We are Mindboost Learning Limited, a company incorporated in England and Wales. Our company number is 10302356 and our registered office is at 22 John Street, Hull, East Yorkshire, HU2 8DH (“Mindboost” / ‘Mindboost Learning” / “we”/ “our” / “us”).
We are committed to ensuring that your privacy is protected and we strictly adhere to the provisions of the UK GDPR (UK General Data Protection Regulation), together with the Data Protection Act 2018, any national implementing laws, regulations, and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (Data Protection Legislation).
In order for Mindboost to provide, our products and services we need to process a certain amount of data, some of which is personally identifiable.
We process data on the following categories of individuals:
- Learners/ System Users
- Website visitors & online customers
- Newsletter/ marketing subscribers
- Suppliers, sub-contractors & freelancers
- Staff (and 3rd party personal data they provide)
- Prospective staff (job applicants)
In order to access the Learning Management System (LMS), and complete training and other associated activities, users require an LMS account. Having an account means Mindboost Learning is storing the personal data you provide, and we further process this to determine training outcomes and retain certification records as well as analyse content and system usage, improve our products and services and respond to support queries and evaluation comments. Where a learner has accessed or is allocated a Mindboost Learning course, directly from Mindboost Learning, Mindboost Learning is the data controller.
If your login details or training has been provided by a 3rd party (e.g. your employer, another training organisation or a Mindboost Learning reseller) then they will be joint data controller, along with Mindboost Learning where applicable and also have access to and will be processing your personal data. Should you require any further information you should contact them directly. If you are unsure who to contact Mindboost Learning may be able to assist, please email firstname.lastname@example.org. Where a 3rd party has provided system access, and no Mindboost Learning content is allocated to the user, then Mindboost Learning is a data processer, and the relevant 3rd party sole data controller.
Mindboost Learning retains learning records ad infinitum, under its commitment to lifelong learning, to enable us to provide factual information on what a learner has studied and achieved, i.e. name, courses studies, CPD gained, test results etc. This is in line with JISC best practice and Guidance on Managing Student Records.
Our servers are provided by Google Cloud and Microsoft Azure. We also work with a number of organisations who assist us in testing our LMS and related infrastructure – City & Guilds Kineo.
Website visitors and Online customers
When you place an order with us on our website, we will ask you to provide certain personal information, for example:
- your name; and
- your email address.
Please note that we require this information to be able to process your order and fulfil our contractual obligations (our condition for processing under UK GDPR). We may be unable to fulfil the contract without your personal data.
If you purchase services, our third party payment provider (Stripe – you can view their privacy information here) may require additional personal information in order to process such payment (e.g. your home address). Please note that this information is not collected or stored by us.
We will share your personal details with a third party in order to enable you to leave a review of our products and services to help us continually improve.
Your personal information will then be used by us to provide you with the services you ordered and to communicate with you regarding the provision of those services. We also monitor website usage and provide statistics to third parties for the purposes of improving and developing our website and the services we provide via our website. Please note that any such statistics and/or information provided to third parties will be made on a confidential basis and will not include information that can be used to identify any individual.
Ahoyhoy assist Mindboost Learning with the development and maintenance of our website.
A cookie is a small piece of information that is automatically created by our website on your computer. Please note that cookies are harmless to your computer. Cookies are a useful way of remembering the choices you have previously made while visiting our website.
Please note that if you set your computer to not accept cookies, there may be certain features/areas on our website that you may not be able to use. It may be necessary to have cookies enabled in order to purchase or access online courses and materials.
When you fill out a webform to sign up to a newsletter, download a resource, such as an infographic, or enquire about a product, we may ask you to provide certain personal information, including your:
- email address;
- job title
- organisation you work for
- telephone number.
By completing the form and ticking the relevant boxes you are providing your consent for Mindboost Learning to process your personal data, and this is the legal basis we are relying on to do so.
We will use the information that you give us to send you relevant emails containing Mindboost Learning news & marketing communications. Your information will be stored by a third-party data processor; MailChimp, you can read their privacy information: here.
In addition, if you have enquired about a product or service we will use the information you have given to update our customer relationship management system so one of our customer support team can contact you. This information will also be stored by another third-party data processor, Microsoft, for more information you can visit Microsoft’s Trust Center: here.
Some automation and profiling may be used to send emails or a series of emails based on your indicated preferences and your interactions with the emails we send to you. For example, if you have enquired about a particular product we may send you a series of emails outlining the features or benefits of that particular product.
We regularly review your interactions with the emails we send you and remove any subscribers who have shown an extended period of inactivity. You can withdraw your consent and unsubscribe at any time by clicking the link at the bottom our email communications or by emailing this address.
If you continue to interact with our emails or website, we will retain your data indefinitely so we can continue to send you emails.
We will not sell or pass your information to third parties other than those set out above.
Suppliers, sub-contractors, and freelancers
Personal data provided by suppliers is only used for purposes related to the supply of goods or services for which we have contracted.
Information regarding the processing of employee data is available internally via the HR Team. Where employees provide 3rd party personal details to Mindboost Learning, for the purposes of being an employment reference, emergency contact, or beneficiary of employment-related benefits, these details are used for that purpose only and processed under legitimate interests.
Should you apply for an advertised job vacancy, or submit a speculative application, either directly or through a recruitment agency or other 3rd party, we will process your data solely for this purpose. We hold all applications on file for a period of 6 months and may contact applicants regarding other similar opportunities potentially of interest that become available within this time.
Subprocessors and other 3rd parties
- Microsoft – provide us with a number of software services
- Kinsta – provide website hosting & support
- Ahoyhoy Digital – assist with website development and maintenance
- City & Guilds Kineo – provide LMS hosting & support
- Course Merchant – provide ecommerce hosting & support
- Stripe – our online payments provider
- Mailchimp – our email marketing provider
- Badgr – provide digital badges and credentialing hosting & support
- Trustpilot – enables us to receive customers’ reviews in order to improve our products and services
How do we safeguard your data?
Protecting your security and privacy is extremely important to us and we make every effort to secure your information and maintain your confidentiality in accordance all relevant Data Protection Legislation. Our systems are protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.
Please note that we may need to disclose your personal information where we:
- are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
- need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.
The UK GDPR provides you with the following rights:
The right of access
You can ask us to confirm that we process your personal data and provide access to and copies of the information we hold about you by contacting us at email@example.com. We will process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request unless there are extenuating circumstances. If we need more information to comply with your request, we’ll let you know.
The right to rectification
If you believe the personal data we hold about you is inaccurate or incomplete, or any of the information you provide to us changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us at firstname.lastname@example.org.
We will comply with your request within one month of receiving it unless we don’t feel it’s appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
The right to erasure
In some circumstances, you have the right to ask us to delete the personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with UK GDPR);
- where the personal data has to be deleted to comply with a legal obligation; and
- where the personal data we process relates to the offer of online services to a child.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
To request that your information is deleted, please contact us at email@example.com.
The right to restrict/object to processing
In some circumstances, you are entitled to ask us to suppress the processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
- if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise, or defend a legal claim.
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds that override your interests, rights, and freedoms or the processing is for the establishment, exercise, or defence of legal claims.
If you wish to restrict or object to the processing of your information, please contact us at firstname.lastname@example.org.
The right to data portability
You have the right to ask us to provide your personal data in a structured, commonly used, and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:
- to personal data you provide to us;
- where processing is based on your consent or for the performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
Rights in relation to automated decision making and profiling
Automated decision-making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on the information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).
We carry out automated decision-making using your personal data as detailed under the Newsletter / Marketing Subscribers heading above.
For further information on these rights, you can contact the ICO via one of the options on their website https://ico.org.uk/global/contact-us/.
For whatever reason, should you wish to lodge a complaint with the Information Commissioner’s Office, as is your right, you can do this by contacting the ICO directly via one of the options on their website https://ico.org.uk/global/contact-us/.