Privacy & Cookies

Adlin Privacy Policy

Purpose

Adlin respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how Adlin collects and processes your personal data through:

a. your use of Adlin websites, including any data you may provide through Adlin websites when you make an enquiry or purchase a product or any course/programme and whether on behalf of yourself or as an employer client (“Services”)
b. your registration for, purchase of or use of any Adlin products and/or Services (including but not limited to courses or programmes or study materials
c. your use of any Adlin social media channel; and
d. your sending of personal data to Adlin by any other means.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you. It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.

1. Who we are

Data controller

Adlin Professional Limited is the data controller of your personal data when you use any Adlin website including any subdomains that may be made available by us from time to time; and all Adlin social media channels (“Website(s)”).

Contact details

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details:

Adlin Professional Limited
Data Privacy Team
International House
24 Holborn Viaduct, London
EC1A 2BN
Email: [email protected]

You have the right to make a complaint at any time to:

  • the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk)
  • the Data Protection Commissioner, the supervisory authority for data protection issues in Guernsey (www.dataci.gg); or
  • the Office of the Information Commissioner, the supervisory authority for data protection issues in Jersey (www.dataci.je).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO (or other relevant authority) so please contact us in the first instance.

2. Important information about this policy

Changes to the Privacy Policy and your duty to inform us of changes

On 25 May 2018 the data protection law in the UK and Channel Islands changed. This Privacy Policy sets out your rights under the new laws.
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. We may update this Privacy Policy from time to time. This version was last updated on 1 January 2021.

If you reject the terms of this Privacy Policy

If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website or any other means.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
 

3. Your personal data

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:

  • Telephone recordings (for monitoring and training purposes) where you call any of our course technical/support teams (although not all calls to Adlin are recorded), recordings (including video, audio and text) where any interactive teaching session is recorded; video recordings from recorded assignments/assessments.
  • Contact data includes billing address, delivery address, postal address, email address and telephone numbers.
  • Employment data (this is relevant where your place on a course or programme is sponsored by your employer/future employer) includes name of employer, job title, work contact details (email address, telephone number and postal address) and employment start and end dates.
  • Financial data includes bank account, billing information and payment card details.
  • Identity data includes first name, last name, usernames for Adlin sites or similar identifier (including any participant registration number assigned to you by Adlin, title, and date of birth.
  • Professional/Career experience data, such as professional qualifications, current employment status/role, employment history and other similar information which you share with us through, for example, your LinkedIn profile.
  • Marketing and communications data includes your preferences in receiving marketing from us and your communication preferences.
  • Profile data includes your usernames and passwords (for Adlin platforms), purchases or orders made by you, your interests, preferences, feedback, survey responses and enquiries submitted to Adlin.
  • Course participant data includes the course or programme you are studying with Adlin, your course in-take data, records of achievements on the course or programme (activity, assignment, assessment and test results), progress information, feedback from course tutors, emails sent by you to Adlin, emails received by you from our Adlin email address or messages posted/received on our course message boards, information relating to your use of course online tools and functionality, information relating to allegations of academic misconduct or other matters of discipline, information relating to any application for mitigating circumstances, any application for deferrals or interruption of studies and any complaints made by you or about you to Adlin.
  • 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.
  • Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Usage data includes information about your visit to a Website, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page and any phone number used to call our customer services numbers.
  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Special categories of personal data

The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data. In some circumstances we may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about any disabilities or learning needs – this information is collected so that any reasonable adjustments can be made to accommodate course participants with disabilities and also to ensure that any learning needs are supported. This information is voluntary.
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 enrol you onto a relevant course or programme or provide goods or services to you). In this case, we may have to withdraw your application or cancel/restrict a product or Service you have with us, but we will notify you if this is the case at the time.

4. How your personal data is collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Eligibility, Employment, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a. apply for a course or programme
b. submit an online query or request a callback
c. purchase goods or Services from us
d. speak or exchange electronic messages with one of our course support teams
e. speak or exchange electronic messages with one of our course technical teams
f. speak or exchange electronic messages with one of our course tutors
g. create an account on our Website
h. subscribe to a service or publication
i. subscribe, register, take part in or view any Adlin webinar
j. request marketing to be sent to you
k. enter a competition, promotion or complete a survey; or
l. give us feedback.

• Through your Studies. You may give us your Student Data throughout your time on a course or programme. This includes personal data you provide when you:
a. engage with our online learning lessons, materials or tools
b. submit content/materials for assessment/feedback
c. take tests or other forms of assessment
d. submit any applications relating to your studies (for example mitigating circumstances applications)
e. raise any issues or questions with your course tutor; or
f. contact one of our teams for technical or other support.

Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

• Third parties. We may receive personal data about you from various third parties as set out below:
 – Contact, Eligibility, Employment and Identify Data from your employer where your employer/future employer is sponsoring your place on an Adlin course or programme.
– Contact, Identity and Profile Data voluntarily submitted to us by you via links to your professional/social media accounts, for example LinkedIn.
– Contact, Identity, Marketing and Communications, Profile, Recruitment, Student, Technical and Usage Data from any third party portals which are used to provide you with Course Participant services, such as Riddle.
– Course Participant Data from any freelance tutor or external presenter engaged by Adlin who has delivered teaching to you as part of your course or programme.
– Technical Data from analytics providers such as Google, Sessioncam, Hotjar and Optimizely; advertising networks; and search information providers, and
– Contact, Financial and Transaction Data from providers of technical and payment services such as Stripe and PayPal.

5. 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 or regulatory obligation.
• Where we have your consent.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Where we are relying on your consent as a legal basis for processing your personal data, for example where we collect voluntary “special category” personal data (as set out in this Policy above) you may withdraw your consent to this processing 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 legal basis 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 in the table below.

Please be aware that, if you are a course participant with Adlin, in the majority of cases we will have a contract in place with you in respect of the course or programme you are undertaking. Therefore, our lawful basis for processing your personal data will be to perform our contract with you.

However, in some instances we will have a contract in place with your employer or prospective employer. For example, some businesses will ask Adlin to deliver a bespoke course or programme to a group of its employees. In these cases, Adlin has a contract in place with your employer and not you as an individual. In these scenarios, Adlin will process your personal data as necessary for our legitimate interests, i.e. the delivering of services to your employer under a contract in place between Adlin and your employer. 

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
Course participants or prospective course participants
To respond to enquiries or requests for informationa. Identity
b. Contact
• Performance of a contract with you; or
• Consent
To assess your eligibility to be enrolled onto a particular course or programme with Adlina. Contact
b. Eligibility
c. Employment* (if sponsored by an employer)
d. Identity
e. Audio/Visual
• Performance of a contract with you; or
• *Necessary for our legitimate interests (to deliver services to your employer under a contract in place between Adlin and your employer) 
To register/enrol you as a course participant with Adlin

 
a. Contact
b. Eligibility
c. Employment* (if sponsored by an employer)
c. Identity
• Performance of a contract with you; or
• *Necessary for  our legitimate interests (to deliver services to your employer under a contract in place between Adlin and your employer)
To deliver the course or programme to you (including the delivery of events)
 
a. Audio/Visual
b. Contact
c. Identity
d. Profile
e. Student
• Performance of a contract with you; or
• *Necessary for our legitimate interests (to deliver services to your employer under a contract in place between Adlin and your employer)
To:
• Manage payments, fees and charges
• Collect and recover money owed to us
• Keep records for audit/accounting purposes
• Defend any legal claims brought against Adlin
a. Identity
b. Contact
c. Financial
d. Transaction
e. Student
• Performance of a contract with you
• Necessary for our legitimate interests (to recover debts due to us or defend legal claims)
• Necessary to comply with a legal obligation
Customers (or prospective customers) of learning materials
To register you as a new customer when purchasing learning materials from Adlina. Identity
b. Contact
• Performance of a contract with you
To process and deliver your order including:
• Manage payments, fees and charges
• Collect and recover money owed to us
• Keep records for audit/accounting purposes
• Defend any legal claims brought against Adlin
a. Identity
b. Contact
c. Financial
d. Transaction
e. Marketing and
Communications
• Performance of a contract with you
• Necessary for our legitimate interests (to recover debts due to us or defend legal claims)
• Necessary to comply with a legal obligation
Clients of Adlin (including employer clients)
To register you as a client of Adlina. Identity
b. Contact
• Performance of a contract with you
To process and deliver the service:
• Manage payments, fees and charges
• Collect and recover money owed to us
• Keep records for audit/accounting purposes
• Defend any legal claims brought against Adlin
a. Identity
b. Contact
c. Financial
d. Transaction
e. Marketing and Communications
• Performance of a contract with you
• Necessary for our legitimate interests (to recover debts due to us or defend legal claims)
• Necessary to comply with a legal obligation
Suppliers to Adlin
To register you as a supplier of Adlina. Identity
b. Contact
• Performance of a contract with you
To process and receive goods/services:
• Manage payments, fees and charges
• Keep records for audit/accounting purposes
• Defend any legal claims brought against Adlin
a. Identity
b. Contact
c. Financial
d. Transaction
e. Marketing and
Communication
• Performance of a contract with you
• Necessary for our legitimate interests (to recover debts due to us or defend legal claims)
• Necessary to comply with a legal obligation
For All
To manage our relationship with you which will include:
• Notifying you about changes to our terms or privacy policy
• Asking you to provide feedback or take a survey
a. Identity
b. Contact
c. Profile
d. Marketing and Communications
• Performance of a contract with you
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey

 
a. Identity
b. Contact
c. Profile
d. Usage
e. Marketing and
Communications
• Performance of a contract with you
• Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 
a. Identity
b. Contact
c. Technical
• 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)
• Necessary to comply with a legal obligation
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
   
a. Identity
b. Contact
c. Profile
d. Usage
e. Marketing and
Communications
f. Technical
• 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)
To use data analytics to improve our Website, products/services, marketing, participant/ customer/client relationships and experiences

 
a. Technical
b. Usage
• 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)
To make suggestions and recommendations to you about goods, services or events that may be of interest to you

 
a. Identity
b. Contact
c. Technical
d. Usage
e. Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

Purpose/Activity Type of dataLawful basis for processing
including basis of legitimate interest
Course participants or prospective course participants
To provide reasonable adjustments to participants with disabilities and to provide learning support to participants who have learning needsData relating to disabilities and/or learning needs• Performance of a contract with you
• Complying with our legal obligations (under the Equality Act 2010)
• Your explicit consent (this information is voluntary)

Less commonly, we may also process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent.

Consent

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations.

In limited circumstances (as set out above), we ask you for your written consent to allow us to process certain particularly sensitive data. When we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

You should be aware that it is not a condition of your contract/right to study with us that you agree to any request for consent from us. However, we may not be able to provide you with certain services (such as learning support) if you do not agree to provide such data to us.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
• Where we have notified you of the decision and given you 21 days to request a reconsideration
• Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do use automated technologies and decision-making when deciding what marketing messages you receive. However, we do not envisage that any other decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Your marketing opt-in preferences will be collected when you register, book a course/programme or make a purchase. You can opt out of receiving marketing at any time by replying to the sender of the marketing communication with the word “UNSUBSCRIBE”.

If you do not agree to receive marketing from us, but change your mind at a later date, you can contact us and update your marketing preferences.

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 or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Adlin group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

6. Disclosure of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above.
• Internal third parties as set out in the Glossary.
• External third parties as set out in the Glossary.
• Specific third parties listed in section 4 above (under the ‘Third Parties’ heading).
• Specific third parties listed in sections 6 and 7 below.
• Your parent or guardian if you are under the age of 18 (or if you specifically request us to liaise with your parent or guardian on your behalf).
• External venues where some element of a course or programme (or event) is delivered (Adlin may share Identity Data with the venue for registration and health and safety purposes).
• Future employers or education providers where you specifically request that we provide confirmation of Identity or Participant Data to those parties for reference purposes.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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. Compliance with the Bribery Act and relevant legislation

In this Privacy Policy, we have explained that your personal data may be used for the purpose of ensuring compliance with legal obligations and that it may be disclosed to Adlin’s group companies’ service providers or governmental departments. This includes for the purpose of enabling Adlin to comply with its obligations under the UK Bribery Act 2010 (the “Bribery Act”), the Criminal Finances Act 2017, The Money Laundering, Terrorist Financing and Transfer of Funds(Information on the Payer) Regulations 2017, Proceeds of Crime Act 2002 and any other local laws or regulations relating to similar purposes which relate to fraudulent, illegal or unethical behaviour (the “Conduct Legislation”).

It is possible that an Adlin staff member may report matters of concern to Adlin and that your personal data may be used by Adlin for the purpose of investigating any such report and taking remedial action thereafter. For example, if an Adlin employee suspects that another employee is misusing company records for his/her own purposes or is committing fraud involving your personal data, they may report this.

Should this happen, your personal data will only be used for the purpose of ensuring compliance by Adlin’s group companies with the relevant laws and regulations. Wherever reasonably possible, your personal data will be anonymised prior to use for the purpose of investigations and remedial action so that it does not relate to you. However, in some specific circumstances this may not be possible as it may prohibit a full investigation and prevent compliance with a relevant regulation or Conduct Legislation. Any transfers to Adlin’s group companies and their service provider(s) which manage this process will be carried out in accordance with the law.

A limited number of employees from Adlin’s group companies will only have access to your personal data which is disclosed in this way where and to the extent that this is necessary for the purposes of carrying out their roles and for the purpose of compliance. In any event, their access will be limited, secure, controlled and justified as Adlin considers is fair and necessary in the circumstances. These employees will be subject to appropriate confidentiality obligations.

We encourage our employees to use this reporting process in good faith and only for serious or substantial issues which cannot properly be reported via other means.

Provided reports are made to Adlin in good faith, we try to protect the confidentiality of your identity as far as is reasonably possible. However, we cannot guarantee this (especially in subsequent court or tribunal proceedings) and we are required to inform the subject of the reports about the allegation(s). Those subjects have the right to request their own personal data, as do you, as set out under Your Legal Rights. 

7. Online Learning Environment

Adlin provides an Online Learning Environment (“OLE”) to course participants and to selected sponsoring employers. The OLE is also accessed by Adlin staff in order to deliver courses and programmes to participants.

Within the OLE the following data sharing is in operation:

  • Your name, last log-in date and course or programme will be viewable by Adlin staff
  • Your participation in and use of online sessions, materials and tools, including any text, audio or video content you submit or record will be viewable by Adlin staff
  • Third Parties chosen by Adlin may review your interaction with the OLE to help Adlin continuously improve the service
  • Test, activity, assignment or assessment feedback and results in the OLE may also be combined to derive benchmarks of performance to allow participants to assess their performance in their chosen programme. These will only be presented in aggregate and individual results will not be disclosed
  • Any test, activity, assignment or assessment uploaded or completed through the OLE will be shared with the appropriate Adlin staff for the purposes of assessment and feedback. 
  • OLE data relevant to assessing your progress within the course or programme may also be shared with your sponsoring employer.

8. International transfers

At present, our Websites and/or any products and/or Services do not require the transfer, storage or processing of your personal data outside of the European Economic Area (‘EEA’)

Should this change in the future, we will update this section of the Privacy Policy.

9. 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.

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.

As set out in section 8 above, your personal data may be held on the IT system of Adlin (e.g. for the purpose of providing training or educational services to you) and/or on the IT system of another third party company (within or outside of Adlin) which is providing IT hosting or other data processing services, in accordance with Adlin’s arrangement in place with that company.

All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
 

10. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

As a learning provider Adlin will hold details of your transcript (i.e. your name, years of study, course or programme name, sponsoring employer, assessment and/or test marks and final grade or award) indefinitely.

In some circumstances we may 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.
 

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, for example:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

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 may 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 may 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. 
 

12. Glossary

Lawful basis

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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.


Third parties

Internal Third Parties
Any future companies formed/brought into the Adlin Group. (Currently, the Adlin Group comprises only Adlin Professional Limited)

External third parties

  • Your employer, acting as an independent controller, where your employer/prospective employer is sponsoring your place on a course or programme (or where your employer/prospective employer has arranged for a course or programme to be delivered to a group of its employees/prospective employees). We will share information relating to your attendance, performance (including test/assessment results) and general behaviour on the course/programme.
  • Service providers acting as processors based in the EEA who provide IT and system administration services.
  • Service providers which act as processors in respect of our telephone call recording operations.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, the UK Home Office, regulators and other authorities acting as independent controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • The police or governmental body, where the police/ governmental body make a request for personal information to Adlin or as and when we consider necessary for the purpose of crime/fraud prevention.
  • The ambulance service if there is any immediate concern regarding your physical health or mental wellbeing.
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. Please be aware that this right does not apply to test/assignment marks and performance.

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. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks. 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. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.

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 services to you. We will advise you if this is the case at the time you withdraw your consent.

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