Privacy Policy

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Aspiration Training Ltd is committed to protecting and respecting your privacy. This Privacy Policy outlines how we collect, use, and manage your personal data, your rights under applicable data protection laws, and how you can exercise those rights.

We aim to be transparent and accountable in using your data, ensuring compliance with the UK Data Protection Act 2018, the General Data Protection Regulation (GDPR) as retained in UK law, and other relevant legislation.

This policy applies to all personal data processed by Aspiration Training Ltd. (ATL), including its subsidiaries such as Aire Vocational Training Ltd. Each entity within the ATL Group adheres to this policy and the principles of GDPR.

  • Learners, apprentices, and trainees
  • Employers and partners
  • Staff, contractors, and job applicants
  • Visitors to ATL’s websites, applications, and digital platforms

This policy applies to data collected via all ATL’s services, including in-person interactions, telephone, email, website forms, learning management systems, and third-party platforms ATL uses for education and business operations.

Where ATL processes personal data on behalf of another organisation (e.g., funding bodies), this policy applies to the extent that ATL acts as a data processor, following the instructions of the data controller.

For questions regarding this policy or specific data processing activities, please contact [email protected].


Policy

Aspiration Training Ltd. provides opportunities for young people and adults to learn new skills and gain qualifications. We have offices in England and Wales (Company registration no 04551344). The registered address is c/o Gateley Plc, Park View House, 58 The Ropewalk, Nottingham, Nottinghamshire, NG1 5DW.

For GDPR, Aspiration Training Ltd. acts as a data controller for personal data we collect directly from learners, employers, and staff. We may also act as a data processor in cases where we process data on behalf of funding bodies or other third parties. If you are unsure about our role in specific circumstances, please contact us at [email protected].


What Personal Data We Collect

We may collect the following types of personal data:

  • Contact Details: Name, email address, phone number, postal address.
  • Demographic Data: Date of birth, gender, nationality.
  • Education and Employment Information: Apprenticeship applications, job titles, employer details, and academic qualifications.
  • Financial Information: Bank details for funding purposes.
  • Usage Data: Information about how you use our website and services (via cookies and analytics tools).
  • Sensitive Personal Data (SPD): Information related to ethnicity, health, learning difficulty or disability indicators, or other similar data when required for government reporting or to assess additional support needs. We take extra precautions to safeguard SPD data, including encryption of stored and transmitted data, strict access controls, regular security audits, and compliance with GDPR standards. Additionally, we ensure that sensitive data is retained only for as long as necessary and securely disposed of when no longer needed."
  • Uploaded Content: Photographs, videos, or audio recordings shared via our platforms.


How We Use Your Data

We process your personal data under the following lawful bases as defined under Article 6 (general data) and Article 9 (sensitive data) of UK GDPR:

A. Consent

Where you have provided your consent, we may:

  • Send you information about promotions, events, or services that interest you.
  • Share your personal data with third-party partners to inform you about apprenticeship opportunities.
  • You can withdraw your consent at any time by contacting us at [email protected], using the 'unsubscribe' link in marketing emails.  Withdrawal requests are processed within 30 days, and you may lose access to certain services or communications that require your consent."

B. Contractual Necessity

We process your data to:

  • Deliver and administer apprenticeship programs and other training services.
  • Fulfil contractual obligations with you or your employer.

C. Legitimate Interests

Where necessary for our legitimate business interests, we may:

  • Respond to your enquiries and provide support.
  • Analyse and improve our services through surveys and feedback.
  • Notify you about service updates and essential changes to funding rules.
  • Carry out marketing and promotional campaigns (with the option to opt out).
  • Maintain records of our dealings and transactions for compliance and quality assurance.
  • Use anonymised data for statistical and research purposes.

D. Legal Obligation

We may process your data to comply with contractual and legal obligations, such as:

  • Registering apprenticeship applications with the Departments for Education in England and Wales
  • Retaining data for audit and compliance purposes.
  • Ensuring compliance with funding, regulatory, and statutory reporting requirements, including the Individualised Learner Record (ILR).

E. Vital Interests

In rare cases, we may process your data to protect your vital interests, such as funding or education change emergencies.


Data Sharing

We may share your data with the following:

  • Government agencies responsible for funding and compliance.
  • Third-Party Service Providers: IT systems, recruitment partners.
  • Apprenticeship Employers: Where applicable, to support apprenticeship delivery and performance tracking. Employers must comply with GDPR when handling learner data.
  • Data Processors: Learner management systems, virtual classrooms, and assessment tools.
  • Certification Bodies: For qualification and certification purposes.
    We ensure all third parties comply with GDPR and relevant data protection laws. We implement appropriate safeguards where data is transferred outside the UK/EEA.

Third-party service providers processing ATL data on our behalf are contractually obligated to follow GDPR and UK data protection laws.


Your Rights

Under GDPR and the UK Data Protection Act 2018, you have the following rights:

  • Access: Request a copy of your personal data.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure: Request deletion of your data where applicable.
  • Restriction: Limit processing of your data under certain circumstances.
  • Data Portability: Receive your data in a structured, machine-readable format.
  • Objection: Object to processing based on legitimate interests, public interest processing, or statistical research.
  • Withdraw Consent: Withdraw consent for processing based on your explicit permission.
  • Lodge a Complaint: Contact the Information Commissioner’s Office (ICO) if you have concerns.
    To exercise your rights, contact [email protected]. We aim to respond within 30 days.


Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy.

  • Learner Data: Retained for a minimum of 6 years after program completion in compliance with funding rules. Certain financial or contractual records may be retained for up to 10 years.


Security Measures

We implement technical and organisational measures to protect your data, including:

  • Encryption of sensitive information.
  • Secure storage systems.
  • Regular security audits and staff training.


Cookies and Website Tracking

We use cookies to enhance your browsing experience. For details on managing your preferences, refer to our Cookie Policy.


Automated Decision-Making and AI Use

We use AI-assisted tools for assessment support, but final grading and feedback are always reviewed by a human assessor. No fully automated decisions are made that significantly impact an individual. If you have concerns about AI processing, contact [email protected].


Data Breach Reporting

In the event of a high-risk data breach affecting personal data, ATL will notify affected individuals promptly and provide guidance on mitigating potential risks. Breaches are reported to the ICO within 72 hours, where legally required.


Contact Us

For any questions or concerns, contact our Data Protection Officer (DPO):
Aspiration Training Ltd
Suite 9B, Floor 4, Grosvenor House, Prospect Hill, Redditch, Worcestershire, B97 4DL.
Telephone: 01527 359646
Email: [email protected]


How to Complain

If unresolved, you may contact the ICO:

  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
  • Phone: 0303 123 1113
  • Website: ICO Complaint Page
  • If you would like to discuss any aspect of this policy, please contact us at [email protected]