Training Privacy Policy
1.1 This policy covers the treatment of personal data that Grant Engineering (IRL) ULC Training Academy (Grant IRL Training) collects when you are applying to attend training and/or assessment with us, whether this application is made in person, by email, letter, via our website or through our eLearning Academy at www.grantelearning.com
The use of the terms ‘we’, ‘us’, ‘our’ and ‘Grant IRL Training’ in this Privacy Policy refers to Grant Engineering (IRL) ULC Training Academy.
1.2 We are committed to safeguarding the privacy of those applying to attend our training centre or eLearning Academy and, in this policy, we explain how we will handle your personal data.
1.3 By accepting our offer of a place on a course with Grant IRL Training, either verbally or by completing our training enrolment form, you are accepting that we will use your personal data in accordance with the terms of this policy.
1.4 We will not disclose your personal data to anyone other than as set out in this Privacy Policy.
2.1 We collect your personal data when you apply to attend training and/or assessment with Grant IRL Training. This may be in one of the following ways:
- Directly from yourself
- Indirectly from your employer, business partner, partner, spouse, etc. who is providing the information on your behalf
- Indirectly from a training agent who is providing the information on your behalf
2.2 This information may be provided via email, post, phone, or online, using the required Grant IRL Training enrolment documentation.
2.3 Where you book or access training online, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy Cookie Policy | Grant Ireland (grantengineering.ie) for further details.
3.1 We will only require from you the personal data necessary to process your application, provide the training and (where applicable) assessment.
3.2 The actual personal data we will require will depend on the actual training/assessment you are applying for, as follows:
- OFTEC training and assessment
- LCL Awards training and assessment
- Grant Engineering (IRL) ULC Product training
- eLearning Academy courses
3.3 For OFTEC training/assessment applicants
We will only collect the necessary personal data as required by European Registration Services (ERS) for the purposes of undertaking the assessment, in accordance with their Quality Management System. This includes your name, address, telephone number, email address, date of birth, national insurance number/PPS number, as well as any physical or learning disabilities in order to ensure equality of opportunity or treatment. Grant IRL also collect data on dietary requirements for catering purposes only.
To comply with the ERS oil competent person’s certification scheme, certain personal data, along with the contract, all assessment documentation and certificate of competence, remains the property of ERS for a period of six years from the date of the assessment.
Our basis for collecting this information is the performance of contract and legitimate interest. Where we are collecting dietary requirements, our lawful basis is consent. Our lawful basis for collecting information about any disabilities is that it is necessary for reasons of substantial public interest under the Data Protection Act 2018.
3.4 For LCL Awards training/assessment applicants
We will only collect the necessary personal data as required by LCL Awards for the purposes of undertaking the assessment, in accordance with their Quality Management System. This includes your name, address, telephone number, email address, date of birth, PPS or NI number, car registration number (when attending training in Birr only) and dietary requirements. We also collect details on whether you have any physical or learning disabilities in order to ensure equality of opportunity or treatment.
To comply with the LCL Awards scheme, certain personal data, along with the contract, all assessment documentation and certificate of competence, remains the property of LCL Awards for a period of six years from the date of the assessment.
Our basis for collecting this information is the performance of contract and legitimate interest. Where we are collecting dietary requirements, our lawful basis is consent. Our lawful basis for collecting information about any disabilities is that it is necessary for reasons of substantial public interest under the Data Protection Act 2018.
3.5 For Grant IRL product training applicants
We will only collect the necessary personal data required to administer the training course in question (i.e. populate, prepare and deliver the course). This will include information such as your name, address, telephone number, email address, car registration number (when attending training in Birr only) and dietary requirements. We also collect details on whether you have any physical or learning disabilities in order to ensure equality of opportunity or treatment. .
Our basis for collecting this information is performance of a contract and legitimate interest. Where we are collecting dietary requirements, our lawful basis is consent. Our lawful basis for collecting information about any disabilities is that it is necessary for reasons of substantial public interest under the relevant regulations.
3.6 For eLearning Academy users
We will collect the information necessary to enable you to create an account and access our free and chargeable courses. This will include information such as your name, email address, postal address, telephone number, chosen password, job details and payment information (where required). Our basis for collecting this information is performance of a contract and legitimate interest.
3.7 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.
3.8 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.
3.9 Where we need to collect personal data by law, or under the terms of any assessment or certification criteria, and you fail to provide that data when requested, we may not be able to provide our training services to you. In this case, we may have to cancel a booking that you have with us, but we will notify you if this is the case at the time.
3.10 Contacting you in the future
We may contact you for your feedback on the course(s) you have attended at Grant IRL Training, and from time to time with information that you may find helpful, such as:
- A reminder that your current OFTEC is about to expire and that you will need to re-take the assessment to maintain that qualification
- Details of new training courses or qualifications
- Details of new Grant products and services
- Technical updates to the information given on the course(s) you attended with us
The lawful basis for this is our legitimate interest in providing you with information relevant to your training, and for improving the training service we offer to future candidates.
You can ask us to stop sending you such information at any time by following the opt-out links on any message sent to you or by contacting us at any time. Where you opt out of receiving this information, this will not apply to personal data provided to us in relation to training and assessment documentation.
For OFTEC training/assessment applicants
Where applicable, we will contact you with a reminder that your current OFTEC qualification is about to expire and that you will need to re-take the assessment in order to maintain that qualification.
4.1 For OFTEC training/assessment applicants
We will only pass your personal data on to ERS to process your application for assessment and confirm your eligibility for certification as required by their certification scheme Quality Management System.
ERS will also pass your personal details on to the scheme owner, OFTEC, to confirm eligibility for Competent Persons Scheme registration.
We will not disclose your personal data to any other parties, e.g., any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.
ERS’s privacy policy detailing how they handle personal data can be found here: https://www.erscert.co.uk/about-us/ers-privacy-policy/
OFTEC’s privacy policies can be found here: https://www.oftec.org/policies
4.2 For LCL Awards training/assessment applicants
We will only pass your personal data on to LCL Awards to process your application for assessment and confirm your eligibility for certification as required by their certification scheme Quality Management System.
We will not disclose your personal data to any other parties, e.g., any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.
4.3 For Grant IRL product training applicants and eLearning Academy users
We may disclose your personal data to any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.
We will also disclose your personal data to Microsoft Teams, which is the third party we use to provide live courses via the eLearning Academy. A copy of their privacy policy can be found here: Microsoft Privacy Statement – Microsoft privacy
4.4 We may pass your personal data to our third-party email provider Zoho for the purpose of distributing the marketing communications to you and other follow up information after you have attended a training course. You can find more information on how Zoho handle personal information by viewing their privacy policy Zoho - Privacy Policy
4.5 We may also share hashed portions of your personal data with certain strategic partners to make our business more responsive to your interests. For example, we may locally hash your email address and transmit the resulting hashed data to Facebook for the purpose of creating “Custom Audiences” (where targeted ads are sent to people on Facebook who already use our services). If you wish to opt-out of this use of certain hashed portions of your personal data, please email us at marketing@grantengineering.ie, and we will begin the process of removing your personal data from our Custom Audience list.
4.6 We may share your personal data with 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.
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in the UK and France, as well as the Republic of Ireland
5.3 Some of our external third-party processors are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
(b) Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain and delete your personal data as follows:
6.3 For OFTEC training/assessment applicants
As required by European Registration Services (ERS), in accordance with their Quality Management System all personal data, application forms, contract, all assessment documentation will be kept for a period of six years from the date of the assessment.
Following this all hard copy records (application forms, contract, and assessment documentation) will be destroyed. Personal data on the Grant Ireland Training database will be retained indefinitely to allow us to provide delegates with any historical training records.
6.4 For LCL Awards training/assessment applicants
As required by LCL Awards, in accordance with their Quality Management System, all personal data, application forms, contract, all assessment documentation will be kept for a period of six years from the date of the assessment.
Following this, all hard copy records (application forms, contract, and assessment documentation) will be destroyed. Personal data on the Grant IRL Training database will be retained indefinitely to allow us to provide delegates with any historical training records.
6.5 For Grant IRL product training applicants
Hard copy data (e.g., enrolment forms) will only be kept until the course in question is delivered. They will be destroyed immediately following the course. Personal data on the Grant IRL Training database will be retained indefinitely to allow us to provide delegates with any historical training records.
If you submit an email enquiry about one of our courses, we will keep that data for 2 years after which it is archived. It is then deleted from our system after 5 years.
6.6 For eLearning Academy users
Personal data on the Grant IRL eLearning Academy database will be retained indefinitely to allow us to provide delegates with any historical training records.
6.7 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7.1 We may update this policy from time to time by publishing a new version on our website and eLearning Academy or by notifying you via email.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 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.
8.1 In this Section 8, we have summarised the rights that you have under data protection law.
Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) The right to access.
(b) The right to rectification.
(c) The right to erasure.
(d) The right to restrict processing.
(e) The right to object to processing.
(f) The right to data portability.
(g) The right to complain to a supervisory authority; and
(h) The right to withdraw consent.
8.3 The right to access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 The right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can, and should, notify Grant IRL Training at any time of any changes to your personal data, e.g., contact details. The Grant IRL Training records will then be amended accordingly.
8.5 The right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation i.e. product guarantees; or for the establishment, exercise or defence of legal claims.
For OFTEC training/assessment applicants
It is a requirement of the European Registration Services (ERS) certification scheme that all personal data, application forms, contract, all assessment documentation will be kept for a period of six years from the date of the assessment.
Any request for erasure of data within this period will result in any current certification being withdrawn by European Registration Services (ERS).
For LCL Awards training/assessment applicants
It is a requirement of the LCL Awards scheme that all personal data, application forms, contract, all assessment documentation will be kept for a period of six years from the date of the assessment.
Any request for erasure of data within this period will result in any current certification being withdrawn by LCL Awards.
8.6 The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 The right to object to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 The right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 The right to complain to a supervisory body
You have the right to make a complaint at any time to the Data Protection Commission’s Data Protection Officer, the ROI supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.
8.12 The right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 Rights related to automated decision making
Your personal data, collected when applying for training or assessment, will not be subject to any automated decision-making processes by Grant IRL Training.
8.14 You may exercise any of your rights in relation to your personal data by written notice to us.
9.1 The Grant Ireland Training Academy is owned and operated by Grant Engineering (IRL) ULC, who is the controller and responsible for your personal data.
9.2 We are based as an Unlimited Company at Crinkle, Birr, Co Offaly, R42 D788.
9.3 Our principal place of business is at Crinkle, Birr, Co Offaly, R42 D788.
9.4 You can contact us:
10.1 Our Data Protection Advisor can be contacted at our office address.