Section 1 Introduction
1.1 Scope of the policy
DNA Skills is committed to preserving the privacy of its staff and apprentices, to comply with the Data Protection Act (2018) and the General Data Protection Regulation (GDPR).
The data protection principles are set out in the Data Protection Act (2018). In line with Article 5 of the General Data Protection Regulation DNA Skills will ensure that all personal data is:
1.2 Purpose of the policy
This policy outlines the responsibilities of all staff (including third parties under contract, and or self-employed/volunteers) with regard to the Data Protection Act (2018) and the General Data Protection Regulation.
Staff are required to handle and process data in any of DNA Skills records or systems in accordance with this policy and in accordance with other related policies concerning the handling or processing of data. DNA Skills will process personal data, examples include:
1.3 A shared responsibility
It is important that all staff who are involved in the delivery of DNA Skills End-Point Assessments and/or regulated qualifications are made aware of this policy and its range of outcomes.
1.4 Reviewing the policy
We will review this policy annually or:
Section 2 Definitions
2.1 Personal data
Defined as data relating to a living individual who can be identified from that data alone, or with other data held by DNA Skills or which DNA Skills is likely to receive. This includes sensitive data relating to an individual’s gender, age, ethnicity, disability, trade union membership, political opinions, religious or similar beliefs, physical or mental health, sexual life, commission or alleged commission of any offence or information concerning related criminal proceedings or outcomes.
Regulates the “processing” of personal information which has a very broad meaning and includes obtaining, storing, viewing, using, updating, disclosing, and destroying any data held electronically, in structured manual records and to a limited extent, to unstructured manual records.
Section 3 Implementation
To meet the responsibilities DNA Skills will:
Section 4 Policies and Legislative Connections
The following policies and guidance are relevant to personal information:
DNA Skills will adhere to its obligations under the Regulation relevant to the use and monitoring of electronic communications, which are predominantly:
Section 5 Data Security
DNA Skills staff must adhere to the following guidelines to ensure personal information is protected from unauthorised viewing and from loss (including computer documents, emails, and paper copies) by ensuring staff are provided with adequate awareness training and follow guidelines set out in the GDPR code of practice
5.1 Data Transfer Guidelines
5.2 Data Storage Guidelines
DNA Skills will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. All EPA staff must take reasonable responsibility to ensure the data is accurate and up to date, relevant and not excessive. Any unauthorised disclosure of personal data to a third party by any staff member may result in disciplinary or legal action.
Failure to comply with DNA Skills policies and procedures for handling staff/apprentice data is a disciplinary offence which may be considered gross misconduct and may also involve personal criminal liability (please see DNA Skills Disciplinary Policy).
Section 6 Data Subject Rights/Subject Access Requests
Individuals have a right under the Regulation to ask DNA Skills if it holds their personal data, and if so, be provided with a copy of it. Any person wishing to exercise this right should apply in writing to DNA Skills, or via email at email@example.com.
To ensure DNA Skills has met the security requirements of the GDPR, the following information will be required before access is granted:
Subject Access Requests will be dealt with in line with the GDPR recommended timescales. DNA Skills will aim to comply with requests for access to personal information as soon as possible but will ensure it is provided within one month as required by the Regulation from receiving the written request. DNA Skills will provide the information in a clear format that is easily understood and, in a format, suitable for the requester’s needs. DNA Skills may request further details to clarify the exact requirements prior to the start of the one-month timeline.
If an individual considers the details provided in response to a Subject Access Request are incorrect or out of date, they should contact DNA Skills immediately.
Anyone whose personal information is processed by DNA Skills has the right to know
It is a criminal offence under the GDPR for any user to alter, illegally access, deface or remove any record (including e-mails) following receipt of an information request. DNA Skills will take necessary action against any individual who is found to have carried out this act, which may result in disciplinary or legal action. Other criminal acts under GDPR may also result in disciplinary or criminal proceedings; definitions can be found at www.ico.org.uk
If you have any queries or concerns regarding DNA Skills management of personal data, then you can contact DNA Skills directly.
Any comments or complaints will be dealt with through DNA Skills Complaints Policy. DNA Skills will maintain records of all complaints and their outcome.
The requirements DNA Skills has for processing personal data are recorded on the public register maintained by the Information Commissioner. DNA Skills notify and renew the notification on an annual basis as the law requires. If there are any interim changes, these will be notified to the Information Commissioner within 28 days. DNA Skills (trading name of SCL Education and Training) registration with the Information Commissioner’s Register of Data Controllers is: ZA063549 and can be found using this link:
If you are still unhappy after having made a complaint you may contact the Information Commissioner’s Office through their website:
Section 7 Data Sharing
There are occasions when it is necessary for DNA Skills to share data with other organisations or people and where consent is required DNA Skills will seek and gain this from the Data Subject, except where exemptions apply:
For further information, access the website of the Information Commissioner’s Office: https://ico.org.uk/
Section 8 Personal Data collected held and processed
Below is a table to show the data collected and processed by DNA Skills
Name - All Data Subjects – Identification purposes
Telephone/Mobile Number - All Data Subjects – To contact if required
Email Address - All Data Subjects – To contact if require
Employees – For contact and payroll/HMRC purposes
Employers – For contact purposes and where to send certificates
Training Providers – For contact purposes
Assessors – For contact purposes
Date of Birth
Employees – Tax purposes
Apprentices – To identify if under 18
Employees – To ensure suitability for job role
Assessors – To ensure suitability for job role
Apprentices – Meet requirements for end-point assessment
Apprentices – Proof of Identity
Employees – Proof of identity
ULN - Apprentices – For regulatory/certification purposes
Disabilities/Special Educational Needs - Apprentices – For reasonable assessment adjustments and special considerations
Next of Kin - Employees – For health and safety purposes
Employees – Assessing suitability for the role and conflicts of interest
Assessors - Assessing suitability for the role and conflicts of interest
Employees – Assessing suitability for the role
Assessors - Assessing suitability for the role
Employees - Assessing suitability for the role
Assessors - Assessing suitability for the role
Section 9 Retention and disposal of Data
DNA Skills will retain information about staff and apprentices for a period of 7 years and where necessary to comply with the law and for legitimate business needs. This will include information needed in connection with administering pensions and taxation, for potential or current disputes or litigation regarding employment, in the case of job applicants, in relation to any complaints or claims regarding the selection process, and information required for job references.
DNA Skills will dispose of data in line and conjunction with the JISC recommended data retention principles for Further Education and any legal and funding audit requirements. Once the retention period has elapsed, DNA Skills will ensure that any information is destroyed by secure means, i.e., by shredding, pulping, or burning for hard copy, deletion etc. for electronic/digitised copy. DNA Skills will use a reputable ISO Accredited company and obtain destruction certification. See website: https://www.jisc.ac.uk/
Section 10 Data security breach procedure
DNA Skills takes the risk to security loss very seriously and adheres to the legal framework set down by the Information Commissioner’s Office and industry standards. Actions may include:
Notification of breaches – if appropriate DNA Skills will inform the following parties:
Section 11 Contacts
Your contact for this policy
If you have any queries about the contents of the policy, please contact our DNA Skills EPA Team:
Telephone: 01344 944675
DNA Skills EPA Team
7 Lakeside Business Park
Title & Key Responsibilities
General Manager - Accountable for the strategic objectives of DNA Skills and its regulatory compliance. Ensures all policies are effectively implemented
Head of Quality & Compliance - Responsible Office and point of contact for regulatory bodies. Oversees the version control of policies
Head of Product & Assessment Development - Acting Deputy for Responsible Officer. Manages the development and life cycle of our products
Quality & Performance Manager - Responsible for the delivery of assessments and quality assurance processes
Head of IT/DPO - Data Controller
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