Hertfordshire Community Learning, also known as DCFL, is the Data Controller and Data Processor for personal data about staff, tutors, course attendees, and volunteers.
Our Information Commission Office (ICO) registration number is ZA166495.
We do not trade personal data for commercial purposes and will only disclose it if is required by law, if it is necessary to confirm your course/event attendance, if it is required as part of a contract with a funder or if it is with your consent.
This policy was updated in April 2018 to show that we are adhering to the new General Data Protection Regulation (GDPR), which comes into force in May 2018.
Register of Interest
If you subscribe to our register of interest list either by telephone, paper form or from our website you will automatically receive information whenever a course is organised that meets the criteria you gave us. You will only receive information that you have opted in to receive.
We use Google Gmail through our own domain name as our email service. Google store their data in the US although they comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework. It does share data with third parties. Details of Googles privacy notices can be found at https://policies.google.com/privacy
We transfer all contacts to our own spreadsheet, Microsoft Excel, held on a desktop PC in our offices, and archived on our Google Drive account.
You can ask to remove your details from the list at any time firstname.lastname@example.org
We use online and paper-based surveys and quizzes to check whether you have understood the teaching of our courses and to give feedback on the quality of our provision. The data collected from our surveys is either fully anonymised or pseudonymised. The online services connected to these surveys/quizzes are Kahoot, Quizizz, and Google Forms. All these companies store their data in the US although they comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework. Google, Kahoot, and Quizizz have privacy notices which can be checked on their websites. Hertfordshire Community Learning downloads the statistical data relating to learners answers and stores the data in a spreadsheet on a desktop PC and backed up to Google Drive account. Some data is shared with funders as a means for them to check the quality of provision. We do not keep this data longer than is necessary and will only keep anonymous copies after the end of the educational year.
We use Google Analytics (GA) to track site user interaction. We have GA code installed on our site which creates one or more text files on your computer (called a “cookie”). The cookies contain an ID number which is used to uniquely identify your browser and track each site you visit that has GA enabled.
We use this data to determine the number of people using our site and to better understand how they find and use our web pages. With this information, we can continually improve the information that we provide on our site and the processes for actions such as contacting us and donating. We can also use it to increase the number of new people finding our site.
Google Analytics stores the following data:
– Time of visit, pages visited, and time spent on each page of the webpages
– Interactions with site-specific widgets
– Referring site details (such as the URL a user came through to arrive at this site)
– Type of web browser
– Type of operating system (OS)
– Network location and IP address
– Document downloads
– Clicks on links leading to external websites
– Errors when users fill out forms
– Clicks on videos
– Scroll depth
Google also collects information about you from its Doubleclick tracking and profiling service, from ad-supported apps on your Android or iOS device, from your YouTube and Gmail activity and from your Google account. This data is put together and used to make inferences about your age, gender, interests, hobbies, shopping habits and living circumstances.
If you already have GA cookies, they will be updated with the latest information about your visit to the site.
As we cannot access any personal data about you ourselves, we are not the Data Controller for your Google Analytics or Doubleclick profile data. You would need to contact Google directly for this information. Google has published a detailed explanation of their privacy rules in regard to Google Analytics on their website.
You have the right to object to this tracking and to stop it happening.
If you would like more detail about the methods used, however, please get in touch at email@example.com
How do I prevent being tracked by Google Analytics?
If you are uncomfortable with this tracking, you can take the following actions:
– Use a tracking-blocker, such as Privacy Badger
– Clear cookies after every browsing session
– Install the Google Analytics opt-out extension
Hertfordshire Community Learning uses Facebook to advertise its courses and encourage people to undertake adult learning. You may come across Hertfordshire Community Learning naturally on Facebook through your own networks, we do this to inform, educate and engage new potential learners. We do not add personal information to Facebook but may add photographs.
Facebook is a hugely valuable tool for us and for the community that we serve, which is why we use the platform. Facebook, however, is a commercial company. We want to remind our users that formation shared on timelines, on our page or in private messages may be used or sold by Facebook for commercial purposes.
When you sign up for a Hertfordshire Community Learning course, we collect a significant amount of personal data which you provide by completing our enrolment form. We will use this information solely for the purpose of administering the course. The data is required as part of contracts with our funders, Hertfordshire Adult Family Learning Services (HAFLS) or Dacorum Borough Council (DBC). They may share your data with other agencies. We do not share this data with any other agency or organisation. If the data is collected as a paper form it is digitised and stored on our Google Drive account. Forms collected digitally are stored on our Google Drive Account. The original forms are sent to our funders. The data collected from enrolment forms is entered by us into a database provided by HAFLS as part of our contract with them. We will keep your data for a period of two years in case you wish to sign up for another course.
Privacy notices for HAFLS and DBC can be found on their websites.
Some of our courses offer online modules to aid revision or give more depth. We use Moodle on a website protected with TLS (Transport Layer Security), shown by the use of ‘https’ and the Padlock in the address bar, as the software for creating the online modules. Access to the modules is password protected for each individual learner and only the course organiser will have access to any learner input. All learner feedback from the online modules is deleted after one year. Personal data is not shared, though anonymised data may be shared with HAFLS to show usage.
From time to time Hertfordshire Community Learning may take photographs at courses or events to document the way the courses or events are run and for promotional use in brochures leaflets and on our website. We will always ask for your permission before a photograph is used.
Employees, Volunteers, and job applicants
We collect personal data relating to those we employ as office staff, tutors or volunteers. We do this for employment purposes, to assist in the running of the organisation and/or to enable individuals to be paid. The personal data includes identifiers such as Name, Date of Birth, National Insurance Number, DBS information, Personal characteristics such as gender and ethnic group, qualifications and absence information. We will not share information about you with third parties without your consent unless the law allows or requires us to. We are required to share some of your personal data with:
- Community Action Dacorum (for payroll)
- Our bank
The data we collect is stored on a Spreadsheet and backed up on Google Drive. We also use Trello, (an online collaboration tool) as an aid to managing workflow. Once you stop working for us, we will keep this information only for the period of time required by law. You can contact us to find out more about this.
If you apply to work or volunteer at Hertfordshire Community Learning, we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside Hertfordshire Community Learning – for example, if we need a reference, or need to get a ‘disclosure’ from the Criminal Records Bureau – we will make sure we tell you beforehand, unless we are required to disclose this information by law. If you are unsuccessful in your application we will hold your personal information for 12 months after your application. After this date, we will destroy or delete your information.
As an individual whose personal data is processed by Hertfordshire Community Learning you have the following rights:
- the right to be informed – which is what this privacy notice is for
- the right to access the data we hold about you the right to object to direct marketing
- the right to object to processing carried out on the basis of legitimate interests
- the right to erasure (in some circumstances)
- the right of data portability
- the right to have your data rectified if its inaccurate
- the right to have your data restricted or blocked from processing
To exercise any of these rights, please email firstname.lastname@example.org or telephone 01442251930 to get in touch.
If you are not happy with the way we have handled your data, and are unable to resolve the issue with us personally, you can complain to the ICO.