Blue Sky Professional Development Limited is a private training organisation specialising in HR and Management training, predominately in East Anglia.  

This privacy policy provides detailed information on who we are, when and why we collect personal information, how it is used, the limited conditions under which it may be disclosed to others and how it is kept secure.  Your rights in relation to your personal data, how to contact us and who to contact if you would like to report a concern about the way in which we process your personal data, are detailed within this policy.

We hold personal data on enquirers, students, alumni, suppliers, employers, clients and staff.  We will not sell this data, although we may share this data with trusted third parties as detailed within this policy.

Who are we?

For the purposes of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), Blue Sky is the ‘controller’ and ‘processor’ of personal data. Our registered address and company number are detailed above.

What personal data do we collect?

We may collect and process your personal data if you –

• complete a form on our website or an Awarding Body website

• complete a survey or feedback form

• correspond with us by phone, e-mail, or in writing

• report a problem

• sign up to receive our communications

• create an account with us, for example, to register for our student website

• enter into a contract with us to receive products and/or services, such as register for a training programme.

We may collect your name, e-mail and postal addresses, telephone number and job role.  

Additional personal data will be required from learners upon registration, as detailed within the Learner Privacy Notice (Learner Personal Data notice 2022.pdf).

If you visit our website, we may automatically collect the following information -

Using Google Analytics, information about your visit to our website, such as the products and/or services you searched for and viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Information we receive from other sources

If you are a tutor, apprentice, or learner, we may also receive information about you from an Awarding Body, a partner training provider or employer when you enquire or register to receive products and/or services from us/them.

Information about other people

If you provide information to us about any person other than yourself, such as your relatives, next of kin, your advisors or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for us to use it for that given purpose.

Sensitive personal data

In certain limited cases, we may collect certain sensitive personal data from you.  That is information about your physical or mental health and/or details of criminal offences.  However, we will only do so with your explicit consent.

In addition, to monitor equality and diversity of our student and staff population, we may collect information from you about your racial or ethnic origin, gender, age, marital status, disability/health, sexual orientation, religion or belief, working patterns/arrangements and caring responsibilities.  This data is not person specific and is collected anonymously. 

How do we use your personal data?

When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

Contract performance: We may use your personal data to fulfil a contract, or take steps linked to a contract -

• to provide the products and/or services to you, i.e. delivery of the training registered for

• to communicate with you in relation to the provision of the contracted products and services

• to provide you with administrative support, such as account creation, security, and responding to issues

• provide you with industry information, surveys, information about events, offers and promotions related to the products and/or services.

Legitimate Interests:  This is necessary for purposes which are in our, your, or third party legitimate interests. These could be -

• providing you with newsletters, surveys, information about our events, offers and promotions related to products and services offered which may be of interest to you

• communicating with you in relation to any issues, complaints, or disputes

• improving the quality of experience when you interact with our products and/or services.

Note: you have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your Rights.

Consent: where you have given your express consent to receive marketing and other communications, we may use your personal data to -

• send you newsletters, surveys, information about our awards and events, offers, and promotions related to products and services which may be of interest to you

• develop and deliver marketing and advertising for products and services. 

Note: You have the right to withdraw your consent at any time.  Please see under the heading ‘unsubscribing’. 

Where required by law: we may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

Who do we share your personal data with?

We may share your personal data with Blue Sky staff and tutors.

We take all reasonable steps to ensure that our staff and tutors protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share your personal data with trusted third parties including:

• Awarding Bodies, such as The Chartered Institute of Personnel and Development (CIPD) and The Institute of Leadership and Management (ILM) 

• Partner training providers (Colchester Institute) and The Learning Records Service

• service providers contracted to us in connection with the provision of products and services, such as providers of IT services and administration support services including our online learning platform supplier and online library supplier.  

• analytics and search engine providers that assist us with the improvement and optimisation of our website.

Note:  Links to third party privacy policies and notices are as follows –

• The Chartered Institute of Personnel and Development (CIPD) www.cipd.co.uk/privacy-policy 

• The Institute of Leadership and Management (ILM)

 www.i-l-m.com/privacy/learnerpersonaldata

• Colchester Institute

www.colchester.ac.uk/disclaimers-terms-and-conditions/

• Learning Records Service

www.gov.uk/government/publications/lrs-privacy-notices/lrs-privacy-notice

• Perlego

www.perlego.com/privacy-policy

• anewspring

www.anewspring.com/privacy-statement/

In addition, we may share relevant data with –

• Fellow students – for the purposes of social learning

• Employers who have funded training for students, giving progress updates where required.

Where a third party recipient is located outside the European Economic Area we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

Where there is a contract between us, we will retain your personal data for the duration of the contract and for a period of six years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

If you have enquired about a product or service, this information will be kept until you register as a Blue Sky student or for one year unless otherwise requested.  

Where you have consented to marketing communications, you may change your preferences or unsubscribe at any time by clicking the unsubscribe link in an email from us.

Where do we store your personal data and how is it protected?

Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.  Your data is stored both electronically and in hard copy format.  Electronic data is stored with password protected access only and hard copies are kept in locked cabinets in a secured office.

Blue Sky tries to minimise risks posed by cloud based storage by using trusted and GDPR compliant suppliers.

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulatory and the relevant Awarding Body of a suspected data security breach where we are required to do so. 

Where you have a username or password (or other identification information) which enables you to access certain services or parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website - any transmission is at your own risk. 

Your Rights

Under the GDPR, you have various rights with respect to our use of your personal data -

Right to Access

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given. We will contact you to verify your identity before proceeding. We will respond within 30 days of the request. Please note that there are exceptions to this right.  We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.

Right to Rectification

We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to Erasure

You have the right to request the deletion of your personal data where, for example, the personal data is no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided.

Right to Object

In certain circumstances you have the right to object to the processing of your personal data, where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interests for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided.

Right to Restrict Processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information.

Right to data portabilityIn certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to make such request, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

Unsubscribing

You may unsubscribe from marketing communications at any time by contacting Beth Russell at beth.russell@blueskypd.co.uk or at the postal address provided or by using the ‘unsubscribe’ functionality on the footer of any marketing communications sent to you.

Contact

If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, please contact our Privacy Officer, Beth Russell, at Blue Sky Professional Development Limited, Henderson Business Centre, 51 Ivy Road, Norwich. NR5 8BF or by email to beth.russell@blueskypd.co.uk.

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern in the first instance, you may lodge a complaint with the UK Information Commissioners Office (ICO) at https://ico.org.uk/concerns

Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Policy.