Help to Grow: Management Programme – Privacy Notice

This Privacy Notice provides information on how the Chartered Association of Business Schools collects and processes your personal data when you express an interest in, or sign up to, the Help to Grow: Management Programme; or if you are a mentor for the Programme. This Privacy Notice further provides you with information regarding your rights and our obligations.

We process data in accordance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.  This Privacy Notice is made in accordance with Article 13 of the UK GDPR.

The Department for Business, Energy and Industrial Strategy (BEIS) is funding the Help to Grow: Management Programme. The Chartered Association of Business Schools is delivering the Programme, and processing your data, on BEIS’s behalf. BEIS is the data controller and the Chartered Association of Business Schools is the data processor in relation to your data. We are providing this Privacy Notice on BEIS’s behalf.  BEIS also has its own privacy policy, which can be accessed here: https://www.gov.uk/government/organisations/department-for-business-energy-and-industrial-strategy/about/personal-information-charter#beis-privacy-notices.

When we mention "we", "us" or "our" in this Privacy Notice, we are referring to the Chartered Association of Business Schools.

We will share your data with the business school where you enrol or mentor and with the evaluation and monitoring partner.

Where we process your personal data for purposes other than in connection with the Help to Grow: Management Programme, we act as an independent data controller.  We provide more detail on this below.

We may review and change this Privacy Notice from time to time, so please check this website page regularly.

This version was last updated in May 2021.

Who is collecting the data?

The Chartered Association of Business Schools is committed to safeguarding and respecting your privacy.

We collect and process your personal information on behalf of BEIS to administer the Help to Grow: Management Programme, as further detailed below. We do so in accordance with this Privacy Notice, and in compliance with the UK GDPR and the Data Protection Act 2018.

The business school where you enrol or mentor will also collect and process your personal data.

BEIS is a department of the UK Government, whose general contact address is: 1 Victoria Street, London, SW1H 0ET.

The Chartered Association of Business Schools is a registered company (company number: RC000880) and a registered charity in England and Wales (charity number: 1162854). Our address is: 3rd Floor, 40 Queen Street, London, EC4R 1DD.

Why do we process your personal data and what is our legal basis for processing it?

We collect and use your information to manage your expression of interest in the Help to Grow: Management Programme, process your application form, administer the Help to Grow: Management Programme to you and after you finish the course, send you alumni information.  If you are a mentor, we collect and use your information to help us administer the Help to Grow: Management Programme.

The legal basis for processing your personal data in connection with the Help to Grow: Management Programme is that it is necessary for the performance of a task carried out in the public interest, by us on behalf of BEIS.

The legal basis for processing your personal data in connection with our newsletter is with your consent.

How do we collect personal data about you?

The Chartered Association of Business Schools may collect data about you in the following ways:

  • Through our website (smallbusinesscharter.org) via your expression of interest or registration for the Help to Grow: Management Programme. Please also see the link to our Website Privacy Policy: smallbusinesscharter.org/privacy-policy/.
  • If you contact us, we may keep a record of that correspondence. If you send us personal information via email, letter or phone, we may keep that information and your contact details.
  • If you are a participant, we will collect information relating to your attendance at the Help to Grow: Management Programme from the business school you enrol with.
  • We will collect data through our virtual learning environment platform, including your feedback, responses to surveys, any data you upload to our discussion boards and online forums, your registration for our alumni events and activities.
  • Our website uses cookies (text files placed on your computer) which, if you agree, will collect Technical Data about your equipment, browsing actions and patterns. This information is used to track visitor use of the site and to analyse site activity. Please see our cookie policy for further details.

What personal data do we collect from you?

If you apply for the Help to Grow: Management Programme, we may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data includes first name, last name, job title, employer, the unique identifier assigned to you on registration, title, age and gender.
  • Contact Data includes employer address, billing address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about your registration and payments.
  • Technical Data includes, but is not limited to, traffic data, browser data, internet protocol (IP) address, weblogs, platform used and other communication data.
  • Profile Data includes feedback and survey responses, information you provide regarding your role at your business, information regarding your interactions with our email communications and attendance at our events.
  • Usage Data includes information about how you use our website.
  • We may collect ‘Special Category’ personal data about you as described below. This is more sensitive personal data under the UK GDPR.

If you opt-in to receiving our newsletter, we collect, use, store and process the following contact information about you: your name, address (preferably your business address), company, telephone numbers and email address. We also record that you have opted-in (or unsubscribed, where applicable).

Special Category personal data

We may collect information revealing racial or ethnic origin and disability with your consent, for the purposes of evaluating equal opportunities. This information will be shared with BEIS for those purposes. It will not be used to make any decisions regarding your application to the Help to Grow: Management Programme.

If you separately choose to disclose information regarding any disability you may have and/or your accessibility requirements, we may use this information to make reasonable adjustments to assist with delivering the Programme to you.

The legal basis for processing your Special Category personal data is with your explicit consent.

What do we use your personal data for?

If you are express an interest in and/or register for the Help to Grow: Management Programme, we will use data collected to:

  • Respond to you if you express an interest in the Help to Grow: Management Programme and/or if you apply for a place by completing our online application form.
  • Share your data with the relevant business school for the purposes of offering you a place and delivering the Programme to you.
  • Share your data with Skilled Education Ltd and Instructure Global Ltd, our virtual learning environment providers, to create your participant profile on the online platform and deliver the Programme content to you.
  • Share your data with our evaluation partners, as detailed in this Privacy Notice.
  • Share your data with the Cabinet Office, as detailed in this Privacy Notice.
  • Share your Technical Data with BEIS to enable them to track the effectiveness of their marketing channels to our site.
  • Maintain e-mail, telephone and offline contact with you, preferably at your place of business, in relation to the Help to Grow: Management Programme.
  • Communicate with you as one of the alumni of the Help to Grow: Management Programme, following the end of the programme, including sending you details of alumni events.

If you opt-in to receiving our newsletter, we will use data collected to send it to you by e-mail, preferably at your place of business.

Mentors

What personal data do we collect from you?

  • Identity Data includes first name, last name, job title, employer, title.
  • Contact Data includes business address, email address and telephone numbers.
  • Technical Data includes, but is not limited to, traffic data, browser data, internet protocol (IP) address, weblogs, platform used and other communication data.
  • Profile Data includes feedback and survey responses, information regarding your interactions with our email communications [and attendance at our events].
  • Usage Data includes information about how you use our website.

If you are a mentor, what do we use your personal data for?

  • Maintain e-mail, telephone and offline contact with you, in relation to the Help to Grow: Management Programme.
  • Share your data with business schools which require mentors to deliver the Programme.
  • Share your data with our evaluation partners, as detailed in this Privacy Notice.

Where do we process your personal data and how do we keep it secure?

We process data at our registered office: 3rd Floor, 40 Queen Street, London, EC4R 1DD. Our staff who work remotely and our third party service providers do so under contracts which protect your data, as described below.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, or used, accessed, altered or disclosed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents and contractors 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.  BEIS will notify you and the Information Commissioner's Office of a breach where it is legally required to do so.

We will take all steps necessary to ensure that your data is processed and stored in a secure environment, in accordance with our legal obligations and the UK GDPR and Data Protection Act 2018.

International Transfers

We may transfer your data outside the United Kingdom (UK), including to third party service providers who support our virtual learning environment.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that one of the following safeguards is implemented:

What are our principles for retaining personal data?

In accordance with the UK GDPR and the Data Protection Act 2018, we retain personal data for no longer than is necessary for the purposes for which it is being processed or to comply with our legal obligations.

The business school where you enrol or mentor may retain your personal data for as long as is necessary for the purposes for which they process it.  For more details, please contact your business school.

Our evaluation and monitoring partners must delete your personal data after expiry of their evaluation contract.

In some circumstances you can ask us to delete your data: see Your Rights below for further information.

Any Special Category personal data that we may collect for the evaluation of the Help to Grow: Management Programme with your consent shall be deleted from our records within two months after the conclusion of the entire Help to Grow: Management Programme. This data will be deleted by BEIS and their appointed evaluators of the Programme once the evaluation is complete.

There are some circumstances where personal data may lawfully be stored for longer periods or permanently, such as for statistical purposes or if the data is anonymised.

Your contact data, processed for the purposes of sending our newsletter, will be stored until you unsubscribe or request erasure of your personal data.

What personal data do we share with BEIS and your business school?

If you are a participant, we will share some of your personal data with BEIS, to enable it to monitor and evaluate of the Help to Grow: Management Programme.

We will share the following information with BEIS:

  • Anonymised Help to Grow: Management Programme participant information (gender, ethnicity, age, disability status, job title).
  • Help to Grow: Management Programme business information (geographical area of business, Business Turnover, number of employees in business, business sector).
  • Anonymised participant satisfaction & engagement data.
  • Technical Data, which is collected through the cookies on our site if you agree. Please see our cookie policy for further details.

BEIS’s Data Protection Officer can be contacted as follows: BEIS Data Protection Officer, Department for Business, Energy and Industrial Strategy, 151 Buckingham Palace Road, London SW1W 9SZ. Email: dataprotection@beis.gov.uk.

We will also share some of your personal data with the business school delivering the programme to which you apply. This will include the following information:

  • Help to Grow: Management Programme participant information (name, email address, phone number, organisation, company address, job title, number of direct reports and other information provided on your application form).
  • Help to Grow: Management Programme business information (geographical area of business, number of employees in business, business sector, business turnover).
  • Anonymised participant satisfaction and engagement data.

Do we share your personal data with third parties?

As mentioned above, we will share some of your personal data with Skilled Education Limited and Instructure Global Ltd, our virtual learning environment providers, who will create, manage and support the online platform that will be used to deliver the Programme to you.  Amazon Web Services, who hosts the platform, will also have access to your data. This will include the following information:

  • Help to Grow: Management Programme participant information (name, email address, phone number, organisation, company address, job title, number of direct reports, the unique identifier that is assigned to you on registration and other information provided on your application form).
  • Help to Grow: Management Programme business information (geographical area of business, number of employees in business, business sector, business turnover).

Other third party service providers who help support our platform will also have access to your data.

We and BEIS may share some of your personal data with a third party monitoring and evaluation partner of the Help to Grow: Management Programme, for evaluation purposes only.

We will share the following information with the monitoring and evaluation partner:

  • Help to Grow: Management Programme participant information (gender, ethnicity, age, disability status, job title).
  • Help to Grow: Management Programme business information (geographical area, business turnover, number of employees in business, business Sector)
  • Participant satisfaction and engagement data.
  • your contact data, to enable the monitoring and evaluation partner to contact you for evaluation.

We and BEIS may share some of your data with the Cabinet Office for evaluation purposes and to guide their communications campaign for the Help to Grow: Management Programme.

We may share the following information with the Cabinet Office:

  • Help to Grow: Management Programme participant information (gender, ethnicity, age, disability status, job title).
  • Help to Grow: Management Programme business information (geographical area of business, Business Turnover, number of employees in business, business sector).

We may also pass your information to third parties for the purposes of completing tasks and delivering services to you on our behalf, for example when we work with a partner to deliver an alumni event; when briefing the facilitator or speaker ahead of an alumni event; or when we contract with a mailing company to send our newsletter.

We use the following third party providers to send our newsletter: Salesforce (Saleforce’s Privacy Information), WordPress (WordPress' Privacy Information) and Campaign Monitor (Campaign Monitor's Privacy Information).

We will not sell your information to third parties.

When we use or work with third party service providers, agents, subcontractors and other associated organisations, we disclose only the personal data that is necessary to deliver and manage the Help to Grow: Management Programme, or to send you our newsletter if you opt-in.

We require all our third party service providers to respect the security of your personal data and to treat it in accordance with the law.

Your Rights

How can you change your preferences for our newsletter or update the data we hold on you?

If you would like to change your preferences about the information we send you, you can. If you want to opt-out of receiving our newsletter, click ‘unsubscribe’ on the emails we send you with it.  If your details have changed you can ask us to update the records we hold about you. To do so, please contact us by emailing enquiries@charteredabs.org or call +44 020 7236 7678.

How can you access the personal data we hold about you?

You have a right to request copies of the personal data we hold about you. This is commonly referred to as a Subject Access Request. There are some exemptions to this right, which means you may not always receive copies of all the information we process. You can read more about this right here. If you would like to make a Subject Access Request, please write to us at enquiries@charteredabs.org, and put ‘Subject Access Request’ in the subject field. BEIS is required to respond to your Subject Access Request within 1 month of your request. However, if your request is complex or we receive a number of requests from you, BEIS reserves the right to extend the time for response by a further two months. We or BEIS would confirm this with you in writing.

You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we or BEIS may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, BEIS could refuse to comply with your request in these circumstances.

What other rights do you have in respect of the data we hold about you?

You may:

  • 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.
  • 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 the 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.
  • 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • 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:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

How do we use cookies and how can you control them?

Most websites you visit will use cookies in order to improve your user experience by enabling that website to ‘remember’ you, please see this link to our Cookies Policy.

Third Party Links

This Privacy Notice may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party links or notices and are not responsible for their privacy statements.

How to contact us or to make a complaint?

If you have any questions about our work with the Help to Grow: Management Programme or if you would like to make a complaint, please contact us by emailing enquiries@charteredabs.org or call +44 020 7236 7678.

If you have any questions about this Privacy Notice or our data protection practices, or if you are not happy with the way that we have handled your personal information, you can contact our data privacy manager:

Ramin Bokaian, Ramin.Bokaian@charteredabs.org, Chartered Association of Business Schools, 3rd Floor, 40 Queen Street, London, EC4R 1DD. Tel: 020 7236 7678.

BEIS’s Data Protection Officer can be contacted:

By Post at: BEIS Data Protection Officer, Department for Business, Energy and Industrial Strategy, 151 Buckingham Palace Road, London SW1W 9SZ.

By Email to: dataprotection@beis.gov.uk.

If you are still not happy, you have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

More detail can be found https://ico.org.uk.