Certain terms and phrases used in this policy are defined in the Glossary at the end of this document.
1. Important information and who we are
[We do not knowingly collect data relating to minors (i.e. those under 18 years). While we are happy to supply information relating to our courses to minors we do not accept orders for courses and or course materials and similar / ancillary items / products from minors without parent/guardian consent.’
Full name: Shawna Baker Email address: email@example.com
Postal address: 1760 Solihull Parkway, Birmingham Business Park, Birmingham B37 7YD
The UK Regulator for data protection issues is the Information Commissioner. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), whose website address is www.ico.org.ukp. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your purchases made and/ or orders placed by you and/or on your behalf, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Make a purchase and / or place an order with us;
- request information or marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below as and when appropriate.
Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising networks such as Criteo and whether based inside or outside the UK; and
(c) search information providers such as Algolia and whether based inside or outside the UK.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as First Data, Etika and SagePage and whether based inside or outside the UK.
- Identity and Contact Data from data brokers or aggregators such as Business Data Prospects and whether based [inside or outside the UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Please see the table below as to the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/activity: To register you as a new customer
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
Purpose/activity: To process and deliver your order including:(a) Manage payments, fees and charges (b) Collect and recover money owed to us
Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity (b) Contact (c) Technical
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Purpose/activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you including
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experience
Type of data: (a) Technical (b) Usage
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/activity: To make suggestions and recommendations to you about goods or services that may be of interest to you including marketing and sales information / promotions and / or offers.
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising as follows;
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We never share your data with any third party. If that ever changes, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase made or an order placed with us by you, warranty registration, or service experience.
A Cookie is a small text file stored on your computer and used by your web browser. They can be used for many different purposes, and on this Website some of them are essential to deliver the functionality needed to run this Website and to enrol on a course.
Our Cooke Policy applies to websites operated directly by us.
We may collect information automatically when you visit the Website. Such information is stored in a Cookie.
When you browse our Website some cookies are required for the site to work correctly. Data is collected via these Cookies for audit purposes. This functionality may include remembering which course product you have added to the shopping basket, or which payment plan you have selected as your preferred option.
These Cookies monitor how visitors navigate around the Website and how they found it in the first place. We use these Cookies to enable us to monitor total (not individual) figures as to which type of content is most popular with users and also to identify problems with the Website which may need to be rectified or improved upon. This enables us to provide our users with a better experience of using our site.
Users can opt out of these Cookies by clicking on the following links:
Our courses are advertised on third party websites as well as on social networks. We work with third party media partners to achieve this.
Advertising Cookies store information about the user’s computer. They do not store personal information about the individual. They are likely, however to store information about which products have been browsed by your computer.
The following are the third party services we use with details of how to opt out / control the use of the relevant Cookies:
Changing Cookie Settings
As a final note, information collected by Cookies does not collect information which identifies you personally. It includes general information about your computer settings, your internet connection, IP address, browsing patterns (including timings) and location
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will Use Your Personal Data above:
- Internal Third Parties as set out above.
- External Third Parties as set out above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
At times we may share your personal data with entities outside UK. This will involve transferring your data outside the UK.
We have reviewed all our systems and the below are those that process data outside of the UK and their locations:
Service provider | Country where it processes data | Purpose/ description
Mail Chimp | USA | e-mail/marketing automation
First Data | USA | Payment provider
Response Tap | European Union | Reporting and insights
Ruler Analytics | European Economic Area (EEA) | Reporting and insights
Facebook (Ads) | USA | Advertising
Google Ads | Europe | Advertising
Google Data Studio | Europe | Reporting and insights
Zapier | USA | Digital automation
SAP Litmos | Worldwide | Learning management system
Rakuten | Worldwide | Affiliate platform
Trustpilot | Italy, The Netherlands | Review platform
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
All account information is password protected. Where appropriate we use industry standard Secure Socket Layer (SSL) encryption to protect data transmission. All of our website security is regularly reviewed by our security and abuse team.
We use SSL technology extensively on our all back-office systems which store and / or process customer account information.
We endeavour to make purchasing our products and services as safe as we reasonably can. Your browser will automatically default to secure mode before you enter any personal or payment details. This means that all of your details are encrypted to keep them secure. To check that you are shopping in a safe environment look for the locked padlock or a key icon in the bar at the bottom of your screen or for the relevant icon when the address bar goes green.
We only accept payments which are placed using SSL. We do not store debit or credit card details on our servers once initial payment has been made and processed. All such details are stored securely through Symantec which uses internationally recognised encryption systems. Encryption keys are then held on state-of-the-art tamper-proof systems. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Should you have further concerns about cyber security please contact our Customer Service Team at firstname.lastname@example.org.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
As a general guide, we retain enquiry information for a period of up to two years from the date of the last enquiry. After that time the information is securely archived. All archived information is kept for a minimum period of six years from the date of receipt.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum of six years after they cease being customers (this is usually once the individual has completed their course) for tax purposes.
In some circumstances you can ask us to delete your data: See Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For further information on this please see the relevant Section below under Glossary.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies which are associated with Open Study College Limited ( for example, but without limitation) holding companies, subsidiary companies and other companies within the same group of companies , companies acting as joint data controllers or processors and companies and entities which provide IT and system administration services
External Third Parties
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.