Privacy Policy - London Academy of Trading

Introduction

Welcome to the London Academy of Trading (LAT) privacy notice. LAT takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

The EU General Data Protection regulation (GDPR) and the Data Protection Act 2018, gives people the right to know what information is held about them, and requires LAT to ensure that personal information relating to living individuals is handled properly, held in confidence and is protected from inappropriate disclosure to third parties.

As part of our legal obligations we have published Staff, Student and General Privacy notices. Where required local privacy notices will be issued to inform individuals about what personal data is gathered, how it is used, stored and retained.

Data Controller

London Trading Academy (“LAT “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 ZA130604), 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.

LAT registered address in England and Wales is Belmont House, Station Way, Crawley, West Sussex, RH10 1JA, United Kingdom.

Our Data Protection Officer

If you have any questions about LAT’s privacy policies, please contact the Data Protection Officer at London Trading Academy, Level 2, 30 Holborn, Buchanan House, London EC1N 2HR.E-mail dpo@lat.london

How to Use This Privacy Policy

LAT holds and processes information about many different types of people such as its current, past or prospective employees, visitors to is website, applicants, students and alumni & supporters. It also processes personal information for a variety of reasons. LAT may also be required by law to collect and use certain types of personal information to comply with statutory requirements. For each category of personal data process you will find the following headings:

• What types of personal data we collect?

• How we use your information?

• What we use your information for?

• Where we collect your information from?

• Who we share your information with?

• How long do we keep your personal information?

• How can you access, amend or take back the personal data that you have given to us?

• How do we store and transfer your data internationally?

• What are cookies and how do we use them?

• How to reject cookies

More information on how LAT collects and uses personal information can be found in the relevant privacy notices below:

Website visitor – 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

Publicity Available Data

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

Marketing Data

Details about your preferences in receiving marketing communications from us

Consents Data

Any permissions, consents or preferences that you give us

Usage Data

Information about how you use our website, products and services

How we use your information

Cookies

Our website https://lat.london/ uses cookies. 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 allow you to register as a member of our alumni network
  • Consent
  • Legitimate interests
  • To operate and develop our alumni network and the activities of our alumni programme
  • 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

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

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 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.

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 hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the EEA. If your information is processed outside the EEA, we will ensure that it is protected to the same standards as if it were being processed within the EEA by putting in place a contract with our agents and service providers that provides adequate safeguards or using service providers that are certified on the US Privacy Shield framework.

If you require more information or have any queries, please contact our Data Protection Officer at: dpo@lat.london

Applicants and Students Privacy Notice

London Academy of Trading (LAT) takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

When processing your Personal Data, LAT is obliged to fulfil individuals’ reasonable expectations of privacy by complying with the General Data Protection Regulation (the GDPR), the Data Protection Act 2018 (DPA), and other relevant legislation and regulations (collectively “Data Protection Law”).

Purpose of this Notice

This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.

London Academy of Trading (LAT) “also referred to in this notice as “we” or “us”) is a data controller (which means we are responsible for deciding how we hold and use your personal information) of your data 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 https://www.globaluniversitysystems.com.

“Personal data” refers to information relating to a living, identifiable individual. It can also include “special categories of data”, which is information about your racial or ethnic origin, religious or other beliefs, and physical or mental health, the processing of which is subject to strict requirements. Similarly, information about criminal convictions and offences is also subject to strict requirements.

“Processing” means any operation which we carry out on your personal data e.g. obtaining, storing, transferring and deleting.

2. Your personal information

We hold a range of personal data about you, some of which you provide to us direct and some of which we receive from third parties, such as UCAS, where relevant. See below for further details of personal data we receive from third parties. Examples of categories of personal data which we hold are: your contact details, prior educational experience/attainment, immigration information (e.g. passport details, language proficiency), where relevant, health information (including any disabilities) and other equality-monitoring data you provide to us. In addition, if you come to study with us, we process data about your academic performance, attendance and progression, and where relevant, breaches of our policies (e.g. academic or other misconduct concerning LAT-related activities).We also process contact and educational details after you have completed your programme or your activities with us are otherwise terminated.

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

When you are an applicant, we process your personal data for the purposes of assessing your eligibility to be offered a place on one of our academic or professional programmes.

If you take up a place at LAT, we process your personal data for the purposes of providing our academic or professional programmes and related services.

If you are unsuccessful or do not take up a place at LAT, we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.

We only process data for specified purposes and if it is justified in accordance with data protection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified on the basis of contractual necessity. In general, this applies to personal data you provide to us to process your application and if enrolled, to monitor academic performance. Without that information, we would be unable to provide you with your chosen academic programme and related support services. Some personal data is also required to fulfil our legal obligations regarding immigration. A failure to provide that information would prejudice your application for a Tier 4 visa.

No

Purpose

Legal basis/ justification

1

Assessing eligibility to undertake our academic or professional programmes.

Processing is necessary for the purposes of taking steps prior to entering into a contract with us.

2

Supporting applicants through the application process and providing further information on the services we can offer.

Necessary for negotiating to enter into a contract and legitimate interests in providing support to applicants

3

Provision of academic or professional programmes and related services (including IT and library services).

Necessary for performing a contract, i.e. to provide your chosen academic programme. This can be a contract with us or a contract between you and your home institution (“contractual necessity”)

4

Identifying students and assisting them in trying to succeed in their learning via the dashboard system.

Contractual necessity and legitimate interest in assisting our students to succeed in their studies

5

Assessment of academic progress and performance (including attendance), and where necessary providing support.

Contractual necessity

6

Financial Administration (including provision of loans and bursaries).

Contractual necessity

7

Administration of extenuating circumstances procedures.

Contractual necessity

8

Administration of complaints, academic appeals, interruption and withdrawal, fitness to study and fitness to practice procedures.

Contractual necessity

9

Immigration matters.

Necessary for us to comply with our legal obligations in relation to students who hold Tier 4 visas. Such processing may also be in the public interest.

10

Making reasonable adjustments for disabilities and providing relevant support to students with ill health and providing wellbeing support.

This includes processing special category information.

Explicit consent.

11

Employability Support.

Contractual necessity and our legitimate interest in assisting our students and alumni to progress in their careers.

12

Regulating LAT’s community (including dealing with misconduct under our procedures for academic and other misconduct including disciplinary procedures).

Contractual necessity and our legitimate interest in maintaining academic standards and the good order of LAT community.

13

Obtaining payment of fees.

Contractual necessity and our legitimate interest in obtaining payment for the services we provide.

14

Protecting our property and assets (e.g. by dealing with misconduct)

Necessary for our legitimate interest in safeguarding our property and assets.

15

Providing appropriate I.T. and other infrastructure facilities e.g. a virtual learning environment

Contractual necessity; legitimate interest in providing a proper infrastructure to support the provision of academic or professional programmes and related student services.

16

Communicating with students.

Contractual necessity and our legitimate interest in marketing LAT and promoting student welfare.

17

Registering alumni to maintain an alumni network

Necessary for our legitimate interests in maintaining an alumni network, and marketing

There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter.

Where the basis of processing your personal data is contractual necessity and you fail to provide the personal data in question, LAT may not be able to process your application or provide you with the programme for which you have applied. A failure to provide immigration-related data may result in failure to obtain a Tier 4 visa for those who students who require it.

Personal data received from third parties

No

Data

Source

1

Contact details and attainment.

UCAS, UKPASS,call agents

2

Your immigration status.

Home Office (UKVI)

3

Transcripts – details of programmes undertaken or being undertaken at another institution; attainment.

Another institution and/or secondary/high schools.

4

Medical, mental health, accessibility-related and similar information. This is special category personal data. We only obtain this information from third parties if you give us consent to do so or if it’s a matter of life and death.

Another institution, medical practitioners and/or family members

5

Your financial status.

Student Loans Company.

6

Details of any LAT-associated complaint

Office of the Independent Adjudicator, and/or Competition and Markets Authority

7

Information required to assess eligibility for courses i.e. from employers or sponsors.

Employers or sponsors.

8

Details as to how you are performing in your apprenticeship job.

Your employer if you are an apprentice

9

Details as to how you are performing on placement.

Your placement provider

10

Details of performance at a partner institution including attendance and disciplinary issues.

International study abroad or exchange programme partner or collaboration partner.

 

Recipients of personal data

On occasion we may need to share your data with third parties. The following table lists what information we may share with whom

 

No

Recipients

Data which we may share with them

1

Companies within the group

Contact details, Course information where students and graduates are interested in entrepreneurship activities and relevant employability activities.

2

Placement providers

Your CV as well as any accessibility and assistance requirements and related information.

3

Co-curricular and/or extracurricular excursion providers.

Accessibility and assistance requirements and related information.

4

Your employer if you are an apprentice.

Details as to how you are performing in the academic part of your apprenticeship.

5

Your employer or sponsor if you are a sponsored student.

Details as to how you are performing and attendance in your course.

6

External examiners.

Identification details and exam papers.

7

Turnitin.

Identification details and assessment papers in order to detect plagiarism

8

Education and Skills Funding Agency if you are an apprentice.

Student details including course and employer information and academic progression.

9

End point assessor if you are an apprentice.

Identification details and assessment details.

10

UK Home Office

Passport details; contact details; programme details including attendance, placement details and work experience; fees and housing details

11

Data processors i.e. third parties who process personal data on our behalf e.g. software providers

Application details; attendance records

12

Local Authority (including the electorate office).

Contact details and course details where there’s a legal basis.

13

Student Loans Company.

Contact details and course details including progression.

14

LAT’s insurers and internal and external auditors, Health and Safety Executive in respect of accidents or incidents connected with the company.

Student details and details in relation to any incident.

15

Regulatory bodies, where you are on a professional programme

Contact details, attendance and progression information and potentially disciplinary or fitness to study or fitness to practice issues.

16

Government agencies i.e. HMRC*

Contact details and potentially other information if requested where there is a legal basis.

17

Police*.

Contact details and potentially other information if requested where there is a legal basis.

18

London Borough of Holborn or other members of the Channel Panel, a programme which provides support to individuals who are at risk of being drawn into terrorism as defined in Part 5, Chapter 2 of the Counter Terrorism and Security Act 2015.

Contact details and other information that LAT could be required to supply in order to comply with the Counter Terrorism and Security Act 2015.

19

Potential employers or other companies requesting a reference or confirmation of qualifications.

Attendance, progression and performance details including disciplinary or academic misconduct issues or breaches of the LAT’s regulations.

20

Close family, next of kin and emergency services where there is an emergency situation such as illness or serious injury.

Personal data including potentially special category data if necessary

21

Other UK based and international educational institutions which the LAT partners or collaborates with to deliver placements, study abroad programmes, dual awards, franchised or validated awards or any articulation or progression agreement.

Contact details, attendance, progression and performance details and details of any disciplinary or academic misconduct issues or breaches of LAT’s regulations

22

Higher Education Statistics Agency (“HESA”); Office for Students and Government Departments such as the Department for Education for analysis of student data or to carry out statutory functions.

Personal details, progression and performance details, details of the Destination of Leavers’ Survey.

The privacy notice for the Office for Students including sensitive data that they may hold, can be found here

https://www.officeforstudents.org.uk/privacy/.

The privacy notice for HESA can be found here https://www.hesa.ac.uk/about/website/privacy

23

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

Contact details and details of debt

* This will only be shared on request and where there is a legal basis for doing so.

 

Overseas transfers of personal data (i.e. outside the European Economic Area (EEA)

Where possible, we aim to hold personal data relating to students within the EEA. Where any of your personal data is transferred outside the EEA it will be subject to a legally binding data sharing agreement and to an adequacy decision by the European Commission (country, territory or specified sectors), or other appropriate safeguards as set out in Article 46 of the GDPR.

Retention of data

The length of time that we keep your personal data for is set out in the Student Records Retention Schedule, please contact dpo@lat.london for more information.

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 of the above rights or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at LAT Level 2, 30 Holborn, Buchanan House, London, EC1N 2HR

E-mail: dpo@lat.london

Complaints to the Information Commissioner

LAT maintains a data protection registration with the Information Commissioner’s Office, the independent authority which oversees compliance with the Data Protection Legislation. LAT registration number is ZA130604 and sets out, in very general terms, the full range of purposes for which we use, students and all other personal information.

You have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.

Graduation – Privacy Notice

London Academy of Trading (LAT) graduation ceremonies are significant events for our graduates, their guests and our staff. These ceremonies are public events and therefore there is no expectation of privacy under data protection legislation for any attendees. This statement explains how personal data will be processed for and during the event and provides guidance should you not wish your personal data to be processed in this way. This applies to all students who are intending to graduate or may be eligible for an award, whether they attend a ceremony or not. Please note the following important information and ensure your invited guests are also aware of the information relevant to them:

· Your name will appear in the Graduation brochure. If you do not want your name included for these purposes you must tell us be emailing dpo@lat.london no later than 5 weeks prior to the date of your ceremony*.

· If you graduate in person your name and award title will be read out at the ceremony immediately prior to you walking across the stage.

· Your photograph will be taken whilst you cross the stage and receive your ‘parchment’.

· Crowd shots will be taken by LAT photographers at the venue and at our graduation receptions and these may include images of you and your guests.

· Your consent will be sought for smaller group or individual photographs prior to these being taken. If you do not wish to be photographed, you should tell the photographer before the photo is taken.

· Live film feed may be used to stream the ceremonies externally.

· If you do not wish to have your photograph taken/ video filmed/streamed when crossing the stage, including being handed your parchment you must tell us by emailing dpo@lat.london no later than 5 weeks before the date of your ceremony*.

· Videos of the ceremonies may be produced and screened at relevant post-graduation receptions and, at a later date, will be made available for viewing from LAT’s website.

· Television companies may be present to interview our honorary graduands and other VIPs or film the event generally. If you do not wish to appear on television, you should maintain your distance from any filming that may take place.

· Appropriate photographs and films of these events may be used to promote the activities of LAT and these may appear in any of our promotional materials, in printed or electronic format, including worldwide web sites, multimedia productions, course leaflets or prospectuses. Please note that websites can be seen worldwide.

· Visual images will be used and retained strictly in accordance with the UK Data Protection Legislation and LAT’s records retention schedules.

If you have any queries or concerns about the use of your personal data for/at our Graduation ceremonies, please email dpo@lat.london no later than 5 weeks prior to the date of your ceremony. Please see the full privacy notice below:

*When emailing please ensure that you include your Student ID and Programme of Study.

 

Identity of controller

London Academy of Trading (LAT)

Purpose for collection/processing

London Academy of Trading (LAT) processes personal data for the purposes of arranging graduation ceremonies, conferring awards on graduands and documenting the event for the purposes of celebrating graduands achievements and for the future promotion of LAT.

Legal basis

Article 6(1) of the General Data Protection Regulation refers:

Article 6(1) (a) consent, is the basis for including names in the press.

Art 6(1) (f), legitimate interests, is the basis for processing personal data for the purposes of photography and filming where this is for future promotion of LAT. Please see the photography statement provided for further information. It is in the legitimate interests of the controller to use images of successful graduates and ceremonies for future promotion of LAT. To balance the individual’s interests, rights and freedoms LAT provides a fact sheet of all photography and filming activities to individuals prior to the event which details how they can avoid inclusion in the photography and filming and exercise their rights in the event that they are included. It is in the interests of both LAT and individual graduands involved to document these auspicious occasions which are important life events to be celebrated.

Whose information is being collected/processed

Students, LAT employees and all other ceremony attendees, including those invited by students/graduands.

What information is being collected

Name, identifying numbers, contact details, educational details, photographs and moving images.

How is the information collected

LAT systems for the event organisation and images by camera on the day of the event.

Who is the information shared with outside LAT

Publicly – the publication of names in graduation brochures, photographs online and in any of LAT promotional materials, in printed or electronic format.

How is the information kept securely

Information/photographs are kept securely on LAT processing equipment in line with LAT’s information security and data protection policies.

How is the information kept up to date

Students are required to keep their information up to date during the course of their studies to ensure that the personal data used at the time of graduation ceremonies is accurate, as this will be recorded at this point as a record of the event.

 

How long is the information kept

Please see LAT’s Records Retention Schedules.

Will the information be used for any automated decision making

No

Is the information transferred outside the European Union?

Ceremony live video streams are broadcast over the internet and may be accessed out with the EU.

Individual photographs and graduation brochures may be transferred outside the EU by third party individuals.

Your rights

Attendance at a Graduation Ceremony is optional and students can choose to graduate in-absentia (without attending). This selection is made at the time of registering a student’s intent to graduate.

Graduands can request that they are not photographed/captured on video while crossing the stage during the ceremony.

This request must be made in writing to dpo@lat.london and submitted no later than 5 weeks prior the date of the ceremony.

Graduands can request that their name does not appear on the official Graduation Brochure.

This request must be made in writing to dpo@lat.london and submitted no later than 5 weeks prior the date of the ceremony

Data protection officer

Enquiries relating to data protection should be made to LAT’s Data Protection Officer, email: dpo@lat.london

Further information

https://lat.london/

 

Alumni and Supporters – Privacy Notice

Purpose of this Privacy Notice:

Our alumni and supporters are extremely important to us. This Privacy Notice explains how we, London Academy of Trading (LAT), use the personal data our Alumni and Development Department collects from our alumni and supporters.

We are the data controller for personal data relating to you and this Privacy Notice explains how we will process your personal data. This Privacy Notice will be kept under review and any changes will be updated on our website and communicated to you as appropriate.

This Privacy Notice was last updated in 20th September 2019.

Due for Review by: 14th September 2020

Who does this privacy notice cover?
This privacy notice covers LAT alumni who have completed a course of over 12 months’ duration. It also covers individuals who have chosen to support LAT in some way that is under the remit of the Alumni and Development Department and have consented to be contacted for one of the purposes set out below. This notice only covers processing of personal data for Alumni and Development purposes as set out below. For other personal data processing related to former-students and alumni see the Student Privacy Notice.

What personal information do we collect?
We may hold a range of personal data about you from a number of sources.
The majority of the personal data that we hold is information provided to us by you. If you are an alumna/ alumnus of LAT, personal data collected during your time as a student is transferred from your student record such as your name, date of birth and gender to LAT’s alumni database when you complete a course of over 12 months’ duration. We may also add information provided by you during interactions with you. If you are a supporter of LAT, the personal data we hold may be information provided by you during your interaction with us.
Examples of categories of personal data which we may hold are:

· Personal identifiers – e.g. your name, gender, student/ alumni numbers and your date of birth;

· Contact details – e.g. your postal/ email address, telephone number and contact preferences;

· Information about your time at LAT – e.g. the courses you completed and your membership of clubs and societies;
Career details – e.g. job role;

· Records of donations – including financial details and Gift Aid status, where applicable (as required by HMRC);

· Communications between the Alumni and Development Department and you;

· Information about your interactions with LAT – e.g. records relating to volunteering activities on behalf of the College, online interactions with us on social media, information about your use of College resources or facilities (e.g. the library), information on your engagement with College meetings, events, groups or networks;

· Results of automated decision making and profiling processes to focus our interactions with you

We may also hold information collected from publically available sources, such as social network posts, internet searches and websites, and may augment this information with the personal data you provide to us.

Why are we collecting your personal data/what are we doing with it (purposes)?
We only process data for specified purposes and if it is justified in accordance with data-protection law. In general terms, we process your personal data for the purposes of increasing alumni involvement with the student experience at LAT, fundraising, alumni/ supporter communications and related activities by the Alumni and Development Department. More specifically, these activities may include:

· sending you publications (e.g. alumni magazines and email newsletters about LAT and fundraising activities);

· inviting you to alumni and supporter events, reunions and University events;

· informing you of benefits available to alumni and supporters;

· asking you to support LAT (e.g. contributing to student mentoring schemes or donations);

· fundraising programmes;

· wealth analysis and research in order to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications; and

· internal record-keeping and administration (e.g. to process a donation or administer an event which you are attending).

There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter. Use of our websites, including our use of cookies, is covered by our website privacy notice: https://lat.london/

Do we use any automated decision making or profiling?
Automated individual decision-making means making a decision solely by automated means without any human involvement and profiling means the automated processing of personal data to evaluate certain things about an individual. We may use automated or manual analyses including segmentation or profiling to link data together to send you communications which are relevant and timely, to identify opportunities which may be of interest to you, to help us identify your potential for supporting LAT and to avoid approaching you with opportunities which are not of interest. We may carry out wealth screening to focus our conversations with you and ensure we provide you with an experience which is appropriate for you.


What legal bases do we rely on for processing your personal data?
Depending on the activity being carried out, we will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your data, as explained below.

· GDPR Article 6(1) (a) – Consent of the data subject
Unless mentioned below, we will only process your personal data in relation to alumni and development purposes where we have your consent. This means we will only email you, or call TPS registered numbers, if we have your express consent to do so. We may contact you by post, unless you have asked us not to. We will also only contact you about College news, events or to ask for a donation if we have your express consent to do so.

· GDPR Article6 (1)(c) – Processing is necessary for compliance with a legal obligation
If you make or have made a charitable donation we will process your name, address, and donation information under 6(1)(c) of the GDPR for the purpose of administering your donation and claiming Gift Aid on your behalf. We may also use available sources to carry out due diligence checks to meet money laundering regulations. If you withdraw consent, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. The College has a legal obligation to supply some of the information we hold about you, as a graduate, to the Higher Education Statistics Agency (HESA) – the official agency for the collection, analysis and dissemination of quantitative information about higher education in the United Kingdom. HESA will treat your data in line with its collection notices. HESA produces official statistics and its outputs are regulated by the UK Statistics Authority, which has a direct line of accountability to Parliament.

· GDPR Article 6.1(f) -Processing is necessary for the pursuit of our legitimate interests
Processing of student record data for alumni under legitimate interests for the purpose of monitoring our academic services and providing you with information (e.g. copy of transcript, confirmation of degree etc.) is covered in the Student Privacy Notice.


Who do we share your personal data with? What data do we share?


On occasion we may need to share your data internally and with third parties. The following table lists what information we may share with whom.

 

Recipients

Data which we may share with them

Our staff in the Alumni and Development Department

Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information.

Our administrative/ IT staff associated with alumni/ supporter activities

Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information.

Volunteer partners associated with alumni/ supporter activities

Contact details and course information

College clubs and societies

Contact details and course information

Event providers

Registration details, accessibility and assistance requirements and related information including dietary requirements.

Third parties engaged by LAT to provide alumni and fundraising related services including potential for wealth analysis and research or to carry out automated or manual analysis to link data together to identify your potential for supporting LAT

Contact details and course information

Data processors i.e. third parties who process personal data on our behalf e.g. software providers, event booking providers etc. (e.g. Eventbrite)

Contact details and course information

 

How are we protecting your personal data?

Your personal data is held securely on LAT’s alumni and supporter database, which is accessible by a limited number of staff and is secured. Any transfer of your personal data outside the European Union will be subject to the Privacy Shield protections. Further information about Privacy Shield can be found at https://www.privacyshield.gov/welcome.

We ensure we have appropriate data sharing agreements in place before sharing your personal data.

We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them.
LAT is committed to working in a transparent, ethical, responsible and honest way.

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 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;

· to object to the processing of your personal data when such 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; and

· to ask for the transfer of your data electronically to a third party.

 

How long is your personal data kept?
Personal data in support of your alumni relationship with LAT will be kept until there is no longer a legal basis for holding it, until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent.
If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes.

How can you maintain your personal data?
You can update, amend or correct the data we hold about you by contacting the Alumni and Development Department by email, phone or post. You can also change your communication preferences at any time to restrict how we process your data, or opt out of some or all communication. We will also review your consent and preferences at least every two years.


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 complaint, please contact our Data Protection Officer:

Data Protection Officer
Address:
Level 2, 30 Holborn, Buchanan House, London, EC1N 2HR
Email:
dpo@lat.london

Complaints to the Information Commissioner
You have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website
https://ico.org.uk/.

Staff Privacy Notice

London Academy of Trading (“we”, “our”, “us”) are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.

What is Personal Data?

‘Personal data’ means any information which identifies you as an individual. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you.

This Statement and LAT data protection obligations

In accordance with the General Data Protection Regulation (the “GDPR”) and the Data Protection Act 2018 (the “DPA”), together, the “Data Protection Laws”, we are a Data Controller as we determine the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This means that we are legally responsible for the personal data we collect and hold about you. It also means that we must comply with the data protection principles (see below). One of our responsibilities is to tell you about the different ways in which we use your personal data – what information we collect (and our legal basis for doing so), why we collect it, where we collect it from and whether (and with whom) we will share it. We also need to tell you about your rights in relation to the information. This notice provides further details about all of these issues.

In order to comply with our contractual, statutory, and management obligations and responsibilities, we need to process personal data relating to our employees, including ‘sensitive’ or special categories’ of personal data, as defined in the Data Protection Laws which includes information relating to health, racial or ethnic origin, and criminal convictions.

All personal data will be processed in accordance with the Data Protection Laws and London Academy of Trading Privacy Policy: https://lat.london/privacy-policy/

Using your information in accordance with Data Protection Laws

Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a ‘legal basis’ for the processing.

The legal bases on which your personal data are collected, the types of personal data, and the purposes for which they are processed is given below.

Application for employment (Subsection)

We need to process your personal data that you supplied to London Academy of Trading as part of your application for a position at London Academy of Trading. This is to ensure that your application can be considered by the relevant department. In your application we will collect the following information:

Personal data gathered

In your application we will collect the following information

First Name(s)
Last Name
Title
Other Name(s)
Preferred Forename
Your Address
Postcode
Telephone (Home)
Telephone (Work)
Telephone (Mobile)
Your personal Email
Details of your Secondary and/or Tertiary education
Professional qualifications
Statement in support of your application
Details within your submitted Curriculum Vitae (CV)
Details of your right to work in the UK

Information about your present and employment history for the previous five (5) years including:
Name of Employer(s)
Address Line 1
Address Line 2
Town
County
Postcode
Job Title
Date From
Date To
Salary
Notice Required

In addition, we may contact your referees as provided in your application to confirm the employment information that you provided.

Special categories personal data

As part of the application you will be asked to provide equality and diversity information, this may include data concerning:

Any disability
Your ethnicity
Your sexual orientation
Your religious beliefs

You have the right to not provide this information, in which case London Academy of Trading will note to statutory bodies that you elected not to provide this information

Criminal records information

In some circumstances we may process your information to undertake a Disclosure and Barring Service (DBS) check, as required by law.

During your employment (subsection)

The Data Protection Laws define ‘sensitive personal data’ or ‘special categories of personal data’ as information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, data concerning sex life or sexual orientation. We will process this data, as well as the data provided in your application in order to perform our obligations arising from your contract of employment with us. The additional personal data we process to meet these responsibilities includes:

Additional data-personal information

The additional personal data (including some special category personal data) we process to meet our responsibilities as an employer includes the following:

Previous sickness information including the reasons for the absence
Bank account details
Passport details
Visa details
Sick pay
Leave entitlement
Parental pay
Pensions data
Remuneration and benefits
Emergency contacts
Trade Union Membership

Statutory responsibilities

We may process your personal data in order to meet responsibilities imposed on us by legislation. The personal data processed to meet statutory responsibilities includes, but is not limited to, data relating to:
tax;
national insurance;
statutory sick pay;
statutory maternity pay;
family leave;
work permits, and
equal opportunities monitoring.

Our lawful basis for processing

The lawful bases for processing personal data will be:

Article 6(1) (b) Contract

Article 6(1) (c) Legal obligation

Article 6(1) (f) Legitimate interest

Purpose of processing

We will use your personal data in connection with your employment relationship with us, including for the following purposes:

To facilitate staff training, such as e-learning.
Managing our accounts and records and providing commercial activities to our clients.
For the use of CCTV systems to monitor and collect visual images for the purposes of security and the prevention and detection of crime – The CCTV policy can be found HERE
To provide you access to relevant systems to undertake your role.
To fulfil our obligations for the contract of employment.
Processing recruitment applications.
Talent, performance and succession planning.
Paying and reviewing salary and other remuneration and benefits.
Providing and administering benefits (including pension, voluntary healthcare schemes, salary sacrifice schemes and others).
Undertaking performance appraisals and reviews.
Policy and Legal Governance requirements and compliance.
Internal audit and data collection.
Legal compliance, requirements and obligations.
Maintaining sickness and other absence records.
Providing references and information to future employers and, if necessary, governmental bodies.
Processing information regarding equality of opportunity and treatment of data subjects in line with the monitoring of equal opportunities and access.
The information we process may be held on LAT’s Corporate systems some of which may be owned and operated by third parties. Where we engage with such third parties, we insist upon strict contractual requirements to be adhered to by them to protect the personal data.

Special categories personal data

The Data Protection Laws define ‘sensitive personal data’ or ‘special categories of personal data’ as information about racial or ethnic origin; political opinions; religious beliefs or other similar beliefs; trade union membership; physical or mental health; sexual life. In certain limited circumstances, the Data Protection Laws permit us to process such data without requiring the explicit consent of the employee.

(a) We will process sensitive personal data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and consent.
(b) Other than in exceptional circumstances, London Academy of Trading will process sensitive personal data about an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding London Academy of Trading’s equal opportunities policies and related provisions.
(c) Information about an employee’s criminal convictions will be held as necessary and only in accordance with Data Protection Legislation.

The lawful basis for processing this special category personal data will be:
The GDPR Article 9(2)(b) ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

Sharing personal data

We sometimes need to share the personal information we process with you and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Laws.

We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfers of personal data outside of the EU. 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 UK data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

Where necessary or required we will share your information with:

· family, associates and representatives of the person whose personal data we are processing;

· current, past or prospective employers;

· healthcare, social and welfare organisations;

· suppliers and service providers;

· financial organisations;

· auditors;

· police forces, security organisations;

· courts and tribunals;

· prison and probation services;

· legal representatives;

· local and central government;

· consultants and professional advisers;

· trade union and staff associations;

· survey and research organisations, and

· press and the media.

Furthermore, in order to fulfil its statutory responsibilities, London Academy of Trading is required to provide some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.

Automated processing

London Academy of Trading does not use automated processing and decision making without manual intervention.

Principles

We will handle your personal data in accordance with the principles set out below:

Principle

Personal Data shall be:

Lawfulness, fairness and transparency be processed lawfully, fairly and in a transparent manner in relation to the data subject.
Purpose limitation collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data minimisation adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy accurate and, where necessary, kept up to date.
Storage limitation kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
Integrity and confidentiality processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

Accountability

be able to demonstrate compliance with the above principles

Keeping personal data up-to date

The Data Protection Laws require us to take reasonable steps to ensure that any personal data we process is accurate and up-to-date. Employees are responsible for informing us of any changes to the personal data that they have supplied during the course of their employment. You can contact cezannehr@gus.global to update your personal data.

Retention of your data

London Academy of Trading retains personal information it collects from you where there is an ongoing business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When there is no ongoing business need to process your personal information, London Academy of Trading will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then London Academy of Trading will securely store your personal information and isolate it from any further processing until deletion is possible. Personnel files are retained for a period of at least 6 years from the date of termination of employment.

How does London Academy of Trading protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Your information will not be transferred outside of the EU.

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.

Right 6: A right to object to our processing of personal data held by us about you.

Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

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@lat.london

Changes to our privacy Policy

Any changes we make to this privacy notice in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

London Academy of Trading maintains a data protection registration with the Information Commissioner’s Office, the independent authority which oversees compliance with the Data Protection Legislation. London Academy of Trading registration number is ZA130604 and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the Information Commissioners Office website for details.

Who do I contact with questions?

The data controller for the purposes of the General Data Protection Regulation is London Academy of Trading. If you have any questions or concerns about how your personal data is used, please consult https://lat.london/privacy-policy/ and if you have a complaint please email London Academy of Trading Data Protection Officer at: dpo@lat.london

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner’s Office. Full details may be accessed on the complaints section of the ICO’s website

 

Recruitment Privacy Notice

1. What is this notice?

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.

2. 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.

3. 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.

4. Where does your personal information come from?

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

· Recruitment agencies and apprenticeship providers may provide us with the following personal information: personal contact details, qualifications, schools attended, details of previous employment(s), skills and experience, hobbies and interests, and interview notes.

· Credit reference agencies may provide us with the following personal information: personal contact details, date of birth, details of credit accounts and usage and an overall credit score.

· Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: role(s) held, dates of employment, details of skills and capabilities and any other information that helps to assess your suitability for the position applied for.

· London Academy of Trading’s staff may provide us with: personal information about you if they are referring you for recruitment.

· Medical professionals may provide us with the following personal information: information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability.

· 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.

· Google and social networking accounts (such as LinkedIn): as part of the recruitment process we may source personal information relating to roles you have held, details of skills and capabilities and any other information that helps us to assess your suitability for the position applied for.

· Disclosure Scotland: as described at section 6 below.

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.

5. 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:

· Retain records relating to the recruitment process;

· Establish, exercise or defend legal claims;

· Comply with the law or requirements of any regulator; and

· Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).

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 UK

To enter a contract

To comply with a legal obligation

Documentation confirming your right to work in the UK

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
  • Information on gender reassignment*
  • Data revealing race, religious beliefs or sexual orientation*

6. 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) from Disclosure Scotland, and provide us with a copy of this.

7. 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.

8. Statutory requirement to provide your personal information

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

· Documentation confirming your right to work in the UK – you are not obliged to provide this information, but if you don’t provide it, we will not be able to enter into a contract with you.

9. 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:

· 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.

10. 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.

11. Transferring your personal information outside the EU

We share your personal data within the GUS Group. This will involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

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 UK data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

12. Data retention

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

· to allow us to establish, exercise or defend legal claims; and

· for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.

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@lat.london

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner’s Office. Full details may be accessed on the complaints section of the ICO’s website

Former employees Privacy Notice

Former employees

London Academy of Trading (“we”, “our”, “us”) are committed to protecting and respecting your privacy.

This privacy notice applies to former employees of London Academy of Trading.

It is important that you read this privacy notice together with our privacy notice at: https://lat.london/privacy-policy/ or any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you. This is so that you are fully aware of how and why we are using your data.

Information we collect

London Academy of Trading does not collect personal data from former employees after they have left our employment, but it may hold the information that was collected before and during the employment relationship, including:

• 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

• Copy of identification (Passport/driving licence)

• Bank account details, payroll records and tax status information

• Salary, annual leave, pension and benefits information

• Start date

• Location of employment or workplace

• 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, training records and professional memberships)

• Compensation history

• Performance information

• Disciplinary and grievance information

• CCTV footage and other information obtained through electronic means such as swipecard records

• Information about your use of our information and communications systems

• Photographs

Our lawful basis for processing

The lawful bases for processing personal data will be:

Article 6(1) (b) Contract

Article 6(1) (c) Legal obligation

Article 6(1) (f) Legitimate interest

How we process your information

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 the obligations in a contract we have entered into with you, such as the employment contract, or a settlement agreement. Some of the contractual obligations in these contracts continue after your employment has terminated, such as the duty to observe confidentiality.

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

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your vital interests (or someone else’s vital interests). Article 6(d).

2. Where it is needed in the public interest. Article 6(1) (e).

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.

We may process your data for the following purposes:

• Paying you and deducting tax and National Insurance contributions and other lawful deductions.

• Providing you with any employee related benefits to which you are entitled after the termination of your employment.

• To reimburse you for expenses incurred in the course of your employment.

• Liaising with your pension provider and the trustees/administrators of pension schemes.

• Administering any contract we have entered into with you.

• Business management and planning, including accounting and auditing.

• Gathering evidence for possible grievance or disciplinary hearings.

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

• To prevent and detect fraud.

• 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 (such as the staff survey) to review and better understand employee retention and attrition rates.

• Equality and diversity monitoring

• Publicising our activities (e.g., group photos of events, site visits, etc.).

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

How we process “special categories” of more sensitive personal information

We may also store and use the following “special categories” of more sensitive personal information that we have collected from you:

• 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.

• Biometric data.

• Information about criminal convictions and offences.

These “special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for storing and using this type of personal information. Our data protection policy contains details of the 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. Where we need to carry out our legal obligations or exercise rights in connection with employment.

2. Where it is needed in the public interest: for example, 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 equality and diversity monitoring and reporting. Where possible, we would seek to anonymise this data.

3. In limited circumstances, with your explicit written consent. However, we do not need your consent to use special categories of your personal information 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.

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.

Who is the information shared with

We may share your data with third parties, including third-party service providers, Government departments and agencies.

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

London Academy of Trading shares your data with:

• Occupational Pension Scheme Trustees and Administrators.

• Occupational Health providers screening

• Trade Unions of which you are a member

Retention

London Academy of Trading will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected.

London Academy of Trading has a records retention schedule that outlines how long we will retain information.

To determine the appropriate retention period for personal data collected as part of your employment, 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 we will retain and securely destroy your personal information after the following periods

• 12 months from date of leaving for employees; except

• Payroll, tax and NIC records which must be retained required for 6 years. This is a legal requirement.

However, these periods only apply to your employment records and not for example to images and materials created and use for marketing and communication purposes (e.g. group photographs taken at away days etc.)

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.

Right 6: A right to object to our processing of personal data held by us about you.

Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

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@lat.london

 

Changes to our privacy Policy

Any changes we make to this privacy notice in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

London Academy of Trading maintains a data protection registration with the Information Commissioner’s Office, the independent authority which oversees compliance with the Data Protection Legislation. London Academy of Trading registration number is ZA130604 and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the Information Commissioners Office website for details.

Who do I contact with questions?

The data controller for the purposes of the General Data Protection Regulation is London Academy of Trading. If you have any questions or concerns about how your personal data is used, please consult https://lat.london/privacy-policy/ and if you have a complaint please email London Academy of Trading’s Data Protection Officer at: dpo@lat.london

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner’s Office. Full details may be accessed on the complaints section of the ICO’s website

 

 

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