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Privacy Policy

This is the privacy policy for information submitted to or held by Policy Hubs Ltd trading as Policy Hub Scotland.

ABOUT US (‘The Data Controller’)

This website is operated by Policy Hubs Ltd.
Company registration No: SC500456

Address: Office One, 1 Coldbath Square, Farringdon, London, EC1R 5HL
Registered office: 21 Young Street, Edinburgh, Scotland, EH2 4HU
t: 0131 344 4611
e: enquiries@policyhubscotland.co.uk

Policy Hubs is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

We are registered with the Information Commissioner under the Data Protection Act 1998. Policy Hubs Ltd: registration number ZA121101

 

YOUR DATA MATTERS

This policy outlines how we obtain, process, store, secure and dispose of the data we use.

In accordance with the General Data Protection Regulation (GDPR), if you have any specific questions on how (or whether) we use your personal data, you can request access to the information we hold about you, including the data you have provided to us. If you so wish, you can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal or security purposes.

You may request the following information free of charge:

  • What personal information we hold about you
  • Why this information is being processed
  • Who has access to this personal information
  • How this personal information is being used in automated decisions
  • What processes are using this information

 

Requests can be submitted via the contact details listed above and will be responded to, in full, within 30 days.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

What we collect and what we do with the information we gather

Our Online Learning Courses

When purchasing an online learning course from us we will ask the ‘booking contact’ to provide information on our course ‘learner(s)’ including their first name, last name, job title, organisation’s address, email address and telephone number. This information will be used to:

  • Create an online profile for the ‘learner(s)’ on the Policy Hubs site, or;
  • Assign the purchased course to an existing learner profile

 

We generally store information about users for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. This includes the ‘learner’s’ name, email address, billing address and telephone number.

We may collect and use ‘Learner’ personal information for the following purposes:

  • To improve customer service
    The information provided helps us respond to customer service requests and support needs more efficiently.
  • To personalize user experience
    We may use information to monitor the course progression of a ‘Learner’, providing them with the flexibility to leave and rejoin the course at any time and immediately see where they left off and which steps they have already completed.
    We may also use information to update the ‘Learner’s’ individual Learner profile page with any new courses they have registered for.
  • To improve our Site
    We may use feedback provided to improve our training products and services.

 

Our mailing lists

We maintain and update our mailing lists on a regular basis to ensure we provide recipients with targeted information on our training that we think may be of interest, using the email address provided to us.

Our mailing lists contain the following information:

  • The Recipient’s First Name
  • Last Name
  • Job title
  • Organisation
  • Work email address (In a small number of cases, subscribers will prefer to be contacted via a personal email address. In which case, that personal email address will be included in the mailing list)

 

You can join our mailing list, via the ‘Join Our Mailing List’

Subscribers can also update their mailing preferences via the webpage – ‘Update Your Preferences’

Subscribers can request to have their details removed from our mailing list(s) at any time by getting in touch with us via the contact details listed above and all emails sent to our mailing lists include instructions on how recipients can ‘unsubscribe’ from future mailings, should they wish to do so.

Our training registration processes

As part of the registration for our online learning courses and training events, we will request certain information in order that we can deliver a quality service to our ‘learners’ and ‘delegates’ and ensure our booking and invoicing processes are as efficient and customer-friendly as possible.

When registering for our training, we will request the following information –

For the booking contact:

  • First Name
  • Last Name
  • Job title
  • Organisation
  • Business Address (If purchasing the training as an individual, customers will list their personal home address instead. In which case, that address will be added to our training register)
  • Work email address (In a small number of cases, customers will prefer to be contacted via a personal email address. In which case, that personal email address will be added to our training register)
  • Work telephone number (In a small number of cases, customers will prefer to be contacted via a personal telephone number or mobile number. In which case, that personal number will be added to our training register)

 

Reason for requesting this information: This is to ensure we can process the booking and confirm the learner or delegate has been registered for the training. It also ensures we have a main point of contact for the booking.

 

For the ‘learner(s) or ‘delegate(s)’:

  • First Name
  • Last Name
  • Job title
  • Organisation
  • Work email address (In a small number of cases, customers will prefer to be contacted via a personal email address. In which case, that personal email address will be added to our training register)
  • Work telephone number (In a small number of cases, customers will prefer to be contacted via a personal telephone number or mobile number. In which case, that personal number will be added to our training register)
  • Dietary requirements
  • Accessibility requirements

 

Reason for requesting this information: This is to ensure we can provide each ‘learner’ or ‘delegate’ with updates on the training they have registered for; send them the relevant joining information (including details on the location, timings and catering arrangements for an event); and, where appropriate, to ensure we can provide them with the necessary tailored services and support to enable them to fully access and enjoy the training.

 

For the billing contact:

  • First Name
  • Last Name
  • Job title
  • Organisation
  • Business Address (If attending the event as an individual, customers will list their personal home address instead. In which case, that address will be added to our training register)
  • Work email address (In a small number of cases, customers will prefer to be contacted via a personal email address. In which case, that personal email address will be added to our training register)
  • Work telephone number (In a small number of cases, customers will prefer to be contacted via a personal telephone number or mobile number. In which case, that personal number will be added to our training register)
  • Business Purchase Order number (if appropriate)

 

Reason for requesting this information: This is to ensure we can liaise with the appropriate individuals / departments regarding the invoicing and payment for the booking.

 

As part of our event management, we will prepare a delegate list and name badges for each of our events. These will include each delegate’s name, job title and organisation. It will not include any contact details. If you have booked to attend an event and do not wish your name to be included in the delegate list or on a name badge, please let us know in writing at least 7 days prior to the event.

For all our training, we will encourage learner and delegate feedback to help us improve what we do and how we do it. Such feedback may, from time to time, be used across the Hub or in future promotional materials. If you do not wish your comments to be attributed to you, please do not write your name and details on the feedback form or tick the relevant box.

As part of our marketing activities – and as part of our attempts to create wider policy conversations – we may, from time to time, take photographs and videos at our events which will appear across the Hub or in future promotional materials. As a result, your attendance at the event may result in you being featured in such photographs or videos. Unless you notify us of your objection to this in advance, your consent will be implied. We will, of course, happily remove and/or cease using any images in which you are featured should you request us to do so.

In addition to the reasons listed above, we may use your information to better understand your needs and provide you with a better service, and in particular for the following reasons:

  • internal record keeping
  • we may use the information to improve our products and services
  • we may periodically send promotional emails about new training, special offers or other information which we think you may find interesting using the email address which you have provided
  • from time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.

 

We will not share data (including any personal information or contact details) for marketing purposes with third parties.

We will not use your personal information to make automated decisions.

Sensitive Data

Policy Hubs does not request, process or hold any of the following sensitive data:

  • Race or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union memberships (unless an individual books to attend one of our events in his or her ‘Trade union’ capacity)
  • Genetic or biometric data
  • Health or mortality
  • Date of birth
  • Sexual orientation

Controlling and managing your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you complete an event or course registration form on the website, make sure the relevant box remains checked or unchecked, indicating that you do or do not want the information to be used by us for direct marketing purposes
  • you can update your details and subscription preferences or unsubscribe at any time via our website or by contacting us by mail, phone or email.
  • you can control and edit the details on your Learner profile page, by clicking ‘edit profile’ when logged on to the site

 

We will not sell, distribute or lease your personal information to third parties unless we are required by law to do so. We may use your personal information to send you promotional offers on behalf of third parties which we think you may find interesting, only when you have indicated a preference to receive such information.

How long is your data held?

Any personal data you give us will be retained by us for as long as it’s needed to perform its function. Our ‘mailing list’ data is held permanently unless you unsubscribe. We regularly review the ‘training register’ data we hold to ensure it is still necessary.

If you leave a comment on our online content, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website, we also store the personal information they provide in their learner profile. All learners can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable and reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Our web site is secured with an SSL Certificate and transactions on the site are protected by SSL encryption. Our off-line databases and email accounts are password protected, as are our individual training registers.

Whilst we take every effort to ensure your information is secure, no representation or guarantee can be given that the site is free from cyber infection. Neither Policy Hubs, nor its employees, shall be liable for any loss, damage or expense as a result of any access to or use of this site or any site linked to it.

Third Party Access

We do not use third-party services for our web advertising or analytics. In practice, the list of third parties that have the potential to access our customer data uploaded on to their hosting infrastructure is limited to the following:

FreeAgent
Policy Hubs uses an online-bookkeeping software – FreeAgent – to manage our company finances, including our invoicing system. Information that appears on our invoices is also held on our secure FreeAgent account. Data that appears on our invoices includes:

  • Booking organisation
  • Organisation’s address (If undertaking the training as an individual, customers will list their personal home address instead. In which case, that address will be added to our invoice)
  • Delegate or Learner First Name
  • Delegate or Learner Last Name
  • Delegate or Learner Job title
  • Business Purchase Order number (if appropriate)

 

This is a hosting service. FreeAgent does not have permission to use this information for its own commercial purposes. The hosted data resides within a UK-based data centre and is therefore bound by all relevant UK data protection requirements.

Stripe
We accept card payments through Stripe. When processing payments, some user data will be passed to Stripe, including information required to process or support the payment, such as the purchase total and billing information. Please see the Stripe Privacy Policy for more details.

Learndash
Policy Hubs uses Learndash as the basis of our online learning course software. However, all learner details are held securely on our web hosting servers. Learndash does not have access or permission to use this information for its own commercial purposes.

Siteground
Policy Hubs uses a web-hosting and email hosting service provided by Siteground. All data collected through our training registration forms; our online learning courses; or contained within emails or processed via our web comment sections is stored on our web-hosting servers operated by Siteground.

This is a hosting service. Siteground does not have permission to use this information for its own commercial purposes. The hosted data resides within a UK-based data centre and is therefore bound by all relevant UK data protection requirements.

Brevo

Policy Hubs uses the services of Brevo for it’s marketing, transactional and learner update emails. The provider of these services is

Brevo (formerly Sendinblue)
106 Boulevard Haussmann
75008 Paris
France

Brevo is a service provider, whose services include the management and analysis of newsletter mailshots. If you enter data via the ‘Join our Mailing List’ page, this will be stored on the Brevo servers, which are located exclusively in the European Union.

Brevo helps us analyse our marketing and newsletter campaigns. When you open an email that has been sent with Brevo, a file (a web beacon) contained within the email links to the Brevo servers. This allows us to determine whether a newsletter message has been opened and which links in the message have been clicked on, if any. Furthermore, technical information is also collected (e.g. time of opening, IP address, type of browser and operating system). This information cannot be traced back to a specific newsletter recipient. The data is exclusively used for the statistical analysis of our marketing and newsletter campaigns. The results of this analysis can be used to optimise the content of future communications in line with subscriber needs.

If you do not want to be included in the Brevo analysis, you can unsubscribe from our communications at any time. We include an unsubscribe link in every marketing email or course newsletter.

Data is processed on the basis of your consent (in accordance with point (a) of Article 6 (1) of the GDPR). You can revoke your consent at any time by unsubscribing to our emails. The legality of data processing that has already been carried out remains unaffected by your revocation.

The data you have entered for the purpose of subscribing to our emails will be stored by us until you unsubscribe.

Further information about Brevo’s privacy policy can be found at – https://www.brevo.com/legal/privacypolicy/

Who has access to your data?

The following categories of people have access to our customer hosting infrastructure (and therefore, potentially, to our hosted data):

  • Policy Hubs Ltd staff (including our Director, our research and marketing teams and our finance team – including our accountant)
  • Siteground operations technicians
  • Stripe operations technicians
  • Learndash operations technicians
  • FreeAgent operations technicians

 

CONTENT
The content and structure of the website is protected by copyright and all rights are reserved.

The information on this site has been produced in good faith but is for general informational purposes only – it is not instructional. It should not be relied on for any specific purpose and no representation or guarantee is given as regards its accuracy or completeness.

Contributions from trainers on the site are the personal views or opinions of the contributor(s) and do not reflect the opinions or views of, are not endorsed by, and cannot in any way be attributed to Policy Hubs. As such, we shall not take responsibility for any impact or offence caused by this content.

Embedded content, links to other websites and Cookies

Our online learning courses on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that other website.

Our website may also contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

HOW WE USE COOKIES
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

To find out how we use Cookies on this site, visit our Cookies Policy.

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