Privacy Policy – Excel Me

Updated at 2024-06-10

1. Introduction

Excel Me (“Excel Me”, “we”, “us” or “our”) is committed to protecting your privacy and handling your personal information responsibly.

This Privacy Policy explains how we collect, use, store, protect and share personal information when you visit our website, contact us, use our services, or participate in an apprenticeship End-Point Assessment (EPA) managed by us.

Excel Me is a wholly owned subsidiary of The Swimming Teachers’ Association, a registered charity in England and Wales (charity number 1051631) and Scotland (charity number SC041988). Our registered office is Anchor House, Birch Street, Walsall, WS2 8HZ, United Kingdom.

For data protection purposes, the identity of the legal entity responsible for each processing activity will depend on the relevant arrangements. In this policy, “Excel Me” refers to the organisation operating the website and providing the relevant services.

We process personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and applicable electronic communications and cookie legislation.

2. Who this policy applies to

This Privacy Policy applies to:

Visitors to our website.
Apprentices registered for or undertaking an EPA.
Employers and their representatives.
Training providers and their staff.
Assessors, independent end-point assessors and quality assurance personnel.
Individuals who contact us with enquiries, feedback, complaints or requests.
Suppliers, contractors and other professional contacts.

Where we process personal information on behalf of another organisation, the relevant contractual arrangements will determine our responsibilities and those of the other organisation.

3. Personal information we collect

The personal information we collect depends on your relationship with Excel Me and the services you use.

3.1 Website visitors and general enquiries

We may collect:

Your name and contact details, including your email address and telephone number.
The contents of messages, enquiries or feedback you submit.
Information you provide through website forms.
Technical information, such as your IP address, browser type, device information and website usage data.
Cookie preferences and website analytics information, where applicable.

3.2 Apprentices and assessment candidates

Where necessary to register, arrange, conduct, quality-assure and record an EPA, we may collect:

Name, contact details, date of birth and relevant identification or registration details.
Apprenticeship standard, programme details, employer and training provider information.
Registration, eligibility and assessment gateway information.
Portfolio documents, work products, written submissions and other assessment evidence.
Assessment schedules, attendance records, assessor notes, questions, responses, feedback, outcomes and grades.
Audio or video recordings of assessments, where recording is necessary and applicable.
Information required to arrange reasonable adjustments or special consideration.
Information relating to appeals, complaints, suspected malpractice, investigations or assessment irregularities.
Records required for quality assurance, certification, audit and regulatory compliance.

We aim to collect only information that is relevant and necessary for the relevant purpose.

3.3 Employers, training providers and professional contacts

We may collect names, job titles, work contact details, organisational information, correspondence, contractual records, service enquiries, feedback and information required to administer our working relationships.

3.4 Special category and sensitive personal information

In limited circumstances, we may process information about health, disability or other special category personal data where it is necessary to consider a reasonable adjustment, special consideration or another legitimate assessment-related requirement.

We will only process such information where an appropriate legal basis and, where required, an additional condition under data protection law applies. Access will be restricted to individuals who need the information for the relevant purpose.

We ask individuals not to submit unnecessary sensitive information through general website forms or ordinary correspondence.

4. How we collect personal information

We may collect information:

Directly from you through forms, emails, telephone calls, meetings and other communications.
From employers and training providers involved in your apprenticeship.
From assessors and assessment personnel.
Through assessment submissions, evidence and assessment platforms.
From relevant awarding organisations, regulators or other authorised bodies where necessary and lawful.
Automatically through our website, server logs, cookies and similar technologies, subject to applicable requirements.

Where personal information is provided by an employer, training provider or another organisation, that organisation should ensure that the information is shared lawfully and that the relevant individuals receive appropriate privacy information.

5. How and why we use your information

We use personal information for the following purposes.

Providing and administering assessment services

To register apprentices, confirm eligibility, arrange assessments, communicate with relevant parties, conduct assessments, record outcomes and arrange certification where applicable.

Maintaining assessment quality and integrity

To undertake internal quality assurance, standardisation, moderation, audits, investigations, appeals and reviews of assessment decisions.

Supporting apprentices

To communicate assessment requirements, provide relevant guidance and feedback, arrange reasonable adjustments and consider special circumstances where appropriate.

Managing relationships and enquiries

To respond to enquiries, manage relationships with employers and training providers, provide customer support and maintain business records.

Meeting legal and regulatory requirements

To maintain required records and provide information to awarding organisations, regulators, auditors or public authorities where required or otherwise lawfully justified.

Operating and improving our website

To maintain website security, diagnose technical problems, understand website performance and improve accessibility and functionality.

Communicating updates and relevant information

To send service-related messages and, where permitted by law, relevant marketing or promotional communications.

We will not use your information for a materially different purpose without providing further information where required by law.

6. Our lawful bases for processing

Under the UK GDPR, we must have a lawful basis for processing personal information. Depending on the circumstances, we may rely on the following bases:

Contract: where processing is necessary to enter into or perform a contract with you or the organisation receiving our services.
Legal obligation: where processing is necessary to comply with applicable legal or regulatory requirements.
Legitimate interests: where processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. These interests may include administering assessments, maintaining quality standards, managing business relationships, preventing fraud and securing our systems.
Consent: where you have freely given consent for a specific purpose, such as certain optional cookies or marketing communications where consent is required.
Public task: where the relevant organisation and processing meet the legal requirements for processing necessary to perform a task in the public interest or exercise official authority. We will rely on this basis only where it is applicable.
Vital interests: in exceptional circumstances, where processing is necessary to protect someone’s life or other vital interests.

Where we process special category personal data, we will also identify and rely on an applicable condition under Article 9 of the UK GDPR and any additional requirements under relevant legislation.

The applicable lawful basis depends on the particular processing activity. We will provide further information where necessary.

7. Who we share your information with

We only share personal information where necessary, appropriate and lawful.

Depending on the circumstances, recipients may include:

Employers and training providers involved in your apprenticeship.
Assessors, independent end-point assessors and internal quality assurance personnel.
Relevant awarding organisations, including Safety Training Awards where applicable.
Ofqual and other competent regulatory or public authorities where required or authorised.
Certification bodies and organisations involved in the administration or verification of assessment outcomes.
IT, website hosting, email, assessment platform and secure data storage providers.
Professional advisers, auditors and legal representatives where necessary.
Law enforcement agencies, courts or other authorities where required or permitted by law.

We require service providers processing information on our behalf to handle it securely and in accordance with applicable data protection requirements.

We do not permit third parties to use personal information entrusted to them by us for their own unrelated purposes without an appropriate legal basis.

We do not sell personal information.

8. International transfers

We primarily operate from the United Kingdom. However, some of our service providers may store or process personal information outside the UK.

Where personal information is transferred internationally, we will ensure that the transfer complies with applicable data protection law. Depending on the circumstances, this may involve an adequacy regulation or decision, an approved international data transfer agreement or addendum, or another legally recognised safeguard.

You may contact us using the details in this policy to request further information about relevant international transfers and the safeguards in place.

9. How long we retain personal information

We retain personal information only for as long as necessary for the purposes for which it was collected, taking into account applicable legal, contractual, assessment, regulatory, audit and record-keeping requirements.

Different retention periods may apply to different categories of information, including:

General enquiries and correspondence.
Employer and training provider records.
Apprentice registration and assessment records.
Assessment evidence, recordings and outcomes.
Appeals, complaints and investigation records.
Website logs, cookies and analytics information.
Financial and contractual records.

Assessment records may need to be retained for longer periods to support certification, quality assurance, regulatory oversight, appeals or audit requirements.

When information is no longer required, we will securely delete it, anonymise it or otherwise dispose of it in accordance with our retention procedures.

Our retention schedule: Specific retention periods are determined by our applicable retention schedule and legal or regulatory requirements. We will make the relevant periods or criteria available in accordance with applicable data protection law.

10. How we protect your information

We take appropriate technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration, disclosure or destruction.

These measures may include access controls, appropriate staff permissions, secure systems, staff guidance, data minimisation, secure disposal and supplier oversight.

Where assessment evidence or sensitive information is handled, access should be limited to authorised individuals who need it for their responsibilities.

Although we take reasonable steps to protect personal information, no method of electronic transmission or storage is completely secure. We maintain appropriate procedures for responding to suspected personal data breaches, including notifications where required by law.

11. Cookies and similar technologies

Our website may use cookies and similar technologies to support its operation, remember preferences, maintain security and understand website usage.

Cookies may include:

Strictly necessary cookies: required for core website functionality or security.
Preference cookies: used to remember settings or preferences.
Analytics cookies: used to understand website traffic and performance.
Third-party cookies or technologies: used by embedded content or external services, where applicable.

We will obtain consent before placing or accessing non-essential cookies where required by law. You can manage your preferences through the cookie settings available on our website, where provided.

You can also manage or delete cookies through your browser settings. Blocking certain cookies may affect some website functionality.

For further details, please consult our cookie settings or any separate cookie notice provided on the website.

12. Marketing communications

We may send service-related communications where necessary to administer assessments, respond to enquiries or manage our professional relationships.

We will send direct marketing communications only where permitted by applicable law. Where consent is required, we will obtain it before sending such communications.

You can unsubscribe from marketing emails using the unsubscribe link provided or by contacting us directly.

Unsubscribing from marketing communications will not prevent us from sending essential service or administrative messages where these are necessary.

13. Your data protection rights

Depending on the circumstances and the applicable legal requirements, you may have the right to:

Access: request a copy of your personal information.
Rectification: request correction of inaccurate or incomplete information.
Erasure: request deletion of personal information where the legal conditions are met.
Restriction: request that we restrict the processing of your information in certain circumstances.
Data portability: request your information in a portable format where this right applies.
Object: object to processing based on legitimate interests or to processing for direct marketing.
Withdraw consent: withdraw consent at any time where we rely on consent. This will not affect the lawfulness of processing carried out before withdrawal.
Challenge certain automated decisions: request applicable safeguards where decisions with legal or similarly significant effects are made solely by automated processing.

These rights are subject to legal conditions and exemptions. For example, we may need to retain assessment records to comply with legal or regulatory obligations, and we may not be able to delete information where a valid retention requirement applies.

Your right to object: Where we process your personal information based on legitimate interests, you may object to that processing. We will consider your objection in accordance with applicable law. You have an absolute right to object to direct marketing.

To exercise your rights, please contact us using the details in Section 17. We may need to verify your identity before responding.

We will respond within the applicable statutory timeframe.

14. Automated decision-making and profiling

We do not intend to make decisions about individuals that have legal or similarly significant effects based solely on automated processing without appropriate legal justification and safeguards.

Where automated decision-making or profiling of this kind is introduced, we will provide the information required by law and implement the relevant safeguards.

Assessment outcomes are subject to the applicable assessment arrangements, quality assurance and review procedures.

15. Children’s and young people’s information

Some apprentices may be under the age of 18. We take particular care to ensure that personal information relating to children and young people is handled appropriately and securely.

We process such information only where necessary for relevant assessment, administrative, legal or regulatory purposes and with appropriate safeguards.

Where required, we will provide privacy information in language that is clear and understandable to the individual concerned.

16. Third-party websites

Our website may contain links to websites, services or platforms operated by third parties.

Those third parties may have their own privacy notices, cookie policies and data handling practices. We are not responsible for their independent processing of personal information.

We recommend reviewing the relevant privacy notice before submitting personal information to another organisation.

17. Contact us

If you have questions about this Privacy Policy, wish to exercise your data protection rights or have concerns about how we handle personal information, please contact us.

Excel Me
Anchor House
Birch Street
Walsall
WS2 8HZ
United Kingdom

Email: info@excelme.co.uk
Website: https://www.excelme.co.uk/

Please include sufficient information to help us understand and respond to your request. Do not send unnecessary sensitive information by email.

18. Complaints

If you are concerned about how we have handled your personal information, please contact us first so that we can investigate your concerns.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

Information Commissioner’s Office (ICO)
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113

You may contact the ICO directly without first contacting us.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, data processing practices, legal obligations or regulatory guidance.

The latest version will be published on our website, together with the date it was last updated.

Where required by law, we will notify affected individuals of significant changes before introducing new processing activities.

We encourage you to review this policy periodically to understand how we handle personal information.