Privacy Policy

1.0 CONTEXT AND OVERVIEW

KEY DETAILS

  • Policy prepared by: Data Protection Leader
  • Approved by Board: 01/05/2018
  • Policy became operational on: 25/05/2018
  • Next review date: 01/05/2019 

INTRODUCTION

Mentor FLT Training Limited (Mentor) needs to gather and use certain information about individuals.

Information can be held by Mentor relating to customers, suppliers, instructors, business contacts, course delegates, employees and other people that the organisation has a relationship with or may need to contact.

2.0 PERSONAL DATA HELD AND REASONS FOR PROCESSING

Mentor holds electronic data required to:

  • Carry out its day to day functionality.
  • Produce a certificate for an individual who has attended a course.
  • Produce ‘delegate reports,’ when requested, by a company wanting to have details of their employees who have been on a course provided by Mentor.
  • Share the individual’s details with the appropriate accrediting body for the type of training undertaken.
  • Process sales invoices to companies or individuals for services or training materials provided by Mentor.
  • Process purchase invoices for services or materials provided to Mentor.
  • Mentor holds electronic data on individuals in the CRM (Customer Relationship Management) system, accounting package, Office 365 and within the file structure on the server.
  • Mentor records and stores data on paper forms required to:
  • Carry out its day to day functionality, to test delegates who attend its courses.
  • To produce a certificate for an individual who has attended a course.

CRM:

Mentor holds information in its CRM system.

Data can be collected/stored for:

  • The company and company contacts with whom the Mentor Sales Teams and other departments communicate.
  • The individual contacts, employed by these companies, who attend a training course.

3.0 DATA COLLECTION AND STORAGE

Data held on the CRM system consists of

  • Company contacts
    • The company whom the individual is employed by
    • Name
    • Job title and role within the company
    • Contact’s phone numbers
    • Contact’s company email address
    • Company address
    • Opt in / opt out of which type of marketing communications
  • Individual’s data
    • Company whom the individual is employed by
    • Name
    • Employee Number
    • Date of birth
    • Course dates
    • Course details
    • Scores
    • Passed / failed

Individuals’ data is collected through the completion of forms known as test sheets and course evaluation forms. These forms are completed by the individual on the course and by a sub-contracted instructor who is authorised as a sub-processor by Mentor.

The forms will include a statement explaining why we need to collect the data and with whom we share it.

Data collected is used to create a certificate for the individual (delegate) which is then either sent to the contact at the individual’s workplace or a central contact, dependent upon the terms agreed in the contract between the company and Mentor.

  • Individual’s data shared to the following people / organisations
    • With the company that ordered the training in the form of a certificate and / or badge. This information will only include:
      • Name
      • Employee number
      • Truck details (for the truck used during testing)
      • Dates of training
      • Instructor / Examiner that carried out the training / testing
  • Tracking online activity

Mentor track activity on their website and engagement with their online marketing via cookies and marketing analysis tools, for example Google Analytics. Data retention controls are in place to periodically remove user data over time.

Cookies are also used on the Mentor website to track shopping basket contents and remember where users are in the order process. Users can disable any cookies stored on their computer, but this may limit the functionality of the Mentor website.

The following are necessary for the website to function properly - the Mentor website will:

  • remember what is in your shopping basket
  • remember where you are in the order process
  • remember that you are logged in and that your session is secure. You need to be logged in to complete an order

The website will not share any personal information with third parties.

4.0 SHARING OF DATA

It is a function of all training companies that they share data about who has been trained with the appropriate accrediting body.

  • The individual’s data is shared with the appropriate accrediting body as required by Health and Safety Law. This will include:
  • Name
  • Date of birth
  • Course start date
  • Course end date
  • Length of course
  • Duration of course
  • Test date
  • Instructor / Examiner name and registration number
  • Course type
  • Truck type

All the data that we hold on individuals who have done courses with us is classed as low risk. We hold no financial records or home addresses for these individuals.

5.0 ACCURACY OF DATA

COLLECTION OF NEW CONTACTS AND ACCURACY OF DATA

Mentor will endeavour to accurately collect the data it needs and provide clear and transparent justification for doing so, referenced at the point of collection, including a privacy policy that is accessible via the website or the App (once developed).

New contacts and sales leads must be constantly brought in to the company to ensure survival and growth. 

Mentor aim to bring in new contacts through the following ways, although this is not an exhaustive list

  • Website
  • Cold calling
  • Visits
  • Leads across company groups
  • Leads through trade union groups
  • Marketing – online and trade magazines
  • Trade shows

Mentor will only market to / contact companies where we believe content will be of legitimate interest to the company / individual but will always provide them the opportunity to opt out via links contained in every email.

Mentor does not use purchased leads to build up its contact database.

6.0 DATA SECURITY AND DATA BREACHES

Mentor will protect itself to the best of its ability against data breaches through staff training and by keeping its IT systems up to date with the latest anti-virus, ransomware and firewall protection, and by complying with the latest best practice for data storage and protection. Mentor’s website will also be tested against hackers ensuring that there is no ‘backdoor’ entry to gain access to the IT system and individual’s data.  If Mentor do suffer a personal data breach, the Data Protection Leader will notify the ICO and the affected parties within 72 hours of the breach. Mentor consider a breach to be an occurrence involving a loss of data which presents a risk to the rights and freedom of any individuals involved, and could result in:

  • Discrimination
  • Damage to reputation
  • Financial loss
  • Loss of confidentiality
  • Any other significant economic or social disadvantage.

7.0 DISCLOSING DATA FOR OTHER REASONS

In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies without consent of the data subject.

Under these circumstances, Mentor will disclose requested data.  However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

8.0 PROVIDING INFORMATION

Mentor aims to ensure that individuals are aware that their data is being processed and that they understand:

  • How the data is being used
  • How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

This is available on request. A version of this statement is also available on the company’s website.

9.0 RIGHT TO BE FORGOTTEN

Due to the nature of the industry in which Mentor operates, we believe in the Right to be Forgotten. 

  • Attendees of a course: if an individual employed by a company requests the right to be forgotten, Mentor will first check with the company to ensure that they approve this data removal from their training records. Once approved, the data can be removed from the CRM.
  • CRM Contact: if a contact no longer wishes to be contacted then we can remove that individual’s data from the CRM. If we have provided training for their company then we cannot delete their company record from our CRM as individual training records will be associated to it.
  • Tracked online activity: anyone who would like records of their online activity removed can request to do so by emailing the Data Controller.

10.0 DELETING DATA

If a contract ends between Mentor and the customer, Mentor can provide all the personal data that they hold about the customer and the individuals within the organisation, if requested.

Mentor will not delete the associated training records as this data may be requested as evidence of training if for example, an individual has an accident.

  • Personal data for people who have attended one of our courses has to be stored and recorded to meet standards set by the Health and Safety Executive. The industry standard for keeping this data is a minimum of 7 years. After 7 years all paper copies of the personal data collected will be shredded on-site by an approved shredding company. Electronic data is stored back to 2007. Our customers use this data to prove compliance to the standards set within the ACOP L117.

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