quickabilities

We respect your privacy and are committed to protecting your Personal Data. This privacy policy will inform you as to how we look after your Personal Data and tell you about your privacy rights and how the law protects you.

Personal data, or personal information, means any information about an individual from which that person can be identified (“Personal Data”).

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Comsensus collects and processes your Personal Data.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER
Comsensus Limited is a company registered in England and Wales under company number 10768784 whose registered address is at The White Building, 33 Kings Road, Reading, England, RG1 3AR (collectively referred to as "Comsensus", "we", "us" or "our" in this privacy policy). Comsensus is the controller and responsible for your Personal Data. Please note that we also own the Quickabilities brand and any website or commercial activities which operate under this name. Accordingly, all such activities fall under this Privacy Policy.

CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact using the following details:

Email: [email protected]

Telephone: +44 (0)118 991 9123

Postal address: The White Building, 33 Kings Road, Reading, England, RG1 3AR

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on [8 November 2022].

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.

THIRD-PARTY LINKS
Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website(s), we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Please note that this policy relates to the processing of your Personal Data. It does not cover data where your identity has been removed (“Anonymised Data”).

We may collect, use, store and transfer different kinds of Personal Data (“Data”) about you which we have grouped together as follows:

• Identity Data includes title, first name, last name, username or similar identifier.
• Contact Data includes your email address and telephone numbers.
• Employment Data includes your work email address, telephone number, employer and job title.
• Profile Data includes your username and password used for online sign-in to our website(s), to amend your preferences and to provide feedback.
• Programme Data includes data which is collected that relates to the programmes you attend. This includes but is not limited to: surveys on objectives; responses to online quizzes; and submitted assignments. We may use this data to approve or certify the successful completion of our programme.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website(s).
• Usage Data includes information about how you use our website(s), and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that Data in this context includes data stored both electronically and in hard-copy.

We also collect, use and share Aggregated Data to report back on our programmes. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity and will therefore become Anonymised Data. However, if this data is no longer anonymised, and it can be used to either directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

There may be occasions when we need to collect Special Categories of Personal Data about you in order to better adapt our services to meet your needs (this includes details about your health and genetic data), for example, if you have a disability and require subtitles to be included in our webinars. In such circumstances, we will obtain your explicit consent for the processing of such data.

We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect Personal Data by law, or under the terms of a contract, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including:

• obtaining information when you submit assignments or complete modules via our online sites;
• when you contact us;
• by storing of the results from training we provide;
  when you complete our user surveys. We use these to help us to ascertain your
• objectives when using the programme or client platform and to obtain feedback;
• conducting bulk sign-in for our clients, when they provide information to us to create an account for you in order to use and access our services and our online sites.

As you interact with our website(s), we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into (e.g. if we process your data because your employer has provided it so we can invite you to sign-up to receive our services);
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• Where we rely on your consent.

Generally, we do not rely on consent as a legal basis for processing your Personal Data (apart from when processing Special Category Data). You can withdraw your consent at any time by contacting us.

MARKETING
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or received services from us and you have not opted out of receiving that marketing.

The kind of marketing activities which we will use your data for include our business-to-business targeting of prospective clients.

THIRD-PARTY MARKETING
We do not currently share your data with any third parties for marketing purposes and if we choose to do so in the future, we will only do so if your provide your express opt-in consent beforehand.

OPTING OUT
You can ask us to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us, through a service experience or other transaction.

COOKIES
A cookie is a small amount of data that is stored locally on a user’s computer or mobile device from a website. Each website can send its own cookie to your browser if your browser’s preferences allow it. Many websites do this whenever a user visits their website in order to report on website traffic, store users preferences or allow a user to login to a system. Your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.

Please note that we may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website(s). They include, for example, cookies that enable you to log into secure areas of our website(s) or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website(s) when they are using it. This helps us to improve the way our website(s) work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website(s). This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website(s), the pages you have visited and the links you have followed. We will use this information to make our website(s) and the advertising displayed on it more relevant to your interests.

The cookies these sites set do not store any sensitive data (such as credit card information or passwords).

You can set your browser to refuse all or some browser cookies, or to alert you when website(s)s set or access cookies. If you disable or refuse cookies, please note that some parts of this website(s) may become inaccessible or not function properly.

CHANGE OF PURPOSE
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 require 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.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your Personal Data with the parties set out below for the purposes set out in this policy.

• External Third Parties such as:
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Companies such as third party Software as a Service (“SaaS”) providers who supply their services to us
  • Google Analytics to assess use of our site and assist in making necessary improvements.
• 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.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

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

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contract clauses which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties 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 and will notify you and any applicable regulator of a breach where we are legally required to do so.

We store your data on our office computers and on our OneDrive. We ensure that these are secured through using such programmes as Microsoft Defender and Microsoft Cloud Server.

Please note that we sometimes store data in certain third-party locations. If you wish to discuss this further, please contact us privately using the details provided.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Please note that, following completion of our contract, we may keep some examples of your work to help improve the Services we offer. We will take steps to ensure that this has been redacted and anonymised so that you cannot be identified. As such, this data shall no longer be subject to this Privacy Policy.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data; the potential risk of harm from unauthorised use or disclosure of your Personal Data; the purposes for which we process your Personal Data; whether we can achieve those purposes through other means; any guidance we may receive from clients; and the applicable legal, regulatory, tax, accounting or other requirements.

Please note that we will delete your user account upon request. If we do receive such a request, and you want to re-join, we may not be able to identify your previous user experiences; programmes you have taken; any other historic user related activity; nor will we be able to retrieve such information - even if you ask us to do so.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These include:

• Request access to your Personal Data.
• Request correction of your Personal Data.
• Request erasure of your Personal Data.
• Object to the processing of your Personal Data.
• Request restriction of processing your Personal Data.
• Request transfer of your Personal Data.
• Right to withdraw consent.

Please see the Glossary below for further information on each of these rights.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

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 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.

Please also note that if this right is exercised, it may limit our ability to competently perform the contract. In some cases, the individual who has made the request may not be able to participate in the training we offer.

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. You also have the right to object where we are processing your Personal Data for direct marketing purposes. 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.

APPENDIX

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

*Please note that “Performance of Contract” covers both the client organisation we have contracted with and the specific individual to whom the data relates.