PN077 - Adult & Community Learning Privacy Notice

Torfaen County Borough Council is committed to protecting your privacy when you use our services. This Privacy Notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards in place to protect it.

TCBC Service Area: Communities, Customer Service and Digital
Work Area: Skills and Employability
Contact Details: Angela Price
Privacy Notice Name: Adult & Community Learning

Data Controller: Torfaen County Borough Council, c/o Civic Centre, Pontypool NP4 6YB

If you wish to raise a concern about the handling of your personal data, please contact the Data Protection Officer on 01495 762200 or email dpa@torfaen.gov.uk

As a learner or participant in services delivered by Torfaen Adult Education, we collect data from you in order to effectively run our services, provide you with a qualification and report to our funding bodies.

Some elements of this notice will only apply to learners attending activities via Google Classroom or Google Meet digital learning platforms. Some elements of this notice will only apply to learners undertaking assessments for specific awarding bodies were those assessments need to be recorded.

Who provides your data to the Council?

The personal information we process is provided to us directly by you. We also receive personal information indirectly from awarding bodies in connection with the qualifications you are studying for.

We will use this data for any or all of the following reasons:

To contact you about matters relating to your learning activity;
To contact you about further opportunities for learning if you have consented to be on our mailing list;
To keep track of your learning with us;
To plan future classes and improve our delivery;
To keep track of any payments or refunds owing;
To provide reports and support funding claims to our funding bodies;
To provide evidence to awarding bodies to support you claiming a qualification or license.

How does the Council collect this information?

From telephone or in person conversations with us;
From electronic forms and paperwork that we ask you to complete;
From the evidence we may ask you to provide to support your application;
By recording exams and oral assessments, where prescribed by the awarding body.

What information does the Council collect about you?

The Torfaen Adult Education team collects:

Personal Identifiers: such as Name, Date of Birth, National Insurance number, your previous surname (if any), Unique Learner Number and an ACL issued identification;
Your contact details and your emergency contact details;
Length of time you have been resident in the UK
Your previous Adult Learning provider (if any)
Employment status details such as if you are currently in or out of work and for how long.
Equality of Opportunity data such as gender, ethnicity, national identity and learning difficulties, disabilities and health conditions. You will be given the option to refuse this information.
Welsh language data such as your skills and qualifications in using the language and your preferred language for communication and for study.
Data relating to the activities you undertake with the ACL service such as course details, dates, attendance and qualifications entered and attained.
Unspent convictions.
Where you are attending an activity via a Google platform we will also create and store a username unique to you that will allow you access to the virtual classroom.
Where oral assessments are required for the purpose of awarding a certificate or license, recordings (voice and or video) will be made and stored. You will be advised to limit your disclosure of personal data other than your name during the recording.
We will record certain examinations where awarding bodies require video recordings to confirm exam conditions are being enforced.

Why does the Council process your personal data?

Under Article 6 of the UK General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

(a) Your Consent. This is required if you opt into our mailing list. Consent only relates to the specific purpose for which it has been given and you can withdraw your consent at any time. We do not rely on consent as a lawful basis for any other processing.

(e) We need it to perform a public task.

Special categories of personal data

We collect the following optional special category data:

personal data revealing racial or ethnic origin
data concerning health

We collect this under Article 9 of the UK GDPR.

Where we collect criminal data, this is processed within the Council under Article 10 of the UK GDPR.

Who has access to your data?

Your data is shared internally only with the appropriate staff where it is necessary for the performance of their roles.

Your data may also be shared externally with organisations. These may include, but not be limited to:

Awarding bodies for the purpose of awarding a certificate or qualification. These may include:
- Agored Cymruo BCS (British Computer Society)
- CITB
- City & Guildso Highfield
Funding bodies for the purpose of reporting our work and claiming funding for your learning. This will not apply to services not funded by these bodies. Funding bodies may include:
- Coleg Gwent, where the college holds the prime contract for the learning provision with Welsh Government
- Welsh Government, either directly or via Coleg Gwent as the funding body for learning provision

Apart from where previously stated, we do not pass your details to third parties unless we are lawfully required do so.

Is the Data transferred out of the UK?

How does the Council keep your data secure?

The Council has internal policies in place to ensure the data it processes is not lost, accidentally destroyed, misused or disclosed. Access to this data is restricted in accordance with the Council’s internal policies and in compliance with the UK GDPR.

Data will be stored securely in:

Secure internal network area for data and electronic copies of files
Secure cloud for electronic enrolment applications
Secured physical storage for paper and hard copies

Where the Council engages third parties to process personal data on its behalf, they do so on the basis of written instructions. These third parties are also under a duty of confidentiality and are obliged to implement appropriate measures to ensure the security of data.

How long does the Council keep your data?

The Council will hold your personal data only for the period that is necessary and will follow organisational and Local Authority standards in this area. At the end of the retention period the Council will securely destroy or dispose of the data in line with retention schedules.

The ACL service operates a 3-year retention policy for learner data.
Data held as evidence for Awarding Bodies is retained in line with the requirements of each Awarding Body.

Are we making automated decisions/profiling with your data?

Your rights

You have a number of Rights you can exercise:

Access - to obtain a copy of your data on request
Rectification – to require the Council to change incorrect or incomplete data
Object, Restrict or Delete - under certain circumstances you can require the Council to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
Data portability – to receive and/or transmit data provided to the Council to other organisations (this applies in limited circumstances)
Withdraw your consent at any time (where consent has been given)
To know the consequences of failing to provide data to the Council
To know the existence of any Automated Decision-making, including profiling, and the consequences of this for you.
To lodge a complaint with a supervisory authority (Information Commissioners Office)

If you would like to exercise any of these rights, please contact Angela Price, Croesyceiliog Community Education Centre, The Highway, Croesyceiliog, Cwmbran, NP44 2HF, or e-mail angela.price@torfaen.gov.uk

The Information Commissioner can be contacted at: The Information Commissioner’s Office (Wales), 2nd Floor, Churchill House, Churchill Way, Cardiff, CF10 2HH. Telephone 0330 414 6421 or e-mail Wales@ico.org.uk

Last Modified: 17/07/2023 Back to top