This Policy explains when and why we collect personal information from our students and customers, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes.
Any questions regarding this Policy and our privacy practices should be sent by email to firstname.lastname@example.org or by calling 01953 609752.
Who we are
We are Swarm and we are not for personal profit national training provider in apprenticeships and professional development. Our registered company number is 08430648 and our registered address is Turnpike Business Centre, London Road, Wymondham, Norfolk, NR18 9SS
How do we collect information from you?
Swarm Apprenticeships Ltd will only use your personal information for purposes which are required to support the learning we offer. We process personal information about the Students we train either directly or sometimes on behalf of other organisations as an approved apprenticeship subcontractor. Under data protection laws we are usually the "data controller" of personal information held about students.
What we Collect
We may collect the following information:
- Information contained within the enrollment application form completed at the start of the programme of learning by us or the lead provider we work on behalf of
- Data on your use of our IT and software systems
- Communications with your tutors, assessor, their managers and with our Head Office
During the learning journey with Swarm, the data we collect and process about you the student can sometimes be deemed as very sensitive. This data include information revealing racial sensitive or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health, and information concerning a person's sex life or sexual orientation. This information is particularly sensitive, and we will therefore only collect this information where it is necessary to complete your learning journey with Swarm. We will ensure it is only seen by those who must see it; and will keep it secure.
What we do with the Information we gather and how long we keep it
We gather information to comply with our contractual obligations in supporting you on your learning journey with us. It is also used to comply with the legal obligations in relation to ESFA funding rules.
This data is then used to:
- Shape the training to give you the best learning experience that’s bespoke to you
- Adhere to the ESFA funding rules and regulations and calculate funding for your learning
- Limited personal information is provided to Awarding Bodies to allow us or our partner providers to register you with them to undertake any units or qualifications that are required as part of your Apprenticeship or learning programme
- Register and enable you to use learning software and gather evidence
- Limited personal information is provided to End Point Assessment Organisations in order to register you for the services they provide in relation to the End Point Assessment required to complete an Apprenticeship Standard
We will process this information for the duration of your training with us and in line with the document retention periods as defined by the Education and Skills Funding Agency (ESFA) and European Social Fund (ESF) who fund your Apprenticeship or learning programme. ESFA funding rules stipulate that your information is retained for 6 years after you complete your training with us. The retention period stipulated by ESF Funding is also dependent on when you complete your training; any students receiving training between 1st August 2014 and 31st July 2020 will require information to be retained until at least 31st December 2030.
Where the personal information is "very sensitive" (as described above), or relates to criminal convictions, the commission/alleged commission of criminal offences, or criminal proceedings, we will only process this information where:
- It is required as part of official documentation as detailed by the ESFA
- It will allow us to tailor your learning to meet any specific needs or requirements that you may have
- The personal information has been given with your freely given consent;
- It is necessary in relation to legal claims;
- It is necessary for reasons of substantial public interest. UK law places our monitoring of diversity and equality of opportunity in this category providing certain safeguards are in place;
- It is necessary to protect your life or the life of someone else and you are physically or legally incapable of giving consent.
There will also be circumstances where we will ask for your freely-given, specific, informed and clear consent to process certain types of information about you if it is not already covered by one of the lawful bases set out above.
Who has access to your information?
The personal information we expect to collect about you may be provided directly to us by you (whether that is information we already hold through the enrollment process, or information you provide to us after that); provided by a third party such as, for example, by the provider we are subcontracting for or your employer.
We use other companies for certain functions and in limited circumstances.
Information about you may be collected from and provided to and used by the following organisations:
- Our delivery Partners who we subcontract for (Qube Learning)
- The Education and Skills Funding Agency (ESFA), to fund your Apprenticeship or learning programme
- Other organisations whose involvement is mandatory in the provision of Apprenticeship or learning programme, such as Ofsted and any auditing instigated by the ESFA
- Quals Direct, the E Portfolio software we use to track your Apprenticeship or learning programme
- End Point Assessment Organisations – the organisations who deliver the final assessment which makes up Apprenticeship Standards. These might include but not be limited to: City and Guilds, ILM, Highfield, Babcock, NCFE, Innovate
- Awarding Bodies – the organisations who certificate any units or qualifications that form part of your Apprentice. These might include but not be limited to: City and Guilds, ILM, Pearsons, ICQ, BSC, NCFE, SFEDI, AAT
- Internal Audit – An external company to carry out an audit on a sample of our Students’ files to verify our compliance with ESFA funding rules and regulations
Any organisation not listed above who provides services or software which is relevant/required for the completion of your Apprenticeship or learning programme will not contact you personally for marketing purposes by email, phone or text message unless you have given your prior consent.
We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email to email@example.com or by calling 01953 609752.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
Controlling your Personal Information
You may request details of personal information which we hold about you under the Data Protection Act 1998.
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