Contact us on 07500046251 or info@space2think.org

Privacy Policy

Introduction

Space2think Ltd is committed to data security and the fair and transparent processing of personal data. This privacy policy sets out how Space2think treat learner personal data.

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.

Who are we?

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), Space2think is the ‘controller’ of learner personal data. Space2think is a Limited Company incorporated by Companies House, Registered in England and Wales No. 06183176. Our registered address is 99 the Fairway, Banbury, Oxon, OX16 0RS.

Space2think is a business providing coaching, training and ILM qualifications.

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact one of our Company Directors rob.husband@space2think.org or andy.howie@space2think.org  or writing to them at Space2think Ltd, 99 The Fairway, Banbury, Oxon, OX16 0RS

What personal data do we collect?

We may collect and process the following personal data: name, gender, date of birth, email address, postal address and phone number, If you:

  • complete a programme registration form
  • complete a form on our Website
  • complete a survey;
  • correspond with us by phone, e-mail, or in writing;
  • report a problem;
  • sign up to receive our communications;
  • create an account with our online lining resources;
  • enter into a contract with us to receive products and/or services

We may also collect other categories of personal data if required in relation to a specific qualification or programme, and personal data if required to carry our quality assurance processes, investigations, complaints and appeals. If you are enrolling on an ILM programme this data will be passed onto ILM to enable your registration on the appropriate ILM programme.

When you are enrolled on an ILM programme through with Space2think there may be exceptional circumstances, where we may collect sensitive information, such as information about your health, to enable us to administer requests for reasonable adjustments, or sensitive personal data relating to an investigation, complaint, or appeal. Such information will only be passed on to the ILM with your explicit consent.
ILM will assign a unique learner number to each learner at the point of learner enrolment which we also use in relation to your learning, assessment, and certification.

If you visit our Website, we may automatically collect the following information:

  • technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit to our Website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

 

How do we use your personal data?

We may use your personal data where this is necessary to pursue our legitimate interests as a provider of coaching, training and ILM qualifications including to:

  • provide you with products and/or services for which you have registered;
  • undertake administration in relation to products and/or services for which you have registered;
  • provide you with a certificate, credential or other record of learning;
  • contact you directly in relation to new and existing products, services, news, awards and events offered by Space2think Ltd. This includes a quarterly newsletter.
  • contact you directly in relation to our quality assurance processes, investigations, appeals, and complaints;
  • assess and provide reasonable adjustments in relation to your learning or assessment where requested.
  • improve the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our Website;
  • perform analytics on sales/marketing data, determining the effectiveness of promotional campaigns.

We may also process your personal data if required by law, including to respond to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

 

Who do we share your personal data with?

We will share your personal data with relevant third parties, where necessary, in relation to your learning, assessment, or certification, including:

  • The ILM
  • ‘Processing’ bodies for psychometric and team role profiles (e.g. Clarity 4D, Myers Briggs Type Indicator, AQR, Belbin and any other that are required as part of a specific intervention)

We may share your personal data with The Institute of Leadership & Management (TILM) to enable TILM to offer you student membership in relation to leadership and management. You can find out more about TILM at www.institutelm.com 

We may also share your personal data with third party providers including:

  • service providers contracted to us in connection with provision of learning, assessment, and training products and services such as markers, moderators, assessors, psychometric tool operators.
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will ensure there is a contract in place with such third parties which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data is protected by appropriate safeguards, including the use of model data protection clauses adopted or approved by the relevant authority where the data protection authority does not believe that the country has adequate data protection laws.

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

In regard of ILM programmes we will retain personal data relating to your learning, assessment, and certification to enable us to provide information about your learning or a replacement certificate.

For ILM programmes we will retain personal data relating to our quality assurance processes, appeals, or investigations for a period of 7 years to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

For non ILM programmes we will retain personal data for the length of the agreed intervention. Where we are the ‘controller organisation; personal data may be retained for a longer period by the ‘processor organisation’ e.g.  Clarity 4D, Belbin. Each of these will have their own privacy policies.

Where do we store your personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Your rights

Under the GDPR, you have various rights with respect to our use of your personal data:

The initial right is that of gaining consent. If we have your consent, we may use your personal data to:

  • send you newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by a member of the City & Guilds Group which may be of interest to you;
  • developing, improving, and delivering marketing and advertising for products and services offered by a member of the City & Guilds Group.

Right to Access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if there is no basis for your request, or if it is excessive.

Right to rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Right to restrict processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.

Right to data portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller or processor, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request make such request, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Contact

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact one of our Company Directors rob.husband@space2think.org or andy.howie@space2think.org  or writing to them at Space2think Ltd, 99 The Fairway, Banbury, Oxon, OX16 0RS

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.

Changes to our Policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.