Privacy Policy

Introduction

The Portsmouth Learning Gateway (PLG) is committed to protecting your personal information when you are using our services. We want our services to be a safe and useful environment for our audience. This notice provides a summary of how we will use information held about you and individuals connected to your setting or school.

We will collect personal information about you through the PLG website(https://www.portsmouthlearninggateway.org.uk) as well as from any personal information you provide to us by phone, SMS, email, in letters, other correspondence and in person.

Our site is managed by a number of data controllers who administer or audit learning and development for Portsmouth City Council (PCC) and its partners. All data controllers have appropriately managed access to relevant information for their area, role and responsibilities.
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Your Account

When you register as a user on our site you are providing us with personal information. As such you should not allow others to access your account:

• DO NOT share your login details with anyone.
• DO NOT use a generic or shared email address that is accessible by multiple people for your PLG account.
• DO NOT write down your login details where others could access them.
• DO use secure and hard to guess passwords

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What information may PLG collect about you, and where is it collected from?

Information that may be collected:

• Title*
• First Name
• Last Name
• Email Address(es)
• Employee Reference
• Telephone number(s)
• Access / Dietary Requirements* • Address
• Job Title*
• Job Role
• Ethnic Origin*
• Disability Status*
• Gender*
• Age Range*

This information will be collected directly from yourself when you register, or from the organisation that you work for.
[* The indicated information is optionally collected if you register your own account - you are not obliged to provide it.]

Where your personal data is supplied to us by your organisation we will only ask for the information necessary to

• Provide user accounts for staff members with appropriate levels of access;
• Organise users into teams defined by the organisation;
• Deliver our services to you.

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Legal basis for collecting and processing your personal data

Where training forms part of the employment contract the data collected is required to manage that employment relationship.
Where there is no requirement to manage a contract then the legal basis will be consent.
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How is your information used by the PLG?

We will only use information about you and individuals connected to your organisation where we have consent or we have another lawful reason for using it.
These reasons include:

• The processing is necessary for a task carried out in the public interest.
• We need to process the information to carry out an agreement we have with you and have received your consent to do so.
• Processing is necessary to provide the service you have asked us to provide.

The reasons we use your information and information relating to individuals connected to your setting include:

• Delivering our services.
• Managing our relationship with you, including (if you choose to be notified) telling you about other courses and training we think may be relevant for you.

PLG representatives may contact you:

• In relation to any service, activity or online content you have signed up for, in order to ensure that PLG can deliver the services, e.g. to notify you of training that is due, to help you reset your password;
• In relation to any correspondence we receive from you or any comment or complaint you make about PLG.
• In relation to any tailored services you are using.
• To update you on any material changes to PLG policies, practices or functionality.

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Will PLG share your personal information with anyone else?

We may share your information and information relating to individuals connected to your setting with others where lawful to do so including where we or they:

• Have a public or legal duty to do so;
• Need to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
• To provide you with services you have requested (e.g. providing a Tutor with a list of attendees to a training event);
• Have asked you or the individuals connected to your setting or school for your permission to share it, and you (or they) have agreed;

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Which other PLG users will be able to access data about me?

Your manager(s) or nominated supervisor(s) will be able to access data held about you to enable them to:

• Monitor training done by you;
• Update your contact details on your behalf;
• Authorise training attendance for you;
• Book places on training events on your behalf.

PLG will automatically notify the appropriate manager when:

• you specify their team when you register with PLG;
• mandatory training is due;
• you book a place on an event that requires manager's authorisation.

NOTE: Managers cannot access your Age, Ethnic Origin, Gender, Disability Status, Access or Dietary Requirements.

Event tutors will be provided with paper event registers. These will include the following personal data about you:

• Your Name.
• Your Team.
• Your Job Role.
• Access / Dietary requirements.
• Your signature (you will be asked to sign the sheet to indicate your attendance).

Data controllers will be able to access your data to:

• Verify, authorise, unlock or reset your access to PLG.
• Modify your data to ensure it is kept up to date and secure.
• Generate training reports for your manager(s) or for auditing purposes
• Provide appropriate managers access to your details (described above)
• Record your attendance on training events. (Paper copies of event registers will be securely disposed of once your attendance has been recorded).
• Appropriately respond to queries or correspondence from you.

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How long will data be held about you?

Emails and Correspondence:

Emails and other correspondence will be retained only for as long as is necessary and then deleted or otherwise securely disposed of.
Correspondence will be retained in order to:

• answer a query
• meet a request, or
• resolve an issue described therein.
• Provide evidence of completion of an online course

Event Registers

Event registers will be retained for as long as is reasonable necessary to record your attendance on a training event then securely disposed of.

Training records for PCC staff:

Training records for PCC staff will be retained for the following time periods:

• Children's Social Care Related courses will be retained for 25 years after the date the member of staff leaves PCC permanently.
• All other training records will be retained for 6 years after the date the member of staff leaves PCC permanently.

After this time training records will be anonymised or destroyed.

Training Records for users from other organisations

If you inform us that you have left your organisation through which you gained access to PLG we will end your registration with PLG. If your account is left inactive for 13 months we will assume that your access is no longer required and end your registration with PLG.
Thereafter:

• Children's Social Care Related courses will be retained for 25 years after the date of the end of your registration.
• All other training records will be retained for 6 years after the date of the end of your registration.

After this time training records will be anonymised or destroyed.
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Your rights

Your rights are protected under the Data Protection Act 2018.

You have the right to request a copy of the information that PLG holds about you.
If you would like a copy of some or all of your personal information please contact learninganddevelopment@portsmouthcc.gov.uk and we will be happy to provide it.

You have the right to ask for your training records in a portable format
If you would like a copy of your training records please contact learninganddevelopment@portsmouthcc.gov.uk and we will be happy to provide a copy. 

You have the right to ask us to correct or remove data PLG holds about you
If you think the data we hold about you is inaccurate please contact learninganddevelopment@portsmouthcc.gov.uk with details and, where possible, we will correct those details for you, or assist you to update your information.

You have the right to object to how your data is being used and ask us to stop.
If you believe we are continuing to use your data for illegitimate reasons or would like to object to how we use your data please contact learninganddevelopment@portsmouthcc.gov.uk.

For a full list of your rights under the Act please visit the ICO website.

Objections and requests under the Act may also be directed to Portsmouth City Council's Data Protection Officer at:
Data Protection Officer, Portsmouth City Council, Civic Offices, Portsmouth, PO1 2AL
Email: DataProtection@portsmouthcc.gov.uk
Telephone: 023 9268 8482

For independent advice about data protection, privacy and sharing issues, you can contact the Information Commissioner’s Office (ICO) at:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (if you prefer to use a national rate number).
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Data Security

How does PCC protect your data?

Portsmouth City Council takes the security of your data seriously. The organisation has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties, Where Portsmouth City Council engages third parties to process personal data on its behalf, they do so on the basis of a data sharing agreement, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Portsmouth City Council Data Protection Privacy Notice can be found here:
https://www.portsmouth.gov.uk/ext/your-council/transparency/data-protection-privacy-notice

How does PLG protect your data?

PLG (Portsmouth Learning Gateway) is hosted by WebBased Ltd in a secure cloud environment that is solely administrated/managed by the appropriate PCC managed staff for the purpose of maintaining/updating the system and the content it produces.
WebBased Ltd. Privacy Policy can be found here:
https://www.webbased.co.uk/privacy-policy/

The Portsmouth Learning Gateway uses the following systems and practices to keep personal data secure:

• Centrally managed and regularly reviewed access
• Mandatory password protection for all users (using a 1-Way Hash with system generated salt)
• Wildcard SSL (Secure Sockets Layer) certificate
• HTTPS (Hyper Text Transfer Protocol Secure)
• SQL injection protection

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