We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information, and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
The GTA University Centre Limited (‘the GTA’) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under The Data Protection (Bailiwick of Guernsey) Law 2017 (‘the Law’) which protects personal data in a manner equivalent to and consistent with the EU General Data Protection Regulation (Regulation (EU) 2016/679)) and we are responsible as ‘controller’ of that personal information for the purposes of that legislation.
Please read this policy carefully as it will help you make informed decisions about sharing your personal data with us.
- What information do we collect?
- How we use your personal information
- Who we share your personal information with
- How long will your personal data be kept?
- Keeping your personal information secure
- What are your privacy rights?
- How to complain
- Changes to this privacy notice
- How to contact us
- Cookie preference centre
1. What information do we collect?
In order to provide the full range of Services, we collect the following personal information that you voluntarily provide to us, whether by phone, SMS, email, letter or other form of communication:
- When you sign up for our newsletter we collect your email address, your name and any comments that you leave in the comments box for the sign-up form.
- When you contact us we will collect your contact information that you used to contact us (such as the email address you used) as well as any information you include in your enquiry.
- When you use the client login feature of the website we will collect information about when you log in, your activity in the client area of the website, and the device you use to log in.
- When you book a Service we will collect your first and last name, contact email addresses, contact postal addresses, contact phone numbers and other similar contact data.
- If you are booking a Service on behalf of a colleague we will need to collect the above data in respect of them as well. If you are responsible for providing third-party data to the website, it is your responsibility to confirm that you are authorised by the individual to do so.
- If you are booking a Service we may collect your financial information for the purposes of managing payment of fees.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such data.
Special category data
If you book a Service with us, and provide medical or sensitive personal data in respect of your application for either access arrangements, coursework extensions or mitigating circumstances, that data is held only for the purposes of providing such Service and is destroyed 3 months following the completion of any such Service.
Information automatically collected
When you browse the website we collect information from the device you use to browse, such as your IP address, unique device identifiers, and information from cookies and similar technologies stored on the device.
Please use our Cookie Preference Centre to manage your cookie preferences.
Information collected from other sources
We collect information through Cookies and other similar technologies (e.g. pixel tags or links) to allow us to optimise and improve your experience.
2. How we use your personal information
Any personal information we gather will only be used in accordance with the Law, this notice and for the purpose stated at the time we gather it. We never sell or lease your personal information to third parties.
We use your personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:
We use the information we collect or receive:
- To send administrative information to you: We will respond to your enquiries and bookings in respect of our Services and keep a record of our communications with you.
- To fulfil and manage your orders: We will use your personal data to fulfil and manage any payments and credits due.
- To facilitate account creation and logon process and manage user accounts: We provide you with access to the client login features of the website and manage your account if you are a client.
- To send you marketing and promotional communications: We will use the personal data you provide for our marketing purposes. You can opt-out of our marketing emails at any time.
- To post testimonials: Prior to posting a testimonial on our Services we will obtain your consent to use your initials and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and advise us of the data you wish to have amended or deleted.
- Request Feedback: We may use your data to request feedback on our Services or to participate in surveys about the Services we provide.
- To help us understand our clients and potential clients, and the effectiveness of our marketing, so that we can plan and deliver effective campaigns to develop our business.
- To understand how people use our website, so that we can design the website to suit our users.
- To protect our Services: We may use your data as part of our efforts to keep our Services safe and secure.
- To enforce our terms, conditions, and policies for business purposes, legal and contractual reasons.
- To respond to legal requests and prevent harm: We may need to share personal information with law enforcement or other authority if required by any applicable law. For other business purposes: we may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, our marketing and your experience. We may use and store this information in aggregated and anonymised form so that it is not associated with individual users and does not include personal information. We will not use identifiable information without your consent
3. Who we share your personal information with
We may process or share data based on the following legal bases:
- Consent: We may process your data if you have given us specific consent to use your data for a specific purpose.
- Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, government requests, a judicial proceeding, court order, or legal process.
- Vital interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person all illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data and share your information in the following situations:
- Third-party service providers (see below): We share your data with the businesses that provide IT and related services to us, such as our customer relationship management systems, and website hosting. We only share the types of data that those businesses need in order to provide us with those services and we make sure our data sharing is governed by a contract that controls what those businesses can do with that data.
- Business partners: Where you have requested information or made a booking with a Service delivered by a Business Partner, we may share your information with that business partner.
Third-Party service providers:
We only share and disclose your information with the following third parties. We have categorised each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke that consent, please contact us.
- Administration: We use a data management system called Administrate provided by Administrate Limited.
- Content Optimisation:
- YouTube video widget without cookies. This widget is set up in a way that ensures YouTube won’t store information and cookies about you on this website unless you play the video.
- We use this social media management platform provided by Hootsuite Media Inc.
- Invoice and Billing: We use QuickBooks, owned by Intuit Inc, to manage our invoicing.
- Virtual Terminal: Worldpay (Worldpay Limited). Any payments made via our website are made directly with the WorldPay facility. The data is not stored on our website.
- Analytics: Google Analytics is a web analysis service provided by Google Inc.
- Marketing: Campaign Monitor is an email address management and message sending service provided by Freshview Pty Ltd.
4. How long will your personal data be kept?
We will only hold your personal data for as long as is necessary for the purposes of the supply of any Services and for any legal requirement.
A small amount of data will be held indefinitely: This is the data that we need to hold so that we can confirm whether individuals attended the GTA and the services they received.
5. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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.
6. What are your privacy rights?
Under the Law you have a number of important rights in relation to our processing of your data. In summary these are:
- the right to request access to your data as processed by the GTA and information about that processing (‘subject access request’)
- the right to rectify any inaccuracies in your data
- the right to request erasure of your data from our systems and files
- the right to place restrictions on our processing of your data
- the right to object to our processing of your data
- the right to data portability. Where we are processing data that you have provided to us, on the basis or consent or as necessary for the performance of a contract between us, you have the right to ask us to provide your data in an appropriate format to you or another controller.
For further information on each of these rights, including the circumstances in which they apply, please refer to the Office of the Data Protection Commissioner www.odpc.gg. If you would like to exercise any of those rights, please contact us (see ‘How to contact us’ below).
Opting out of email marketing: If you would like to unsubscribe from any email or newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email or newsletter. It may take a few days for the change to take effect.
Cookies and similar technology: You can set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies from our website this could affect certain features or services of our Services.
7. How to complain
We hope that we can resolve any query or concern you raise about our use of your information. Please submit your query using this Data Subject Access Form. The Law also gives you right to lodge a complaint with the Office of the Data Protection Commissioner www.odpc.gg.
8. Changes to this privacy notice
This privacy notice was published on 28 May 2018 and last updated August 2020.
We may change this privacy notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.
9. How to contact us
If you wish to contact us please email the Data Protection Officer at either [email protected], or post to GTA University Centre, Suite D, St Peter Port House, Union Street, St Peter Port, Guernsey, GY1 2PT, or call on 01481 721555.