Privacy Notice & Website T & C's


GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction

Bellatrix Health and Safety Limited ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

  1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Learners - shall mean Learners registered at the Approved Centre i.e. Bellatrix First Aid Training, for the purposes of undertaking the Awarding Organisation’s qualifications.

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Qualification Regulators: refers to those organisations responsible for regulating qualifications in England, Wales and Northern Ireland i.e. Ofqual, Qualifications Wales and the Council for the Curriculum, Examinations and Assessment (CCEA).

Subject Access Request: has the same meaning as “Right of access to personal data” and refers to formal Access requests received from any individual from whom the Parties have appropriate legal basis to capture, process and retain their data.

  1. Who are we?

Bellatrix Health and Safety Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:

(Bellatrix First Aid Training is a trading name of):

 

Bellatrix Health and Safety Limited

18 The Broadway

Stoneleigh

Epsom

Surrey.  KT17 2HU

Email: info@bellatrixfirstaidtraining.com

For all data matters contact our Data Protection Officer at info@bellatrixfirstaidtraining.com

  1. The purpose(s) of processing your personal data

We need to collect certain personal information to be able to book you onto our courses and offer you the best possible service.  You provide some of this data directly, for instance when you contact us via email or our ‘Contact Us’ form on our website or submit a Booking Form. 

We only use your data for the purposes for which it was collected and, where relevant, to meet our legal obligations.  We use your personal data for the following purposes:

 

Performance of the service to our customers: We process personal data to enable us to provide education and training to our customers and clients.

  • You may give us the information about you by filing in forms on our website (www.bellatrixfirstaidtraining.com) or by corresponding with us by telephone, email, post, face-to-face or otherwise.  This includes information you provide when you search for a product or submit a ‘Contact Us’ form. We may also hold details of when we contact you or you contact us.

 

  • For the registration of Learners, who are undertaking qualifications offered by Bellatrix First Aid Training i.e. Name (including First Name, Middle Name(s) and Surname); Date of Birth; Gender; Telephone Number; Personal Email Address; Learner Address; Learner Signature; Employer; Unique Learner Number (ULN); Centre Name; Centre Number; Course Location (Venue); Course Start Date; Course Finish Date; Course Time; Course Duration; Answer Paper Number(s); Qualification Title; Qualification Number; Learner Placement Data, Data Pertaining to Learner Performance, including Assessment Paperwork, Assessment Results, Learner Workbooks, Achievement Date; Certification Date; Learner Certificate; Records of Achievement.

 

  • For the assessment of Learners, including the assessment of evidence provided when claiming Recognition of Prior Learning (RPL), who are undertaking qualifications offered by Bellatrix First Aid Training.

 

  • For the award of qualifications to, and the certification of, Learners by the Awarding Organisation.

 

  • To ensure Learner certificates received from the Awarding Organisation are securely distributed to Learners.

 

  • Where you consent to us using your personal data.

 

  • You ask us to do something before entering into a contract i.e. to provide you with a quote.

 

  • To carry out our obligations arising from any contracts entered into between you and us for services. 

 

  • We will also collect your information where you only partially complete or abandon any information inputted into our website, contact form or course booking form. We may use this information to contact you to remind you to complete any outstanding information or for marketing purposes, with your consent. 

 

  • To carry out our obligations arising from any contracts entered into between you and us by sharing with selected third parties only to the extent necessary to administer your course(s) i.e. our Awarding Organisation.

 

  • If you intend to give us personal data about someone else (perhaps a friend booking onto a course with you), it is your responsibility to check before you give it to us that you have their consent to do so. You should also ask them to read the privacy item in the booking Terms and Conditions or direct them towards reading this Privacy Policy.

 

Supporting, Communicating and Marketing our services to our customers: To provide you with information on products and services that you request from us.

 

  • To provide you, with your consent, with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.

 

  • To notify you about changes to our service.

 

  • Note that our marketing communications will continue to comply with the Privacy and Electronic Communication Regulations 2003 (PECR).  You have the right at any time to stop us from contacting you for marketing purposes and can unsubscribe from any email marketing using the reply ‘Stop’.

 

Improving our services: We sometimes use your personal information to improve our products and services. Clicking behaviour and search results on our website can for instance help us to prioritise or identify new services.

 

 

Disputes and Complaints: We use Personal Data to manage and deal with appeals from Learners against decisions made by Bellatrix First Aid Training. 

 

  • Where processing is necessary for the establishment, exercise or defence of legal claims or other legal obligation.

 

  • We may use your personal information to record and deal with a complaint, record a request not to receive further marketing information and for other essential internal record keeping purposes.

 

  • We may also use personal information in the context of dispute settlements, to enforce our agreement with you, to enforce our rights towards third parties or defend ourselves against any third party claims or allegations.

 

Legal obligations: We may process your information in relation to a legal obligation. This includes cases where we must comply with requests from competent authorities, qualification regulators and administrative obligations and in cases involving legal disputes.

 

  • In order to respond to all Subject Access requests received directly from individuals for whom personal data is shared between the Awarding Organisation and Bellatrix First Aid Training.

 

  • Sensitive information will only be collected where necessary for the purpose of legal compliance i.e. equal opportunities. We record and transfer (i.e. to our Awarding Organisation) Personal Data obtained when managing and recording Conflicts of Interest, Reasonable Adjustments and Special Considerations.  For example, we may need to collect pre-existing injuries or health information from you when you register for a course in order for us to make reasonable adjustments.  Clear notices will be provided at the time we collect this information, stating what information is needed, and why.

 

General business management: For us to run our business, we also use your personal information for our general business processes. This may include some financial or payment details if you have made a purchase.  It also includes the planning, undertaking and management of quality assurance activity, malpractice or maladministration investigations, processing your information for recording and archiving, insurance and other administration related purposes.  

 

 

4. The categories of personal data concerned

 

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

 

  • Personal data which may include your Name (including First Name, Middle Name(s) and Surname); Date of Birth; Gender; Telephone Number; Personal Email Address; Learner Address; Learner Signature; Employer; Unique Learner Number (ULN); Centre Name; Centre Number; Course Location (Venue); Course Start Date; Course Finish Date; Course Time; Course Duration; Answer Paper Number(s); Qualification Title; Qualification Number; Learner Placement Data, Data Pertaining to Learner Performance, including Assessment Paperwork, Assessment Results, Unique Reference Number(s)

 

  • Special categories of data necessary for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment between persons.   We record and transfer to our Awarding Organisation, Personal Data obtained when managing and recording Conflicts of Interest, Reasonable Adjustments and Special Considerations.  For example, we may need to collect pre-existing injuries or health information from you when you register for a course in order for us to make reasonable adjustments.

 

  • We collect certain data through our website i.e. cookies and similar technologies.  Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. We register your interaction with our services in order to improve our website, content and services.  You can manage your cookie preferences through your browser settings.

 

5.What is our legal basis for processing your personal data?

We only collect and process your personal data when there is a lawful basis to do so. The lawful basis we rely on in this respect includes:

  1. Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

☐ Consent of the data subject;

Where you gave us explicit consent to process the data concerned i.e. to enable us to communicate with you about new courses or services or where you contact us by email or our ‘Contact Us’ form.

 

If you intend to give us personal data about someone else (perhaps a friend booking onto a course with you), it is your responsibility to check before you give it to us that you have their consent to do so.

 

If you're aged 16 or under, you must get your parent/guardian’s permission before you provide any personal information to us.

 

 

 

 

If you have given your consent to the processing, you have the right to withdraw your consent at any time, by notifying us by email or post.  We will discontinue the processing of your information upon receipt of your withdrawal.

 

☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract

For the registration of Learners who are undertaking qualifications offered by Bellatrix First Aid Training.

 

For the assessment of Learners, including the assessment of evidence provided when claiming Recognition of Prior Learning (RPL), who are undertaking qualifications offered by Bellatrix First Aid Training.

 

For the award of qualifications to, and the certification of, Learners by the Awarding Organisation.

 

To ensure Learner certificates received from the Awarding Organisation are securely distributed to Learners

 

To manage and deal with complaints and appeals from Learners against decisions made by Bellatrix First Aid Training. 

 

To carry out our obligations arising from any contracts entered into between you and us for services. 

 

To carry out our obligations arising from any contracts entered into between you and us by sharing with selected third parties only to the extent necessary to administer your course(s) i.e. our Awarding Organisation.

 

We will also collect your information where you only partially complete or abandon any information inputted into our website, contact form or course booking form.

 

☐ Processing necessary for compliance with a legal obligation

Where the processing is necessary to comply with a legal obligation, i.e. the legal requirement to keep administrative records for a certain period of time, or the legal obligation to share certain data with qualification regulators or for criminal investigation purposes

 

In order to respond to all Subject Access requests received directly from individuals for whom personal data is shared between the Awarding Organisation and Bellatrix First Aid Training.

 

☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject

A legitimate commercial interest to process your personal data to be able to run our business and for the purposes of certain forms of direct marketing and profiling.

 

If there is a legitimate interest from a business or security perspective, i.e. to prevent fraud or abuse of our Services, or for the purpose of network and information security of our IT systems;

 

  1. Special categories of personal data (article 9 of GDPR)

Our lawful basis for processing your special categories of data:

☐ Explicit consent of the data subject

Where you gave us explicit consent to process the data concerned i.e. you told us about a particular health issue that may impact on your ability to complete a course. 

 

The processing of Sensitive Personal Data is necessary for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment between persons—

(i) holding different beliefs, or (ii) of different states of physical or mental health or different physical or mental conditions, with a view to enabling such equality to be promoted or maintained, providing:

- the data use does not support measures or decisions with respect to any particular data subject otherwise than with the explicit consent of that data subject; and

- does not cause, nor is likely to cause, substantial damage or substantial distress to the data subject or any other person.

 

If you're aged 16 or under, you must get your parent/guardian’s permission before you provide any personal information to us.

 

☐ Processing necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity

 

Special categories of data necessary for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment between persons.  

 

Personal Data and Sensitive Personal Data may be shared between the Parties relating to physical and mental health status.

 

  1. Sharing your personal data

Your personal data will be treated as strictly confidential and will be shared only to the extent necessary to operate our business, to provide you with our services, to provide customer service and to communicate with you in connection with our services.

 

We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.

 

We will only share your data for the following purposes:

  • Third party suppliers: We may need to share your information with our Awarding Organisation, Qualsafe Awards, our Associate Trainers and our Web Hosting Provider who help us to deliver our services.  These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.
  • Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime.

 

We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.

  1. How long do we keep your personal data?

In respect of personal information, we will retain it for no longer than necessary for the purposes for which it was collected, or as long as is required by law, taking into account guidance issued by the Information Commissioner’s Office.

 

If you have made an enquiry or requested a quotation but do not take it any further, we will retain a record of your personal information for a period of 36 months.

 

If you decide that you no longer wish to receive communications from us, we may need to retain a minimal amount of personal data so we can keep a record you have asked us not to contact you.

 

We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction).

 

Data may be retained longer in cases where it is used in relation to a legal claim or is used in relation to a valid legal process.

  1. Providing us with your personal data

We require your personal data as it is a requirement necessary to enter into a contract.  Failure to do so will have the following consequences:

  • You will be unable to book onto any of our courses. 
  • If you withdraw your consent for us using your personal information for the purposes set out in this privacy policy, we may not be able to provide you with access to all or parts of our services.
  1. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for the processing the data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means;
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, where applicable i.e. where processing is based on legitimate interests or direct marketing

 

If you wish to exercise any of these rights please contact our Data Protection Officer in writing. You have the right to be provided with a copy of the information we hold free of charge. However, we reserve the right to charge a reasonable fee to comply with requests for further information, based on the administrative cost of providing you with the information.

 

If you wish to exercise these rights, please send your letter along with copies of two separate identification documents which provide photo identification and confirm your address, such as a passport, driving licence, or utility bill. Please also provide any additional information that is relevant to the nature of your contact with us, as this will help us to locate your records.

 

We will respond within 30 days, on receipt of your written request and copies of your identification documents.

 

As we are a Limited company and not a ‘public authority’ as defined under the Freedom of Information Act, we will not respond to requests for information made under this act.

 

  1. Transfer of Data Abroad

Your personal data is processed by our staff in the United Kingdom.  We do not transfer personal data outside the EEA. 

  1. Automated Decision Making

We do not make automated decisions i.e. those that are made with no human involvement in the decision-making process that have a legal or similarly significant effect on individuals.

  1. Storing your personal data

We use technical and corporate organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.

 

Please be aware that there are always inherent risks in sending information such as a booking form, by email and or by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.

  1. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

 

  1. Changes to our privacy policy

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. Please check back frequently to see any updates or changes to our privacy policy.

  1. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer at info@bellatrixfirstaidtraining.com.

 

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

 

 


Website Terms and Conditions

 

 

This web site is provided by Bellatrix Health and Safety Limited. Your use of this site is subject to the following terms and conditions which are deemed to be accepted by your use of the web site. If you are not prepared to accept these terms and conditions, you should not use this web site nor access any areas of the site.

 

You may access this web site and use it from anywhere in the world. However, these terms and conditions shall apply regardless of how and from where in the world you access this web site.

 


Rights

 

The software that runs the site is owned and managed by Absowebly Limited. Other than that permitted by applicable laws, you must not copy, modify, alter, download, distribute or de-compile that software without the consent of Absowebly Ltd.

 

By accessing this web site, you agree that you will access its contents solely for your own personal, professional but non-commercial use. The copyright and all other intellectual property rights on this site is owned by Bellatrix Health and Safety Limited and material may not be copied, reproduced, republished, downloaded, stored, posted, broadcast or transmitted in any way except for your own personal use. Where you download, store or print off any of the contents of this site, you must ensure that the Bellatrix copyright notice appears on such content. Any other use requires prior written permission from Bellatrix Health and Safety Limited.

 

Bellatrix reserves the right, at its discretion, to withdraw, suspend, alter, add, delete or modify the web site or certain features, articles or parts thereof with or without notice to you, where Bellatrix have reason to do so. There may be times when the web site, parts of the web site or features become unavailable either scheduled or unscheduled. You agree that Bellatrix will not be liable to you or any third party for such an occurrence.

 

Bellatrix attempt to provide accurate information on this web site. However, the web site is provided on an ‘as is’ and ‘as available’ basis without any warranty being given in relation to the web site included but not limited to implied warranties of non-infringement, compatibility, security, accuracy, fitness for purpose, that any information is up to date or correct or any implied warranty arising from the course of dealing or usage or trade. Any documents or guides have been prepared to provide general guidance only. These guides do not constitute legal advice and reliance ought not to be placed upon them. No liability can be accepted by the author/publisher for its content. The interpretation of the law is ultimately a matter for the courts and users of this web site should take their own advice where appropriate.

 

Bellatrix Health and Safety Limited shall not be responsible or liable to you for any loss of materials uploaded or transmitted through this web site. We shall not be liable for any special, indirect or consequential damages including loss of business, profits, anticipated savings, opportunity, reputation or goodwill, however caused.

 

Bellatrix Health and Safety Limited reserve the right to vary or amend these terms and conditions from time to time without prior notice. Any changes take effect at the time of posting them to the web site.

 

You warrant that you will only use this web site in accordance with these terms and conditions and only for a lawful purpose and in a lawful manner.

 


Linking

 

You may be able to obtain access to other third party web sites from the links page on this web site. The content of such web sites to which you may navigate, by means of hypertext links, from Bellatrix web site is beyond our control. You use the links entirely at your own risk. Bellatrix Health and Safety Limited do not accept responsibility for any damage or loss you may suffer arising out of accessing those sites including but not limited to, damage or loss arising from your use of documents or other information found on those web sites.

 

Any links to third party web sites are for your convenience and the inclusion of a link on this web site does not imply any endorsement, guarantee, warranty or representation by us of the quality or accuracy of the information, products or services provided to you on those third party web sites.

 


Force Majeure

 

Bellatrix Health and Safety Limited shall have no liability to you if it is prevented from, or delayed in performing, its obligations or from carrying on its business by acts, events, omissions or accidents beyond its reasonable control, including (without limitation) strikes, lock-outs or other industrial disputes (whether involving the workforce of the Supplier or any other party), failure of a utility service or transport network, act of God, war, riot, civil commotion, malicious damage, compliance with any law or governmental order, rule, regulation or direction, accident, breakdown of plant or machinery, fire, flood, storm or default of suppliers or subcontractors.

 

Nothing in these terms and conditions shall exclude or limit liability for death or personal injury resulting from our negligence or that of an employee or agent.

 


Governing law and jurisdiction

 

This web site and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims), shall be governed by and construed in accordance with, the law of England and Wales.

 

The parties irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim that arises out of, or in connection with, this web site or its subject matter or formation (including non-contractual disputes or claims).