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PRIVACY NOTICE
CLIENTS & DELEGATES

Data Controller: Neway Training Solutions, Kelvin House, RTC Business Park, London Road, Derby DE24 8UP

Data Protection Officer: Not required

Data Controller: Lisa Stevenson (01332 360033)

Neway Training Solutions collects and processes personal data relating to its delegates and clients to manage compliance with its statutory obligations including all safety aspects. Neway Training Solutions is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.  The lawful basis for processing will be either via consent or legitimate interest.

What information does Neway Training Solutions collect?

Neway Training Solutions collects and processes a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number, date of birth and gender;
  • details of your bank account (for refunds only);
  • national insurance number;
  • information about your emergency contacts;
  • information about your nationality and entitlement to work in the UK;
  • information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments; and
  • equal opportunities monitoring information including information about your ethnic origin, sexual orientation and religion or belief.

Neway Training Solutions collects this information in a variety of ways.  For example, data might be collected through information provided by you such as client enquiry form, sponsor forms attendance registers, Sentinel records, course contract information, obtained from your passport or other identity documents such as your driving licence or birth certificate; from forms completed by you at the start of or during attendance at a training/assessment event; from correspondence with you; or through meetings or other assessments.

In some cases, Neway Training Solutions may collect personal information about you from third parties, such as Sentinel, employer and sponsor.

Data will be stored in hard copy course files and in Neway Training Solutions’ IT systems.

Why does Neway Training Solutions process personal data?

Neway Training Solutions needs to process data to comply with Rail Infrastructure Managers requirements (e.g. Network Rail, TFL), including but not limited to Sentinel Scheme Rules, RTAS Rules and NSAR accreditation. 

In some cases, Neway Training Solutions needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check delegate’s medical records and proof of identity e.g. National Insurance, Date of Birth, Passport, Driving Licence.

Processing delegate data allows Neway Training Solutions to:

  • maintain a record of competency on Sentinel;
  • maintain a record of training and assessment for other safety purposes e.g. technical competencies;
  • respond to and defend against legal claims.

Some special categories of personal data, such as information about health or medical conditions, are processed to maintain a record of competency on Sentinel.

Emergency contact details are retained on paper record for the duration of the training event only.  This information is not processed and is securely destroyed at the end of the event.

Where the organisation processes other special categories of personal data, such as information about ethnic origin, sexual orientation or religion or belief, this is done for the purposes of equal opportunities monitoring. This is to carry out its obligations and exercise specific rights in relation to compliance with Network Rail Rules.   Provision of this data is optional and consent is implied if provided by delegates.

Who has access to data?

Your information will be processed by employees of Neway Training Solutions.

Neway Training Solutions shares your data with third parties in order to comply with:

  • Sentinel Scheme Rules
  • NSAR and Network Rail – to comply with RTAS Rules
  • Employers/Sponsors – to comply with Sentinel Scheme Rules
  • Any third party with a legitimate interest, regarding proof of competency to meet safety legal obligations or investigations e.g. ORR, HSE.
  • Clients or their representatives e.g. training assessment results
  • A person may request a copy of the data and Neway Training Solutions Ltd must respond within 30 days.

Neway Training Solutions will not transfer your data to countries outside the European Economic Area unless requested by the individual, their employer or sponsor.

How does Neway Training Solutions protect data?

Neway Training Solutions takes the security of your data seriously. Neway Training Solutions 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.  The Training Management system has password access limited to the employees of Neway Training Solutions Ltd.  Paper records are kept in a locked cupboard with access to keys controlled. 

For how long does Neway Training Solutions keep data?

Neway Training Solutions will hold your personal data for a minimum of seven years. After this period paper records are securely destroyed.

Emergency contact details are retained on paper record for the duration of the training event only.  This information is not processed and is securely destroyed at the end of the event.

IT databases are also deleted after this period.

Your rights

As a data subject, you have a number of rights. You can:

  • request access your data to verify the lawfulness of the processing;
  • require Neway Training Solutions to change incorrect or incomplete data;
  • require Neway Training Solutions to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where Neway Training Solutions is relying on its legitimate interests as the legal ground for processing.  This is subject to compliance with Sentinel Scheme Rules.

If you would like to exercise any of these rights, please contact Lisa Stevenson in writing at the address detailed on the last page of this document.

A copy of the data will be provided free of charge unless your request is unfounded, excessive or repetitive.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You have some obligations under your Sentinel Scheme Sponsorship to provide Neway Training Solutions with information. 

Neway Training Solutions may not be able to provide evidence of competence for your training event.

Changes to this privacy notice

This privacy notice is kept under regular review and was last updated on 16th March 2021.

Further Information

If you have any questions which you feel have not been covered by this Privacy Notice, please do not hesitate to email us or write to:

Lisa Stevenson
Kelvin House
RTC Business Park
London Road
Derby DE24 8UP

[email protected]