GDPR

The data controller in respect of your personal data is Claret & Blue Training (referred to as ‘we’ ‘our’ or ‘us’ in this statement). If you have any queries about our handling of your information, you can contact our Data Protection Officer by writing to Claret & Blue Training, 7 Sunnybank Road, White Horse View, Westbury, Wiltshire, BA13 3EA.

 This data protection statement explains how we will use the personal data that you provide to us via your intermediary or via on an online application or that we have obtained about you through our use of the personal data you have provided (referred to in this policy as your ‘information’) when you enter into an agreement with us.

The categories of information that we may collect about you are as follows: name, address, e-mail address, telephone number, company name and address, occupation and any documents required to be provided by you. From time to time we may require other forms of personal information as required to comply with legal or regulatory requirements.  If you fail to provide us with the mandatory information that we request from you, we may not be able to properly manage the agreement we have with you (for example, it may have an impact on our ability to assist you with any queries). 

If your information changes during the terms of the agreement we have with you, you must inform us immediately.

The purposes for which we use your information and the legal bases under data protection laws on which we reply to do this are as follows (as relevant): 

It is necessary for the performance of the agreement with you or to take steps to enter into it. This includes administering the agreement between us (including tracing your whereabouts to contact you and recover debt) and to provide you with the service under that agreement (ie communicating with you, providing updates, dealing with any complaints, notifying you of any changes to this statement). 

It is necessary for our legitimate interests. This includes: 

• to understand your needs and provide a better service to you and to help us develop and improve our products and services; 

• to protect our business and to comply with laws that apply to us; 

• monitoring communications between us (calls, letters, e-mails and texts) to prevent and detect crime, to protect the security of our communications, systems and procedures, and for quality control and training purposes; 

• for management and audit of our business operations and system testing in order to protect our business; 

• creating a profile of you to enable us to identify and personalise what products and services to offer you for marketing purposes; 

• conducting a review to enable us to provide relevant and timely renewal communication activities;

It is necessary for compliance with a legal obligation. This includes when you exercise your legal rights under data protection law, to verify your identity, for the establishment and defence of our legal rights for compliance with our legal and regulatory responsibilities. This may also include processing special categories of data about you, for example for our compliance with our legal obligations relating to vulnerable people or if you go into arrears with your payment.

You have given us your consent to use it in certain ways including when you request that we disclose it to a third party. You can withdraw your consent at any time.

We disclose your information to the following: 

• Law enforcement agencies in order to detect, investigate and prevent crime (we or any fraud prevention agency may pass your information to law enforcement agencies). 

• Third party debt collecting agencies engaged by us to recover monies owed to us. 

• Any third party to whom we sell your debt. If we do this, you will be notified, and that third party will become the data controller of your information. 

• Third parties acting on our behalf, such as back-up and server hosting providers, IT software and maintenance providers and their agents. 

• Outsourced service providers required for compliance with legal and regulatory obligation, or for marketing activities where your consent has been provided. 

• Market research organisations engaged by us to undertake customer satisfaction surveys and market research. 

• Courts in the United Kingdom or abroad as necessary to comply with a legal requirement, for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations. 

 Should you not enter into an agreement with us, we retain your information for 6 months or as long as necessary to deal with any queries you may have.

We may hold your information for a longer or shorter period from that described above where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law; and
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

 You have the following rights (which may not always apply or be subject to certain circumstances):

• to be informed about the processing of your information (this is what this statement sets out to do);
• to have your information corrected if it is inaccurate and to have incomplete information completed;
• to object to processing of your information;
• to restrict processing of your information;
• to have your information erased;
• to request access to your information and information about how we process it; 
• to move, copy or transfer your information (‘data portability’).

We may update the data protection statement from time to time. When we change the data protection statement in a material way, a notice will be displayed on our website along with the updated data protection statement.

We encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have. You have the right to complain to the Information Commissioner’s Office where your data has or is being used in a way that you believe does not comply with data protection laws.