Learning Performance Training Privacy Policy

Learning Performance Training are committed to respecting your privacy and ensuring that we only communicate with you because we feel that you have a legitimate interest in our services.
We are the UK’s largest and longest standing provider of student workshops, alongside inspirational and supportive sessions for parents and teachers.

This privacy policy explains exactly why and how we contact you, how we collect and store your data, where we find your information, how we work with our partners and what to do if you do not wish to be contacted by us along with information about how we would handle security breaches.

We are fully compliant with the PECR, Data Protection Act 1998, GDPR and are understand the guidance set out by the ICO and DMA. Our lawful basis for processing is ‘legitimate interest’. We will never share your information with any third parties.

Why and how we contact you and our lawful basis for processing.

Why?

The reason for our contact is to make you (schools) aware of our services. We are an educational training provider who have delivered in the marketplace for the past 26 years, we provide accelerated learning and personal development workshops for students, teachers and parents. Our workshops provide benefit to thousands of schools across the UK (we have testimonials, case studies and quantitative data to support this) therefore it is in the best interest of the schools that we inform them of what we can offer their students and staff.

How?

There are 3 steps we take in order to fulfil our criteria:

1. Collect contact information from schools in the UK, so that we can send them direct marketing in the form of emails.

2. Promote our brand to schools, in the hope that they will invite us to deliver our workshops.

3. Ensure that we send excellent presenters to provide outstanding workshops

The direct marketing we carry out is via email or occasionally via post. We do not ‘cold call’ - the only time an individual would hear from us via telephone is if they had showed interest in our services by clicking on our emails, enquiring with us or by meeting the conditions our any third party partners deem as legitimate interest. For further information about our partners, please see the section stating ‘how we work with our partners’.

Lawful basis for processing

We have recently conducted an Information Audit along with a legitimate Interest Assessment to ensure that we are fully compliant with the new rules around personal data.

The DMA, summarising instructions from the GDPR update, states that -

‘You can send individuals a marketing email/text as long as you provide an easy way to opt-out of future communications from you.’ [1]

We operate under a ‘soft opt-in’ policy relating to previous customers, which is approved by the ICO. This means that if you have bought from us in the past, we can assume that you are interested in hearing about our services still.

'The term ‘soft opt-in’ is sometimes used to describe the rule about existing customers. The idea is that if an individual bought something from you recently, gave you their details, and did not opt out of marketing messages, they are probably happy to receive marketing from you about similar products or services even if they haven’t specifically consented. However, you must have given them a clear chance to opt out – both when you first collected their details, and in every message you send.’ [2]

We provide an ‘unsubscribe’ link (which is considered to be an ‘opt out’) at the bottom of all of our marketing emails.

Please refer to the ‘what to do if you do not wish to be contacted by us’ section for information about unsubscribing from our marketing mails and your rights.

How we collect and store your data

The data we collect is readily available in the public domain and can be requested legally in accordance with the Freedom of Information Act 2000. Schools have a legal obligation to update their details on ‘Get information about schools’ under the Education Act 1996. The information we collect is indicated beneath:

School name, contact name, school address, job title, school email address, school phone number.

The ICO defines the contact name and job title as being ‘personal data’ because, ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. [3]

From our understanding, this means that any information we hold which can be directly related back to the person is considered to be ‘personal data’. For example, if we just collected contact names without school name, job title, school email address, school address, school phone number and stored them on our computer systems, it would be very unlikely that the person could be identified.

However, if we were to collect the contact name and school name, it is more likely that the individual could be identified.

We do not hold or store any information about the contacts home address, personal phone number of any special category data, we simply hold information about the contacts role in the school so we can send targeted marketing to them.

We collect this by:

- Externally – we have worked with 2 companies in the past:
- The Education Company (Spirit)
- Sprint Education

We store schools financial information in 2 ways:

We invoice schools electronically which our Financial Support staff only have access to via a secure password.

1) If schools send us a remittance via post, this information is stored in a locked cabinet, which only the Finance Manager has access to, before it is taken to our Accountants.

2) If schools send us remittance via email, the details are stored in a secure folder on our Finance Manager’s computer, which only the Finance Manager has access to.

Where we find your information

We search for schools’ information using these methods:

School websites

School name, contact name, school address, job title, school email address, school phone number

How we work with our partners

We work with The Education Company with the only data being received from them is school name, Contact name, Job title and email address.

We receive this information if the individual has clicked on a link or has responded by email

The agreement we have with Spirit (The Education Company )is that we are provided with access to their “date mining platform which allows us to send Marketing campaigns.

What to do if you do not wish to be contacted by us

All of our emails have an unsubscribe link, please click on this and it will automatically unsubscribe you from any future marketing mail. Alternately, please send an email with the subject line ‘UNSUBSCRIBE’ to holly@learningperformance.com and we will manually unsubscribe you.

You have the right to be informed why we are processing your data and the right to ask to be removed from our marketing emails.

How we would handle security breaches

We do not collect or process any ‘special category data’ (sensitive data) which is defined by the ICO as being related to:

Race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life, sexual orientation

All data we collect is stored on our secure computer systems. 

In accordance with Article 33 of the GDPR:

‘In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons’.[6]

We are confident that a personal data breach would be unlikely to result in a risk to the rights and freedoms of natural persons. Therefore, if a breach occurred, we would be sure to document the breach in alignment with the terms set out on the ICO website:

‘However, if you decide you don’t need to report the breach, you need to be able to justify this decision, so you should document it’.[7]

In the 26 years since our company was founded, we have never experienced a security breach. The impact of a breach on our system would be minimal because the only data which could be stolen is already available in the public domain.

Contact information

For further information about our privacy policy, please contact us via holly@learningperformance.com or write to us at: Learning Performance Training, Old Bank House, 1 High Street, Arundel, West Sussex BN18 9AD

Glossary
‘You’ refers to the customer

‘We’ refers to Learning Performance Training as a company

‘Our workshops’ refers to the personal development and accelerated learning workshops we provide. Details of which can be found on our website – www.learningperformance.com