to give your personal information

If you choose not to give us your personal information, it may delay or prevent us from being able to comply with our own legal obligations. It may also result in us being unable to, or refusing to, engage you or your organisations as a supplier.

Automated decisions

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

How long we keep your personal information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general terms, we will hold information for so long as you continue to provide us with products and services and for an additional period of 6 years thereafter.

As a global company we work with agents and service providers who may process your personal information on our behalf outside the UK. If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at:DPO@edvanza.com

Job Applicant privacy notice

This is the 'Recruitment Privacy Notice' of Edvanza. 

This notice applies to individuals applying to work with us, including prospective directors, employees, trainees, apprentices, work experience students, workers, consultants and contractors. It applies whether the work applied for is part time or full time; or permanent, temporary or for a fixed term.

We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information.

This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this notice at any time.

Your personal information

In this privacy notice, 'your personal information' means your personal data i.e. information about you from which you can be identified. Sections 5 and 6 below set out your personal information that we may process.

Your 'personal information' does not include data where the identity has been removed (anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.

Special categories of personal information

'Special categories of personal information' means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 5 below, and data described at section 6, falls within these 'special categories' or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out at sections 5 and 6 below.

Where does your personal information come from?

Your personal information will come from you or us, and may also come from the following sources:

Some of the sources above will only be relevant in certain circumstances, or if you have applied for a particular role. If you would like more information on the source of your personal information please contact the HR department.

Processing your personal information

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:

Reason for processing your personal information

Legal ground(s) for processing, and legitimate interest (where applicable)

Your personal information

Contact you regarding the recruitment process and any offer of work

To enter a contract

Personal contact details (including name, address, email, telephone number)

Make a decision about your recruitment or appointment, including assessing your skills, qualifications and suitability for the work

To enter a contract

For our legitimate interests:

  • to select suitable employees, workers and contractors
  • Information provided in your application form, CV, any covering letter or email, and interview notes
  • Information sourced from google and social networking accounts (such as LinkedIn) relating to roles you have held, details of skills and capabilities and other information that helps us to assess your suitability for the work.

If you have accepted an offer of work from us that is subject to such checks:

  • Take up references (from referees whom you have given us permission to contact);
  • Carry out credit checks; and / or
  • Confirm your professional memberships, registrations and / or qualifications.

To enter a contract

For our legitimate interests:

  • to select suitable employees, workers and contractors

  • References and details of previous employers (including role(s) held, dates of previous employment, details of skills and capabilities and other information that helps to assess your suitability for the position applied for)
  • Results of credit check: personal contact details, date of birth, details of credit accounts and usage and credit score
  • Professional qualifications, registrations, practising certificates, accreditation details, and membership details

Determine the terms of any potential contract between you and us

To enter a contract

To comply with a legal obligation

Offer letter, and proposed contract between you and us

If you have accepted an offer of work, check you are legally entitled to work in the United Kingdom

To enter a contract

To comply with a legal obligation

Documentation confirming your right to work in the United Kingdom

Consider reasonable adjustments to the recruitment process for disabled applicants

To enter a contract

To comply with a legal obligation

For our legitimate interests:

  • To select suitable employees, workers and contractors

*For special categories of information:

  • To exercise or perform employment law rights or obligations

Information about a disability, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability*

Carry out equal opportunities monitoring.

For our legitimate interests:

  • To review equality of opportunity or treatment

*For special categories of information:

  • To review equality of opportunity or treatment
  • To exercise or perform employment law rights or obligations

The following information you have provided via our equal opportunities monitoring form:

  • Health data, including disability information*
  • Information regarding pregnancy and maternity*
  • Age and date of birth
  • Marriage or civil partnership status*
  • Gender
  • Data revealing race, religious beliefs or sexual orientation*

Information about criminal convictions

To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 6.

We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.

If you have accepted an offer of work from us that is subject to a criminal record check, we will ask you to obtain a disclosure check (at the appropriate level) and provide us with a copy of this.

Data necessary for the contract

Sections 5 and 6 above identify personal information that we may need to enter a contract with you. You are not obliged to provide this information, but if you don't provide it, we may not be able to proceed with the recruitment process or enter into the contract.

Statutory requirement to provide your personal information

In some circumstances, the provision of your personal information relates to a statutory requirement. This includes:

Sharing your personal information with third parties

We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

Automated decision-making

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

Transferring your personal information outside the UK

We share your personal data within the GUS Group. This will involve transferring your data outside the United Kingdom (UK).

Some of our external third parties are based outside the United Kingdom (European Economic Area India, Philippines, and The Republic of Belarus) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with GDPR, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

Data retention

If you don't start work with us following the recruitment process, we will retain your personal information for six months thereafter:

If you ask us to retain your personal information so that we can contact you to discuss future work opportunities, we will write to you separately, to obtain your explicit consent to retain your personal information for a fixed period of two years on that basis.

If you start work with us following the recruitment process, we will give you a copy of our Staff Privacy Notice and will retain your personal information as detailed in the Staff Privacy Notice.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

• To gain access to your personal data.

• To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed.

• To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest.

• To object to the processing of your personal data for marketing purposes.  You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.

 • To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.

• To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.

• To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.

If you require more information or have any queries, please contact our Data Protection Officer at: DPO@edvenza.com.

EDVANZA EMPLOYEES,WORKERS AND CONTRACTORS PRIVACY NOTICE

Edvanza is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the United Kingdom General Data Protection Regulation (UK GDPR) and/or the Data Protection Act 2018.

Edvanza is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

The kind of information we hold 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 (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

We will collect, store, and use the following categories of personal information about you:

· Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

· Date of birth.

· Gender.

· Marital status and dependants.

· Next of kin and emergency contact information.

· National Insurance number.

· Insurance records

· Bank account details, payroll records and tax status information.

· Salary, annual leave, pension and benefits information.

· Start date and, if different, the date of your continuous employment.

· Leaving date and your reason for leaving.

· Location of employment or workplace.

· Copy of driving licence.

· Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).

· Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).

· Compensation history.

· Performance information.

· Disciplinary and grievance information.

· CCTV footage and other information obtained through electronic means such as swipe card records.

· Information about your use of our information and communications systems.

· Photographs.

· Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

We may also collect, store and use the following more sensitive types of personal information:

· Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

· Trade union membership.

· Information about your health, including any medical condition, health and sickness records, including:

· where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;

· details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and

· where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

· Genetic information and biometric data.

· Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies such as:

· Professional bodies such as the, Association of Chartered Certified Accountants, Law Society of England and Wales, and / or the Solicitors Regulation Authority may provide us with the following personal information: qualifications, registrations, practising certificates, accreditation details and membership details.

We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform a contract, to which you are a party or in order to take steps at your request prior to entering into such a contract.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

4. Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (in relation to any processing we are carrying out with your consent, see below for how to withdraw your consent). Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal. We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you, and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as providing a description of which categories of data are involved. Where a legitimate interest is involved, we state what the legitimate interest is.

· Making a decision about your recruitment or appointment.

· Determining the terms on which you work for us.

· Determining whether your engagement is deemed employment for the purposes of Chapter 10 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) and providing you with a status determination statement in accordance with the applicable provisions of ITEPA 2003.

· Checking you are legally entitled to work in the UK.

· Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).

· Providing the following benefits to you.

· Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties

· Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits.

· Administering the contract we have entered into with you.

· Business management and planning, including accounting and auditing.

· Conducting performance reviews, managing performance and determining performance requirements.

· Making decisions about salary reviews and compensation.

· Assessing qualifications for a particular job or task, including decisions about promotions.

· Gathering evidence for possible grievance or disciplinary hearings.

· Making decisions about your continued employment or engagement.

· Making arrangements for the termination of our working relationship.

· Education, training and development requirements.

· Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

· Ascertaining your fitness to work.

· Managing sickness absence.

· Complying with health and safety obligations.

· To prevent fraud.

· To monitor your use of our information and communication systems to ensure compliance with our IT policies.

· To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

· To conduct data analytics studies to review and better understand employee retention and attrition rates.

· Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in connection with employment.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your more sensitive personal information.

· We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance. We need to process this information to exercise rights and perform obligations in connection with your employment.

· If you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, we will use information about your physical or mental health, or disability status in reaching a decision about your entitlements under the share plan.

· If you apply for an ill-health pension under a pension arrangement operated by a group company, we will use information about your physical or mental health in reaching a decision about your entitlement.

· We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

· We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our  data protection policy.

We envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

· To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences).

· We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.

· If you have accepted an offer of work from us that is subject to a criminal record check, we will ask you to obtain a disclosure check (at the appropriate level) from Disclosure Scotland, and provide us with a copy of this.

We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.

2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, pension administration, recruitment, benefits provision and administration, IT services.

We will share personal data regarding your participation in any pension arrangement operated by a group company with the trustees or scheme managers of the arrangement in connection with the administration of the arrangements.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

· We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, Health professionals and occupational health providers involved in your care, in order to consider reasonable adjustments to the recruitment process for disabled applicants.

· Relevant regulators such as The Association of Chartered Certified Accountants, the Law Society of England and Wales and the Solicitors Regulation Authority.

· Our professional advisors.

· Other third parties as necessary to comply with the law.

Transferring information outside the UK

We share your personal data within the GUS Group. This will involve transferring your data outside the United Kingdom (UK).

Some of our external third parties are based outside the United Kingdom (UK) (European Economic Area India, Philippines, and The Republic of Belarus) so their processing of your personal data will involve a transfer of data outside the UK.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure(s) to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the UK laws on data protection: we require such third parties to agree to put in place safeguards, such as the Standard Contractual clauses or equivalent measures.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer at: DPO@edvanza.com.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from our Data Protection Officer at: DPO@edvanza.com.

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 requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker, or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy and in accordance with applicable laws and regulations.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

· Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

· Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

· Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

· Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer at: DPO@edvanza.com.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer at: DPO@edvanza.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues Full details may be accessed on the complaints section of the ICO's website

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact our DPO by email via:DPO@edvanza.com