Financial Services Training Partners LLP Privacy Notice
This privacy notice is published on 25/4/2018
Who are we?
Financial Services Training Partners (FSTP) is a company that provides training and consultancy services. Our registered office address is at Acorn House, 393 Midsummer Boulevard, Milton Keynes, England, MK93HP.
Our Registered No OC372081.
FSTP is the data controller and our Data Protection Officer can be contacted by emailing: email@example.com.
16 or Under
We are concerned with protecting the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
When do we collect personal data about you?
- When you register or enquire about any service provided by FSTP.
- When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
- We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and FSTP.
Why do we collect personal data?
We collect and use personal data mainly to perform direct marketing, sales and customer service. We also collect data about suppliers, partners and persons seeking employment with our company.
How do we collect personal data?
We collect your data when you:
- Fill and submit account registration form on our website.
- Fill and submit newsletter subscription form on our website.
- Fill and submit personal and delivery information when buying products on our site.
- Initiate contact through chat, contact form, telephone call or other means of direct communication.
What we use your personal data for? 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 the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal obligation
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver any requested services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time 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 as a result of service purchase, service experience or other transactions.
What type of personal data is collected?
We collect the following information name, phone number, title and email address, in addition to your job title, company’s name and contact information. When a service is purchased we will also collect payment details from either the company or the individual. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.
If you upload photos or videos, add posts or comments, etc. on our website, the information can be read by anyone with access to the site and used for purposes over which we or you have no control. Therefore, FSTP is not responsible for any information you submit to the website in the public domain.
If you apply for a job at FSTP, we will collect the data you provide during the application process.
FSTP does not collect or process any special categories of personal data, (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
International Transfers of Data
We do not share your data outside of the EEA. However should we engage any external third parties (as set out below) in the future that are based outside of the EEA, their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
Your rights to your personal data
You have the following rights with respect to your personal data:
- The right to request a copy of your personal data that FSTP holds about you.
- You can access this functionality if you are a student by going to https://www.fstp.co.uk/wp-admin/profile.php and clicking the Download button. If you are not a student you can request this information by sending a request to firstname.lastname@example.org.
- The right to request that FSTP corrects your personal data if inaccurate or out of date.
- If are a student and have a registered profile on our website, you may update your user profile by logging in and changing it on https://www.fstp.co.uk/wp-admin/profile.php If you are not a student you can request this information by sending a request to email@example.com.
- The right to request that your personal data is deleted when it is no longer necessary for FSTP to retain such data.
- If you are a student you can access this functionality by going to https://www.fstp.co.uk/wp-admin/profile.php and clicking the Forget button. If you are not a student you can request this information by sending a request to firstname.lastname@example.org.
- The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
- If you want to withdraw your consent to e-marketing, please make use of the unsubscribe link included in our communication. Please note that you may still receive system messages and administrative communications from us, such as system messages and notifications about your account activities.
- The right to request that FSTP provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
- You can send this query to email@example.com.
- The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
- The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
- You can send this query to firstname.lastname@example.org.
Any query about your Privacy Rights should be sent to email@example.com.
This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.
For further information visit http://www.aboutcookies.org or http://www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
Do we share your data with anyone?
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:
Divert Digital Ltd
Mijireh is a secure hosted payment page service that offers a PCI Compliant and secure credit card payment form that allows you to integrate our website with a large number of payment gateways around the world. They value and respect your privacy and will take all reasonable steps to protect your personal information.
Your data which is encrypted is as follows:
- personal data (address data, telephone number, etc.)
- login data (username and password)
- all methods of payment selected, credit card and bank account
LinkedIn and Twitter are social networks. Integration of social network components allows them to track which page on our site you are accessing, but only if you are logged in to their account. If you do not wish this, please log out of your social network accounts before browsing the web.
When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
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 instructionsNo 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.
Your right to complain with a supervisory authority
If you are unhappy with the way in which your personal data has been processed, you have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issueshttps://ico.org.uk/concerns/.We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at firstname.lastname@example.org .
Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
Modern Slavery Statement
Introduction from Partners of FSTP LLP
Modern slavery and human trafficking is abhorrent to all honest and decently minded business owners. The partners of FSTP feel very strongly that we must take responsibility and be alert to the risks, however small, in the business and the wider supply chain of businesses we are involved with.
This statement is aligned to the requirements of section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.
FSTP is Limited Liability Partnerships providing training and consultancy services to businesses requiring our support. Our primary client base consists of UK Financial services regulated firms however our RoATP status for the provision of Apprenticeships affords us the opportunity to work with businesses that are not FS regulated and thus widens the contact and potential service provision to firms predominantly in the UK.
FSTP’s 3 partners employ 5 FTE staff and contracts with vetted Consultants to deliver services.
Through our Code of Conduct we define a high standard of ethical behaviour for all of those who represent FSTP and our whistleblowing arrangements encourage all employees and contractors to report any concerns related to activities or the supply chains including risk of slavery or human trafficking.
We are committed to preventing acts of modern slavery and human trafficking within our business and we expect our supply chain to adopt a similar approach and support a zero-tolerance approach to modern slavery.
We expect our suppliers and client firms to ensure:
- Living wage is paid
- No forced or child labour
- Freedom of association
- Health and safety arrangements are sufficient to protect all employees and contractors in their working environment
Where required a Modern Slavery Statement is published and freely accessible