Privacy and Cookies Policy

Introduction

Effective Date: March 2024

Welcome to The CPD Certification Service Limited Privacy and Cookies Policy (“Privacy Policy”).

The CPD Certification Service Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy sets out how we look after your personal data when you visit our website and tells you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy and Cookies Policy

This Privacy Policy aims to give you information on how The CPD Certification Service Limited collects and processes your personal data including any data you may provide via our website (www.cpduk.co.uk) when you purchase our certification services (through our website or by getting in contact with us directly), when you register with us as a member or when you otherwise contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy carefully together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware and understand our practices regarding how and why we are using your personal data and how we keep it secure. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Controller

The CPD Certification Service Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this Privacy Policy). The CPD Certification Service Limited (company number 03606693) is a company registered in England and Wales, the registered office address of which is at Boston House, 69-75 Boston Manor Road, Brentford, London, TW8 9JJ. We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number ZA336789.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the contact details set out below.

Contact details

Full name of legal entity: The CPD Certification Service Limited

Email: privacy@cpduk.co.uk

Postal address: The Data Privacy Manager, The CPD Certification Service Limited, Boston House, 69-75 Boston Manor Road, Brentford, London, TW8 9JJ

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, always appreciate the chance to deal with your concerns before you approach the ICO so please contact us using the details above so that we can try to help you in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review and we may update and amend this Privacy Policy from time to time and any changes will be posted on our website. We therefore recommend that you check this page from time to time to take notice of any updates or changes to our Privacy Policy. In relation to material changes to this Privacy Policy and where we think it appropriate, we will take steps to inform you via appropriate means. The version of this Privacy Policy was last updated on the Effective Date stated at the beginning of this Privacy Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us and let us know if the personal information that we hold about you needs to be corrected or updated.

Third-party websites and links

Our website contains links to and from third-party websites including of our clients, partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and if you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these privacy policies or the data they may collect or share about you. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (which is called anonymous data).

We may collect, use, store, transfer and process different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, postal address, email address and telephone numbers.
Financial Data includes payment card details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and geographic location, preferred language (used to display our website), browser plug-in types and versions, operating system and platform, use of cookies or other devices to store and sometimes track information about you including device type (unique device identifiers) and device screen size (more details on our use of cookies is set out in the Cookies section below) and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, professional qualifications, reviews, feedback and survey responses.
Usage Data includes information about how you use our website, products and services, items you viewed or searched for, page response times, download errors, length of visits to certain pages (including how much time is spent on which pages), page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
Marketing and Communications Data includes your preferences in receiving newsletters and marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services or open an account). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

Direct Interactions. You may give us your Identity, Contact, Financial, Profile and Marketing and Communications Data and any other personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

register on our website and apply for our products or services (including requesting to have CPD materials certified by us);
create an account on our website (or when an account is created for you);
subscribe to our service, publications or newsletters;
place an order on our website;
request marketing to be sent to you;
enter a survey; or
correspond, give us feedback, report a problem with our website or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites we operate or websites employing our cookies. Please see the Cookies section below for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data (including quantitative website data and qualitative data) from analytics providers such as Google, HubSpot and Hotjar (part of Contentsquare Group which specialises in digital experience analytics), based outside the UK and advertising networks based inside the UK.
Contact and Financial Data from providers of technical, payment and delivery services such as PayPal based inside the UK.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK and social media sites such as Twitter, Facebook and Instagram.

HOW WE USE YOUR PERSONAL DATA

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.
Where you have specifically consented to us using your personal data in a particular way (for example, when you consent to our use of non-essential cookies or to receiving our publications or newsletters). You have the right to withdraw consent at any time. Please see the “Opting out” section below for more information on how to unsubscribe from marketing.

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. You have the right to withdraw consent to marketing at any time by contacting us or unsubscribing via any link or instructions contained in the direct marketing communication you receive from us.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 we rely on our legitimate interests as the legal basis for processing your personal data.

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 member (including providing access to any portal we may provide)	(a) Identity  (b) Contact	Performance of a contract with you
To process and deliver the services including: (a) manage payments, fees and charges (including membership fees); and  (b) collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) 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: (a) notifying you about changes to our terms, products and services and/or Privacy Policy; and  (b) asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (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 members use our products/services and to correspond with you so as to keep you up-to-date with any such changes)
To administer and protect our business and this website (including troubleshooting, data and statistical analysis, research, testing, system maintenance and fixing of issues, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, to study how our members use our website, to develop and maintain our website and improve our business)  (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you (including making suggestions and recommendations to you about goods or services that may be of interest to you) and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how members use our products/services, to develop them, to grow our business and to inform our marketing strategy) Consent (to being sent marketing communications and where we obtain this information by using cookies or where otherwise required by law)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers/members for our products and services, to keep our website and software updated and relevant, to develop our business and to inform our marketing strategy) Consent (where we obtain this information by using cookies or where otherwise required by law)
For fraud detection, monitoring and prevention	(a) Identity (b) Contact	Necessary for our legitimate interests (to prevent and detect crime and fraud) Necessary to comply with a legal or regulatory obligation
To enable you to partake in course feedback or provide references or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you  (b) Necessary for our legitimate interests (to study how members use our products/services, to develop them and grow and market our business)
To receive and respond to enquiries from you about our products and services including potential members	(a) Identity (b) Contact (c) Marketing and Communications	Necessary for our legitimate interests (to engage with you and to facilitate the growth of our business) Necessary to comply with a legal or regulatory obligation

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

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 at privacy@cpduk.co.uk.

Please note that if you decide to opt out or unsubscribe it could take up to 72 hours to process the update through our systems.

Cookies

When you visit our website, we collect some basic information such as your internet service provider’s domain name, which pages you accessed on our website, and when.

We also use cookies, which are small pieces of information that are saved to your device when you use our website. We use cookies which are necessary for our website to function, and, when you consent to this, we also use non-essential cookies.

You can set your browser to refuse all or some cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information on the cookies used on our website, please see the Cookies section below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

External third parties as follows:

Service providers to the extent they need to process personal data to provide us with their services based inside and outside the UK and who provide IT, system administration and business support services (including payment processing providers such as PayPal, VISA and Mastercard and website hosting services such as Amazon Web Services (AWS) who provide application servers and cloud storage) and data analytics providers (such as Google Analytics, HubSpot and Hotjar) to help us understand how you use our services and website and to improve and optimise our website and your experience.
Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
Enforcement companies, based inside and outside the UK when we believe it is necessary to comply with the law or enforce our rights under our terms and conditions or in any contracts between us or to protect the rights, property or safety of The CPD Certification Service Limited, our employees or customers, our business partners or others. This includes exchanging information with the police or other investigatory or law enforcement authorities and companies and organisations involved in fraud protection.
Certain third parties, based inside and outside the UK, where we have reason to suspect fraud or the commission of any other criminal offence. Such third parties may include business partners, law enforcement bodies, providers of fraud prevention and detection services, and recipients of fraud prevention and detection services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Third parties to whom we may choose to sell, transfer or merge all or part(s) of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy or any other privacy policies to which it refers.

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 instructions.

INTERNATIONAL TRANSFERS AND WHERE WE STORE YOUR PERSONAL DATA

Our operations are principally based in the UK and the personal data that we collect from you is mainly processed, stored and used within the UK and in countries of the European Economic Area (EEA). However, in order to offer you the best service we can provide, we also work with service providers from other parts of the world. This means that the data we collect sometimes needs to be transferred, stored and used by companies operating outside the UK and/or EEA who work for us or one of our service providers to countries which may not provide the same level of protection as the UK and the EEA.

Whenever we transfer your personal data out of the UK and/or 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 which is equivalent to EEA and/or UK standards.
The service providers to which we transfer your personal data are bound by European Commission-approved standard contractual clauses which offer data protection safeguards and/or equivalent standard clauses approved in the UK.
A derogation applies in accordance with data protection laws (for example, you have provided your explicit consent, or the transfer of data is necessary in order for us to exercise or defend a legal claim).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA.

DATA SECURITY

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 also 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.

Please note that, notwithstanding the steps we take, the transmission of information via the internet can never be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website.

Also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential and making sure it is not susceptible to being guessed. We ask you not to share a password with anyone.

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our members (including Contact, Identity and Financial Data) for six (6) years after they cease being members for tax purposes. We also keep general enquiry data (which does not lead to a contractual relationship) for a period of up to two (2) calendar years after the enquiry has closed. This is to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect or defend our legal rights. After these respective time periods, we securely delete your personal data from our systems unless we have to retain it pursuant to any legal, regulatory, tax, accounting or reporting requirements to which we are subject.

In some circumstances you can ask us to delete your data: see “Your Legal Rights” section below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Please note this Privacy Policy does not apply to anonymous data.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:

Request access to your personal data (commonly known as a “data subject access request”).
Request correction of your personal data, if it is inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances (also known as “the right to be forgotten”). Note, however, that this is not an absolute right and we may not always be required to comply with your request of erasure, for specific legal reasons.
Request restriction of processing of your personal data which enables you to ask us to suspend the processing of your personal data in certain circumstances.
Object to processing of your personal data in certain circumstances.
Request a copy of certain personal data in a “portable” format (eg, a pdf file) and request that we transfer this copy to a third party.
Right to withdraw consent at any time where we are relying on consent to process your personal data.

These rights are subject to certain limitations and exceptions and we will inform you of the relevant exemptions upon which we rely when responding to any request you make. For example, if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. The ICO website contains more detail on the rights mentioned above if you require any further information.

You may exercise any of the rights set out above by contacting us at privacy@cpduk.co.uk.

No 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.

COOKIES

What are cookies?

Our website uses cookies and other similar technologies (together “cookies") to ensure that you receive the best experience. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer (if you agree) when you use our website. These cookies allow us to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website and, where appropriate, serve you relevant advertisements.

Managing and disabling cookies

You always have a choice over whether or not to accept cookies. When you first visit our website, we will ask you to consent to either our recommended settings, or choose which cookies to switch on.

You can manage cookies and chose to block or restrict cookies by selecting the appropriate settings in your internet browser. However, if you choose not to accept certain cookies, you may impair certain functionality on our website or may cause it not to work at all. Please note, strictly necessary cookies will always be set as they are essential for our website to operate. You can set your browser to block or alert you about these cookies but some parts of the website will then not work.

Types of cookies used and purpose

We use the following types of cookies on our website for the following purposes:

Strictly necessary cookies. These are cookies that are required for the core functionality and operation of our website such as page navigation and cannot be switched off in our systems. They also include cookies that enable you to log into secure areas of our website. If you disable these cookies via your browser settings certain parts of the website will not function for you. These cookies do not store any personally identifiable information.
Analytical/performance cookies and third party cookies. These cookies help us improve or optimise the experience we provide, improve the performance of our website and help us better understand our users experience and needs. They allow us to recognise and count the number of visitors to our website, to see how visitors move around our website when they are using it (including what links are chosen to click and how much time is spent on which pages) and see if you get any error messages. This helps us to improve the way our website works, for example, by ensuring any errors are fixed and that users are finding what they are looking for easily. We use Google Analytics, HubSpot and Hotjar on our website, which provide third-party web analytics services and user behaviour analytics services, to help us analyse user behaviour including how visitors use the website so as to optimise the user website experience and create a better overall experience. Further information about these partners can be found here and via the link set out below in relation the individual cookies we use on our website.
Functionality cookies. These are used to recognise you when you return to our website, for example by remembering the cookies you have consented to. This enables us to personalise our content for you and to check that certain functionality is working on our website.
Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests and also show you relevant adverts on other sites. We may also share this information with third party service providers for this purpose so that when you are on another website, you may be shown advertising based on your browsing patterns on our website.

Click here to find more information about the individual cookies and other similar technologies we use on our website and the purposes for which we use them.

If you wish to opt-out of tracking by Google Analytics across all websites you can do so here https://tools.google.com/dlpage/gaoptout. If you wish to opt-out of Google Analytics for Display Advertising and customize Google Display Network ads in general please go to https://www.google.com/settings/ads or Google Analytics' currently available opt-outs for the web.

Third-party cookies

Some of the cookies used on our website are set by a third party (for example for web analysis such as Google Analytics) and not fully controlled by us: these are the cookies identified in the table that you can access via the link above with a domain name that is not cpduk.co.uk. You should review the privacy and cookie policies of these parties to find out how they use cookies and the information they collect through cookies. You also have the option to disable all third-party cookies via your internet browser settings. When you withdraw consent for cookies, please make sure that you refresh the page or browse to a different page on our website, to ensure that the cookies are removed from your internet browser.

Further information about cookies

You can find out more about how cookies work and how to manage cookies on the following websites: www.allaboutcookies.org or www.youronlinechoices.com