Privacy Policy

Introduction


The Institute of CPD (“ICPD”, “we” or “us”) is committed to data security and the fair and transparent processing of personal data. This privacy policy (“Privacy Policy”) sets out how we treat your personal data when you visit and interact with our website [www.cpdinstitute.org] and/or our [The Institute of CPD] app (collectively, the “Platform”), regardless of where you visit it from, or when your personal data is otherwise collected through our provision of products and services, and tell you about your privacy rights and how the law protects you. 


IMPORTANT INFORMATION AND WHO WE ARE


Purpose of this Privacy Policy


This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Platform (including any data you may provide through the Platform as detailed in the section headed “HOW IS YOUR PERSONAL DATA COLLECTED?” below) and through our provision of products and/or services.


The Platform is not intended for children under the age of 16. We do not knowingly collect data relating to children under such age.


It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.


Who we are


ICPD is a trading name of The Professional Development Consortium Limited, a UK company limited by shares, with registration number 08293321. Our registered office address is 21 Navigation Business Village, Navigation Way, Ashton-On-Ribble, Preston, Lancashire, United Kingdom, PR2 2YP.


We are a professional membership body that connects like-minded people with the shared purpose of inspiring others to part-take in continuing professional development.


Controller


We are the controller and are responsible for your personal data.


We have a data protection team which is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our data protection team using the following details:


Full name of legal entity: The Professional Development Consortium Limited


Email address: hello@cpdinstitute.org


Postal address: The Institute of CPD (ICPD), The Old Station, Moor Lane, Staines-upon-Thames, TW18 4BB


You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.


Changes to the Privacy Policy and your duty to inform us of changes


We keep our Privacy Policy under regular review. 


Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.


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


Third-party Links


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


THE DATA WE COLLECT ABOUT YOU


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


As further detailed in the table below in the section headed “HOW WE USE YOUR PERSONAL DATA”, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:


  • Identity Data includes first name, last name, username or similar identifier, marital status, title, learner registration number, date of birth and gender.


  • Contact Data includes billing address, postal address, delivery address, email address and telephone numbers.


  • Financial Data includes bank account and payment card details.


  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.


  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform.


  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses and your interactions with our online learning tools, including certification bookings and assessments.


  • Usage Data includes information about how you use our Platform, products and services – 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.


  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We may also collect personal data that includes “Sensitive Data” (also known as “Special Category Data”)..


For verification purposes, we reserve the right at any time to request additional information (including but not limited to the kinds of personal data listed above) from you to help confirm your identity.


If you fail to provide personal data


Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


HOW WE COLLECT YOUR PERSONAL DATA


We use different methods to collect data from and about you including through:


  • Direct interactions. You may give us your personal data (in those categories listed above) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:


  • apply for and/or purchase our products or services;


  • create an account on our Platform;


  • subscribe to our service or publications/communications;


  • request marketing to be sent to you;


  • enter a competition, promotion or survey; 


  • use any other websites we operate or other services we provide;


  • report a problem; or


  • give us feedback or contact us.


  • Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.


  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, such as:


  • analytics providers, advertising networks, search information providers, sub-contractors and providers of technical, payment, delivery, back-up and data storage services, credit reference agencies, data brokers or aggregators;


  • if you are a learner: learning centres, training providers or your employer when they register to receive products and/or services from us;


  • third parties to whom you have provided personal information that you have elected to transfer to us; and 


  • publicly available sources, such as Companies House and the Electoral Register based within the UK.


HOW WE USE YOUR PERSONAL DATA


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


  • Where we need to perform the contract we are about to enter into or have entered into with you.


  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.


  • Where we need to comply with a legal obligation.


To find out more about the types of lawful basis that we will rely on to process your personal data, please see the Glossary below.


Generally, we do not rely on consent as a legal basis for processing your personal data. Where we do rely on consent, you have the right to withdraw consent to marketing at any time by contacting us.


Purposes for which we will use your personal data


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest 

To register you as a new customer

(a) Identity


(b) Contact


(c) Profile

Performance of a contract with you

To process and deliver your order of products and/or services, including:


(a) Managing payments, fees and charges


(b) Collecting and recovering money owed to us


(c) Providing you with a certificate, credential or other record of learning



(a) Identity


(b) Contact


(c) Financial


(d) Transaction


(e) Marketing and Communications



(a) Performance of a contract with you


(b) Necessary for our legitimate interests (to recover debts due to us)



To manage our relationship with you which will include:


(a) Notifying you about changes to our terms or privacy policy


(b) Asking you to leave a review or take a survey


(c) Communicating with you in relation to the provision of any contracted products and services


(d) Communicating with you in relation to any issues, complaints or disputes



(a) Identity


(b) Contact


(c) Profile


(d) Marketing and Communications


(a) Performance of a contract with you


(b) Necessary to comply with a legal obligation


(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)



To enable you to partake in a prize draw, competition, research or complete a survey

(a) Identity


(b) Contact


(c) Profile


(d) Usage


(e) Marketing and Communications



(a) Performance of a contract with you


(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)



To administer and protect our business and this Platform, including


(a) Troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data


(a) Providing administrative support, such as account creation, security and responding to issues


(b) Enhancing security measures in place that protect data for which we are responsible



(a) Identity


(b) Contact


(c) Technical



(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)


(b) Necessary to comply with a legal obligation

To deliver relevant Platform content, industry information, information about our awards and events, news and promotions relating to our new and existing products and services to you, and to measure or understand the effectiveness of the advertising we serve to you

(a) Identity


(b) Contact


(c) Profile


(d) Usage


(e) Marketing and Communications

(f) Technical



Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our Platform, products/services, sales/marketing, customer relationships and experiences, and to determine the effectiveness of promotional campaigns

(a) Technical


(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about products and services, awards, events, offers and promotions that may be of interest to you

(a) Identity


(b) Contact


(c) Technical


(d) Usage


(e) Profile


(f) Marketing and Communications



Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.


Promotional offers from us


We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).


You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.


Opting out


You can ask us to stop sending you marketing messages at any time by using the ‘unsubscribe’ functionality on the footer of any marketing communications sent to you, or by updating your details in your account profile. 


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. 


For the avoidance of doubt, this section does not apply to communications that we may send to you as part of your contract with us. For example, where we send you information about products & services that are delivered as part of your membership contract with us.


Cookies


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


Change of purpose


We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


DISCLOSURES OF YOUR PERSONAL DATA


We may share your personal data with the parties set out below for the purposes set out in the table above.


  • Internal Third Parties as set out in the Glossary below.


  • External Third Parties as set out in the Glossary below.


  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


INTERNATIONAL TRANSFERS


Some of our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.


Should an international transfer take place, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:


  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.


  • Where we use certain service providers, we may use specific contracts or data protection clauses commonly adopted or approved for use in the UK or the European Economic Area (“EEA”) which give personal data the same protection it has in the UK or the EEA.


DATA SECURITY


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.


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


DATA RETENTION


How long will we use your personal data?


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


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


Ordinarily, where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of six years following the end of our financial year to which such records relate, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities. 


In some circumstances you can ask us to delete your data: see the section headed “YOUR LEGAL RIGHTS” below for further information.


In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS


Under certain circumstances, you have rights under data protection laws in relation to your personal data.


Please see the sub-section on “YOUR LEGAL RIGHTS” of the Glossary below to find out more about these rights.


If you wish to exercise any of these rights, please contact us.


No fee usually required


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


What we may need from you


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Time limit to respond


We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


GLOSSARY


LAWFUL BASIS


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


  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


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


THIRD PARTIES


Internal Third Parties


Other companies in the same corporate group as ICPD, acting as joint controllers and who are based in the United Kingdom, and provide IT and system administration services and undertake leadership reporting.


External Third Parties


  • Service providers in connection with our provision of products and services, such as providers of IT and system administration services, distributors of journals and customer relationship management services.


  • Analytics and search engine providers that assist us in the improvement and optimisation of our Platform.


  • Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.


  • HM Revenue & Customs based in the United Kingdom, regulators and other authorities (whether national or international) who require reporting of processing activities in certain circumstances.


  • Any other third party in the event that we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions, including exchanging information with other companies and organisations for the purposes of crime and fraud prevention.


YOUR LEGAL RIGHTS


You have the right to:


  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Please note that 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, or if we are legally prevented from disclosing such information.


  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:


  • If you want us to establish the data’s accuracy.


  • Where our use of the data is unlawful but you do not want us to erase it.


  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.


  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.


  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.


  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Document Last Updated: 31st March 2022