We provide academic resources, online courses, formal examinations and tuition services.
A reference to “you” or “your” is a reference to a user of the PFS website or any of our related services.
This policy outlines the steps and measures Complete Tuition Ltd ‘the company’ take in order to ensure data is handled in accordance with regulations set out in the Data Protection Act 2018 (DPA 2018), and the General Data Protection Regulation (GDPR) as it applies in the UK.
The policy is based on information taken from the following sources along with the knowledge of our internal processes.
Data protection principles
Complete Tuition Ltd is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- Processed lawfully, fairly and in a transparent manner in relation to individuals.
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest is not be considered to be incompatible with the initial purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- This policy applies to all personal data processed by the company
- The DPO and management shall take responsibility for the company’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- To ensure its processing of data is lawful, fair and transparent, the company shall maintain a Data Protection Actions and Timelines Policy.
Individuals have the right to access their personal data and any such requests made to the company shall be dealt with in a timely manner.
- All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the company’s systems.
- The company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The company shall take reasonable steps to ensure personal data is accurate. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date as set out in the Data Protection Actions and Timelines Policy
- To ensure that personal data is kept for no longer than necessary, the company shall enact its archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why. The checks to ensure data is deleted and archived in a timely manner are set out in the
- Data Protection Actions and Timelines Policy.
- The company shall ensure that personal data is stored securely using modern software that is kept up to date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate backup and disaster recovery solutions shall be in place.
- In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
- PFS values its learners and respects their privacy. Any information we collect about you is held with the utmost care and security. The trust and confidence of our customers and visitors is essential to us – we would never do anything to jeopardise that. We will only collect personal data on this website in order to process a request – a sample request, an account payment or an enquiry. We will never use these details for anything other than to service your request. Once we have a previous relationship with you (including by one of the actions listed above), then we may send you the occasional email to keep you up to date on our products and see if there is anything we can do to help you.
Data We Collect
We may set cookies on your browser, for the following purposes:
- a cookie to track your session – this will track the items you have added to your cart, progress through checkout, and is also used to send automated complete your purchase reminders etc – in other words, support our core functionality.
- a cookie to track if we have shown you our welcome message previously so that we don’t show it again.
- third-party Google Analytics cookies which track all visits to our website anonymously. More information at: https://support.google.com/analytics/answer/6004245
- third-party Facebook cookies which track your session if you have visited our website via a Facebook or Instagram advertising campaign.
In limited circumstances, we may ask you to provide personal data on our website. This data may include:
• Name • Email Address • Telephone Number • Billing Address • Shipping Address • Date of Birth (Applicable for certain products only) • ULN (for exams only)
The only time we will ask for any or all of this data is if you have asked us to perform one of the following actions:
- Process an ecommerce purchase placed by you
- Process a payment you are making against an order
- Provide assistance to an enquiry made through any of our contact forms
- You have booked an exam through our service
We will only ever ask for information that is relevant to help us action your request and we will only use that data to fulfil your request. If you have provided us with an email address, we may send the occasional email to you to keep you up to date with our products and to reach out to see if there is anything we can help you with. You can ask us to stop these mailings at any time by emailing email@example.com
Transfer of Data
In order to better fulfil any requests, we may move your data into our Customer Relationship Manager system. This system is only ever accessed by Complete Tuition Ltd employees and any data we hold on you will never be shared with other people or companies without your consent. We will never sell, rent or otherwise share your data for commercial purposes.
You are entitled to view, amend, or delete the personal information that we hold about you at any time. Email your request to us at firstname.lastname@example.org and we will respond and action your request as appropriate within 30 days.
Registering with us
If you register with us, we save the details you provide and use them to enable us to personalise the service we offer to you. You can update your details at any time by contacting us. Please note we never store card details.
Who has access to the information you provide or we collect
We retain access to some personal information that we have collected from you but only for an appropriate amount of time.
When you select to use the service of one of the tutors listed on PFS, those agencies or tutors may have access to your Information. Their use of your personal information is governed by their privacy policies. We are not responsible for the privacy policies and practices of any tutor, agency or website, even if you access them using links from our site or if you can access our site through their site. We, therefore, recommend that you check the policy of each website that you visit.
With regards to the testing services we provide, we hold the rights to all exam papers provided and any content or material linked to the provision of examinations. This includes, but is not limited to, completed exam papers and recordings of online mock examinations.
If we offer or supply a service to you that is provided on our behalf of a third party we may have to pass your Information to them in order to deliver the service. By using this site you consent to us providing your Information to the third parties licensed by us to provide such services. We will not otherwise disclose, sell or distribute your Information to any third party, not associated with us without your permission unless we are required to do so by law. We will not provide your personal information to third parties for marketing purposes.
For functional skills examinations, we do share your information with the exam board Open Awards in order for them to process your information in relation to your exam.
Access to, changing or removing the information we hold
Registered users of PFS can update their information by logging into their PFS account and following the instructions provided. In order to ensure our service remains relevant to you, we encourage you to update your contact details as and when they change.
Changes to the policy
We may change this policy from time to time as we add new services or features or in response to changes in the law or our commercial arrangements. Any changes to this policy will be posted on this site. Users of the site are advised to check these terms regularly.