Notice
Privacy notice
This notice explains what personal data we collect, why we use it, who we share it with, how long we keep it, and your rights. It applies to apprentices and learners, prospective learners, employer and school contacts, job applicants and visitors to our website.
At a glance
- We're the data controller for your personal data, under UK GDPR and the Data Protection Act 2018.
- We only use your data where we have a lawful reason.
- We never sell your data, or share it for other organisations' marketing without your consent.
- You have rights, including to see and correct your data, and we respond within one month.
- Questions? Email data@traintogetherltd.co.uk or call 0116 235 8000.
Who we are
Train Together Limited, 3 Gilmour Close, Beaumont Leys, Leicester LE4 1EZ. Company number 07449097. ICO registration Z254055.
Our data protection contact is our interim Data Protection Officer, Charles Dall'Omo. Email data@traintogetherltd.co.uk, call 0116 235 8000, or write to the interim Data Protection Officer at the address above.
The personal data we collect
Depending on your relationship with us, we may collect:
- Identity and contact details: name, date of birth, address, email, phone number, gender, and, for learners under 18 or under 25 with learning difficulties or disabilities, a parent, carer or next of kin for emergencies.
- Education and training data: previous education and qualifications, initial assessment results, attendance, coursework and assessment results, progress reviews and progression.
- Employment data, for apprentices: employer, job role, working hours, start date and National Insurance number.
- Financial data: bank details, where needed for payments or refunds.
- Correspondence: records of contact by post, email or phone. Calls may be recorded for training and quality.
- Website data: standard internet log information and anonymised usage data.
Special category and criminal offence data. Where relevant and lawful, we may process information about your health, disabilities or support needs (for reasonable adjustments and safeguarding), ethnicity (for equality monitoring), and offences (for safeguarding, and where your training brings you into contact with children or adults at risk). We treat this with extra care, and use it only for the purpose it was collected for.
Where we get your data
Mostly from you, when you enquire, register, enrol or complete forms and surveys. We also receive data from your employer, from previous education providers and, where lawful and relevant to safeguarding or funding, from bodies such as local authorities, social services or government agencies.
Why we use your data
| Purpose | Lawful basis | For special category data |
|---|---|---|
| Delivering and administering your apprenticeship or training | Contract; legal obligation | Not usually required |
| Meeting funding, statutory and reporting requirements | Legal obligation; public task | Substantial public interest |
| Safeguarding and promoting learners' welfare | Legal obligation; legitimate interests | Substantial public interest (safeguarding) |
| Reasonable adjustments and learning support | Legal obligation; consent where appropriate | Explicit consent, or substantial public interest |
| Equality and diversity monitoring | Public task; legitimate interests | Substantial public interest (equality of opportunity) |
| Enquiries, feedback and quality assurance | Legitimate interests | Not usually required |
| Marketing about our programmes and services | Consent | Not applicable |
Where we rely on consent, for example for marketing, you can withdraw it at any time by contacting us or using the unsubscribe link in our emails.
Who we share it with
We only share your data where there's a lawful reason. Depending on the purpose, this may include:
- The government departments and agencies responsible for apprenticeship funding and oversight, including Skills England, for funding, monitoring and statutory reporting.
- End point assessment organisations, for your assessment.
- Regulators such as Ofsted and the Information Commissioner's Office.
- Others where the law requires it, such as HMRC, the police, social services, the courts and safeguarding partners.
- Trusted service providers who process data for us under a written contract, such as our IT, hosting and learning platform providers. They act only on our instructions.
We do not sell your personal data.
International transfers
Most of the data we process is held in the UK. Our forms provider (Jotform) uses UK data residency, and our cognitive assessment provider, Cognassist, is a UK company. Two providers are based in the United States: HubSpot, our customer relationship management system, and Thinkific, the learning platform for our Academy. Transfers to them are protected by the UK Extension to the EU-US Data Privacy Framework. Any other transfer outside the UK is protected by an adequacy decision or appropriate safeguards.
How long we keep it
- Apprentice and learner records: generally up to six years after your programme ends, in line with funding requirements.
- Financial records: six years, for accounting and tax.
- Marketing contacts: until you unsubscribe, after which we keep only what we need to respect your request.
When data is no longer needed, we dispose of it securely.
Your rights
You have the right to:
- Be informed about how we use your data
- See the data we hold about you (a subject access request)
- Have inaccurate data corrected
- Have your data erased, in certain circumstances
- Restrict how we use your data, in certain circumstances
- Object to processing based on legitimate interests, or to direct marketing
- Data portability, where it applies
These rights aren't absolute, and some depend on the lawful basis we rely on. We don't make automated decisions that have legal or similarly significant effects on you.
To use your rights, contact our Data Protection Officer at data@traintogetherltd.co.uk or 0116 235 8000. There's normally no charge. We'll respond within one month of receiving your request and anything we need to confirm your identity, or tell you if a complex request needs longer.
Cookies, security and young people
Cookies. Our website uses HubSpot cookies to keep it working and, if you agree, to understand how visitors use it. See our cookie notice.
Security. We protect your data with access controls, multi-factor authentication, encryption, secure systems, secure disposal and regular staff training. If a breach is likely to put your rights at risk, we'll tell you and the Information Commissioner's Office as the law requires.
Young people. Some of our learners are 16 or 17, and occasionally younger. We take particular care with their data, collect a parent or carer as an emergency contact where appropriate, and take account of their age and understanding.
Complaints and changes
If you're concerned about how we handle your data, please contact our Data Protection Officer first so we can put things right. You can also complain to the Information Commissioner's Office at any time: 0303 123 1113, or ico.org.uk.
We review this notice regularly and publish the current version here.
Related policies: Data protection · Cookie notice