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Purpose
Buttercups Training respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how Buttercups Training collects and processes your personal data through:
- your use of Buttercups Training websites or apps, including any data you may provide through Buttercups Training websites/apps when you make an enquiry or purchase a product or any course/programme (whether online, face to face or distance learning) and whether on behalf of yourself; as an employer client; as a third party training provider; or as a reseller (“Services”);
- your registration for, purchase of or use of any Buttercups Training products and/or Services (including but not limited to courses, programmes or study materials (in any medium));
- your use of any Buttercups Training social media channel; and
- the provision of personal data to Buttercups Training by any other means.
- This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
This Privacy Policy is provided in a layered format so, if you wish, you can select the specific areas of the Policy you are interested in, as set out below. We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.
Who we are
Data controller
In this privacy notice, references to "we" or "us" or “our” and “Buttercups” are to Buttercups Training Limited. Buttercups is a ‘data controller’ which means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice applies to: candidates prior to enrolment on a Buttercups course, learners undertaking a Buttercups course, learners who have completed a Buttercups course, apprentices at any part of the enrolment or learner journey and post completion of their apprenticeship programme of study, employer clients, visitors, including website users, pharmacy professionals or those seeking to become pharmacy registrants who are undergoing fitness to practice investigations where Buttercups are involved, current and former employees, contractors, and consultants.
Contact details
We have appointed a data protection officer (“DPO”) 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 DPO using the following details:
FAO of the Data Protection Officer
BPP Professional Education Group
Legal Team
4th Floor, 3 London Wall Buildings
London
EC2M 5PD
Email: Dataprotection@bpp.com
You have the right to make a complaint at any time to:
- the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk)
- the Office of the Data Protection Authority, the supervisory authority for data protection issues in Guernsey (www.odpa.gg); or
- the Jersey Office of the Information Commissioner, the supervisory authority for data protection issues in Jersey (www.jerseyoic.org).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO (or other relevant authority) so please contact us in the first instance.
Important information about this policy
Changes to the Privacy Policy and your duty to inform us of changes
This Privacy Policy sets out your rights under the Data Protection Act 2018 and the UK General Data Protection Regulation.
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.
We keep this Privacy Policy under review and may update it from time to time. This version was last updated on 11th June 2024.
If you reject the terms of this Privacy Policy
If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website, apps or any other means.
Third-party links and products
The Website (and apps) may include links to third-party websites, plug-ins and applications. 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 are not responsible for their privacy policies. When you leave our Website or app, we encourage you to read the privacy policy of every website you visit.
Through the course of your studies you may also be directed to use third party. We do not control these third-party platforms and are not responsible for their privacy policies or responsible for personal data which may be transferred by you to such third parties. When using these platforms, we encourage you to read their terms of use and privacy policy.
Your personal data
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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Audio / Visual Data includes recordings from closed circuit televisions systems which are in place at some of our premises for security purposes; telephone recordings (for monitoring and training purposes) where you call any of our advice or sales teams (although not all calls to Buttercups Training are recorded); photographs of you for use on ID cards or to be used on registers/your online accounts so Buttercups employees (such as tutors or exam invigilators) can identify you; audio/video recordings of meetings with tutors, pastoral reviewers or other performance/progress calls on courses or programmes (although not all of these types of calls are recorded); recordings (including video, audio and text) where any virtual classroom, seminar, webinar or other interactive teaching session is recorded; video recordings from recorded exams/assessments (including mock exams/assessments); and any video recordings from any recorded interviews (such as skills scans, credibility interviews and English language interviews for visa compliance purposes). Please see Online Learning and Assessment for further information.
Contact Data includes billing address, delivery address, postal address, email address and telephone numbers.
Eligibility Data includes education/academic history, records of qualifications and/or training, personal statements and references. For apprentices this will also include national insurance number.
Employment Data (this is relevant where your place on a course or programme is sponsored by your employer/future employer) includes name of employer, job title, line manager name and contact details, work contact details (email address, telephone number and postal address), National Insurance number and employment start and end dates (and for apprentices may include hours of work).
Identity Data includes first name, maiden name, last name, reference number, usernames for Buttercups sites (including Buttercups Virtual Learning Environment, and other online learning environments, or similar identifiers (including any learner registration number assigned to you by an external body who shares information with us such as awarding bodies or the General Pharmaceutical Council), marital status, title, date of birth and gender. It may also include copies of identification documents (such as a passport, drivers licence or national identity card) which are used to confirm your identity in assessments (including online assessments).
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Next of Kin Data includes the name and contact information of a friend or relative to be used in the event of an emergency involving you. It may also include details of relatives you have authorised to communicate with Buttercups Training on your behalf or attend Buttercups events with you, such as study days.
Profile Data includes your usernames and passwords (for Buttercups platforms), purchases or orders made by you, your interests, preferences, feedback, reviews, survey responses and enquiries submitted to Buttercups Training.
Recruitment Data includes any information you have provided to us (or through a third party such as Job Train, Zellis, Indeed, My First Job, LinkedIn or a recruitment agency) in your curriculum vitae, any covering letter, any application form (including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and reasons for wanting to apply for the relevant position) and any information you provide to us during an interview.
Data includes the course or programme you are studying with Buttercups, your years of study, records of achievements on the course or programme (exam, assessment and mock results), exam scripts, exam transcripts, attendance and progress information, feedback from lecturers or personal tutors (including learner references), emails sent by you to Buttercups, emails sent/received by you to or from your Buttercups email address or messages posted on any forums or message boards (including on Teams), information relating to your involvement in Buttercups’ apprentice network, information relating to your involvement in Buttercups’ alumni network, information relating to your registration for or attendance at any Buttercups hosted/advertised events, information relating to allegations of academic misconduct or other matters of discipline, information relating to any application for mitigating circumstances or an academic appeal, any application for deferrals or interruption of studies and any complaints made by you or about you to Buttercups.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Usage Data includes information about your visit to a Website, through and from the Websites or apps (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page and any phone number used to call our customer services numbers. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
Special Categories of Personal Data
The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data. In some circumstances we may also collect, store and use the following “special categories” of more sensitive personal information:
Information about your race or ethnicity – this information is collected for equality and diversity monitoring purposes. We also collect this information on behalf of the Department for Education in relation to apprenticeship learners.
Information about your nationality and immigration status – 1) this information is required to ensure right to work in the UK and right to study in the UK. Accordingly, we will collect information such as copies of passports, copies of visas and any relevant correspondence between you and the UK Visas and Immigration department of the Home Office.
Information about any disabilities or learning needs – 1) this information is collected so that any reasonable adjustments can be made to accommodate learners with disabilities (for example large print learning materials or exam papers) and also to ensure that any learning needs are supported (for example extra time in exams). This information is voluntary but Buttercups will not be able to provide you with learning support/reasonable adjustments if you do not provide this information.
Medical information – this information may be collected where a medical issue is having an impact on your studies and or/work with Buttercups (for example, you may have a prolonged period of absence; or you make an application for an interruption of studies where an illness is preventing you from studying; or where a medical issue has affected your performance in an exam, you may make an application for mitigating circumstances) or if an incident occurs whilst on a Buttercups site and such information is required for health and safety reporting. It may also include dietary requirements where you are attending a catered Buttercups event. This information is voluntary.
Information about criminal convictions, offences, and fitness to practice – We will ask you to provide confirmation of whether you have any unspent criminal convictions as part of the application process. We also require you to confirm whether you are undergoing fitness to practice proceedings or whether you are temporarily or indefinitely suspended from the register.
Any declaration will not be an automatic bar to your application but Buttercups will have to evaluate the details of such conviction or fitness to practice for two reasons. Firstly, to ensure there is no threat to the safety of other learners and employees at Buttercups and secondly to advise whether your conviction or fitness to practice is likely to bar you from your chosen profession.
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 enrol you onto a relevant course or programme or provide goods or services to you). In this case, we may have to withdraw your application or cancel/restrict a product or Service you have with us, but we will notify you if this is the case at the time.
How your personal data is collected
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity, Contact, Eligibility, Employment, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for a course or programme;
- submit an online query or request a call back;
- purchase goods or Services from us;
- speak with one of our resourcing, onboarding and induction teams;
- speak with one of our client or supplier services teams;
- speak with your tutor or other teaching staff;
- create an account on our Website;
- download and use any Buttercups app;
- subscribe to a service or publication;
- subscribe, register, take part in or view any Buttercups webinar;
- are captured on closed circuit television when attending our premises;
- request marketing to be sent to you;
- enter a competition, promotion or complete a survey; or give us feedback.
Through your Studies
You may give us your data throughout your time on a course or programme. This includes personal data you provide when you:
- attend lectures, seminars, webinars or other learning sessions (including where these are online);
- submit work for assessment (including mocks);
- take exams or other forms of assessment (including mocks);
- submit any applications or complaints relating to your studies (for example, mitigating circumstances applications);
- raise any issues or questions with your lecturer / personal tutor; or
- contact one of our learner advice teams for support.
Automated technologies or interactions
As you interact with our Website or apps, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Cookies
A cookie is a small file (typically letters and numbers) which may be placed on your computer when you access our website. A cookie cannot read your computer’s hard disk or make any information available to third parties.
Through the cookie we can recognise your computer and browsing activity if you return to the website, allowing us to provide you with a better service. We also track user traffic patterns in order to determine the effectiveness of our website. We do not release this information to third parties.
We use cookies to allow our website to recognise when you return to our site (which helps us to optimise your visits) and cookies to track the length of each visit.
If you would like more information on cookies click here.
We use Google Analytics which allows us to collect information about how you use our site. If you access our website directly (and not via an email) you’re visits will be tracked anonymously.
We use Google Analytics to understand how our website is being used in order to improve the experience for you. All user data is anonymous.
We use social buttons such as Twitter, Google, Facebook and LinkedIn to share or bookmark pages on our site or email updates. Those sites may collect information about your internet activity, including if your visit to our site (even if you don’t click on the button if you’re logged on to their site). You should check the privacy and cookies policy of each of these sites to see how they use your information and find out how to opt out and delete such information.
You are able to manage cookies. For more information click here. If you want to block all cookies all of the time you can set your computer preferences to do so. However, if you are a registered user of Buttercups Training you will need to allow “per-session” cookies in order to access password-protected sites.
Our website does not require you to input personal data to use it. You may however volunteer personal data such as your name and email address to request information, updates and our services. That information is required to deal with your query appropriately.
Third parties
We may receive personal data about you from various third parties as set out below:
- Identity, Contact, Transaction and Learner Data from any third party survey/review organisation or portal provider, such as SurveyMonkey, Eventbrite and TrustPilot.
- Data relating to criminal convictions and offences from the Disclosure and Barring Service (and any umbrella body company used to access DBS checks including uCheck, Yoti, UKCRBS).
- Technical Data from analytics providers such as Google.
- Identify and Contact Data from advertising networks; and search information providers (such as Companies House or LinkedIn)
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 or your employer.
- 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 or regulatory obligation.
- Where we have your consent.
- Where we are relying on your consent as a legal basis for processing your personal data, for example where we collect voluntary “special category” personal data (as set out in this Policy above) you may withdraw your consent to this processing at any time by contacting 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 legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| Learners or prospective learners | ||
| To respond to enquiries or requests for information | a. Identity b. Contact |
• Performance of a contract with you; or • Consent |
| To assess your eligibility to be enrolled onto a particular course or programme with Buttercups | a. Contact b.Eligibility c.Employment* (if sponsored by an employer) d.Identity e.Audio/Visual |
• Performance of a contract with you; or • *Necessary for our legitimate interests (to deliver services to your employer under a contract in place between Buttercups and your employer) |
| To recruit you for apprenticeships with Buttercups’ selected employer clients | a. Recruitment | • Consent; or • Necessary for our legitimate interests (to recruit apprentices/trainees for our employer clients) |
| To review and process any application you make for a position or post within Buttercups including: • In response to any vacancy advertised via the HR or Resourcing Team |
a. Identity b.Contact c. Recruitment |
• Consent |
| To register/enrol you as a learner with Buttercups | a. Contact b.Eligibility c. Employment* (if sponsored by an employer) d. Identity |
• Performance of a contract with you; or • *Necessary for our legitimate interests (to deliver services to your employer under a contract in place between Buttercups and your employer) |
| To deliver the course or programme to you (including the delivery of events) | a.Audio/Visual b.Contact c. Identity d.Profile e.Learner |
• Performance of a contract with you; or • *Necessary for our legitimate interests (to deliver services to your employer under a contract in place between Buttercups and your employer) |
| To participate in surveys or similar research and analysis exercises undertaken by governmental or other agencies (including but not limited to the Department for Education, Higher Education Funding Council for England, the Office for Students or the Higher Education Statistics Agency) (or any successor body to them) or by third parties engaged by such bodies. | a. Identity b.Eligibility c. Learner |
• Necessary for our legitimate interests (to study how learners use our services, to develop them, to grow our business and to inform our strategy) • Necessary to comply with a legal obligation |
| Clients of Buttercups Training (including employer clients) | ||
| To register you as a client of Buttercups Training | a. Identity b.Contact |
• Performance of a contract with you |
| To process and deliver your order including: • Manage payments, fees and charges • Collect and recover money owed to us • Keep records for audit/accounting purposes • Defend any legal claims brought against Buttercups |
a. Identity b.Contact c. Financial d.Transaction e.Marketing and Communications |
• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us or defend legal claims) • Necessary to comply with a legal obligation |
| Suppliers to Buttercups Training | ||
| To register you as a supplier of Buttercups Training | a. Identity b. Contact |
• Performance of a contract with you |
| To process and deliver the service: • Manage payments, fees and charges • Collect and recover money owed to us • Keep records for audit/accounting purposes • Defend any legal claims brought against Buttercups |
a. Identity b.Contact c. Financial d.Transaction e.Marketing and Communications |
• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us or defend legal claims) • Necessary to comply with a legal obligation |
| For All | ||
| To manage our relationship with you which will include: • Notifying you about changes to our terms or policies • Asking you to provide a review or take a feedback survey |
a. Identity b.Contact c. Profile d.Marketing and Communications |
• Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | a. Identity b.Contact c. Profile d.Usage e.Marketing and Communications |
• Performance of a contract with you • Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and our Website or apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | a. Identity b. Contact c. Technical |
• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation |
| To deliver relevant Website or apps content and advertisements 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 customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Website or apps, products/services, marketing, learner/ customer/client relationships and experiences | a.Technical b.Usage |
• Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website or apps updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods, services or events that may be of interest to you | a. Identity b.Contact c. Technical d.Usage e.Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| Learners or prospective learners | ||
| To confirm that you have the correct immigration status to be enrolled as a learner with Buttercups Training | Data relating to nationality and immigration status (copies of passports and visas) | • Performance of a contract with you • Complying with our legal obligations to the UK Home Office |
| To provide reasonable adjustments to learners with disabilities and to provide learning support to learners who have learning needs | Data relating to disabilities and/or learning needs | • Performance of a contract with you • Complying with our legal obligations (under the Equality Act 2010) • Your explicit consent (this information is voluntary) |
| To: • Monitor periods of absence* • Deal with applications for mitigating circumstances or academic appeals • Deal with applications for interruptions of study or deferrals • Deal with fitness to practice investigations • Confirm any dietary requirements for Buttercups catered events |
Medical data (may include doctors notes or medical records) | • Performance of a contract with you •Your explicit consent (this information is voluntary) |
| To minimise the spread of Covid-19 and safeguard learners, staff and visitors. | Medical data (may include Covid-19 test results or information on vaccination status) | Public Task Legitimate interests Please see Covid-19 Monitoring and Reporting for further information |
| To carry out equal opportunities monitoring and reporting | Data relating to race and ethnic origin (and other special category personal data) | • Your explicit consent (this information is voluntary) • It is in the public interest to process such data • Necessary to comply with a legal obligation |
Less commonly, we may also process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent (for example if you suffer a medical problem whilst on Buttercups’ premises).
Consent
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations.
In limited circumstances (as set out above), we ask you for your written consent to allow us to process certain particularly sensitive data. When we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
You should be aware that it is not a condition of your contract/right to study with us that you agree to any request for consent from us. However, we may not be able to provide you with certain services (such as learning support) if you do not agree to provide such data to us.
Information about criminal convictions
We will only use information relating to criminal convictions or alleged criminal behaviour where the law allows us to do so. This can arise when it is necessary for us to comply with the law or for another reason where there is a substantial public interest in us doing so. Less commonly, we will, if necessary, use information relating to criminal convictions or alleged criminal behaviour where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
We will only collect information about criminal convictions or allegations of criminal behaviour where it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions/allegations and offences in the following ways:
- Cross-refer to relevant policies/processes/vetting procedures. We are allowed to use your personal information in this way where it is in line with our data protection policy and where one of the following reasons arises:
- Where we need to carry out our legal obligations or exercise our legal rights;
- Where it is substantially in the public interest to do so and necessary for performing our functions as an Training Provider.
Automated decision-making
We do use automated technologies and decision-making when deciding what marketing messages you receive. However, we do not envisage that any other decisions will be taken about you using automated means, however we will update this Policy if this position changes.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Your marketing opt-in preferences will be collected when you register, book a course/programme or submit and enquiry through the website. You can opt out of receiving marketing at any time by replying to the sender of the marketing communication with the word “UNSUBSCRIBE”. If you do not agree to receive marketing from us, but change your mind at a later date, you can contact us and update your marketing preferences.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third party marketing
We will get your express opt-in consent before we share your personal data with any company outside of BPP group of companies for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.
Cookies
You can set your browser to refuse all or some browser 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 about the cookies we use, please see our Cookie Policy.
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. Please note that 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.
Data sharing
We will in some circumstances have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you; where it is in the public interest to do so or where it is necessary for the performance of our functions as a Training Provider. This will, in some circumstances, involve sharing special categories of personal data and, where relevant, data about criminal convictions/allegations.
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within Buttercups Training. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT Services, security vetting, expenses processing, Recording of Health and Safety and accident records. The following third-party service providers process personal information about you for the following purposes:
BPP Education Group
As of 18 April 2024, Buttercups was acquired by the BPP Education Group. As a result of that acquisition the BPP Group will provide support to Buttercups for certain centralised functions such as Legal support. Therefore there may be occasions when your personal data is shared with BPP Holdings Limited. For information on how your personal data is processed by BPP Holdings Limited, please see its privacy policy at www.bpp.com/privacy
Your Employer
Your employer, acting as an independent controller, where your employer/prospective employer is sponsoring your place on a course or programme (or where your employer/prospective employer has arranged for a course or programme to be delivered to a group of its employees/prospective employees). We will share information relating to your attendance, performance (including exam/assessment results and mock exam/assessment results and if applicable, recordings of coaching and performance calls), course progression, and general behaviour/performance on the course/programme.
The General Pharmaceutical Council (GPhC)
Sharing your information with the GPhC is a legal and regulatory requirement on the part of your employer and Buttercups Training. GPhC need to know who can legally practice and we are required to share the names of those qualified.
This includes providing GPhC with annual data for their own statistics reports and may include special category personal data, where you have shared this with Buttercups.
The Department for Education (DfE)
We will share your information with the DfE as this is a legal and governmental requirement for any entering an apprenticeship qualification. Please see their Privacy Notice below:
This privacy notice is issued by the Department for Education (DfE), on behalf of the Secretary of State for the Department of Education (DfE). It is to inform s how their personal information will be used by the DfE.
Your personal information is used by the DfE to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique number (ULN) and a personal learning record (PLR). Your information will be securely destroyed after it is no longer required for these purposes.
Your information may be shared with third parties for education, training, employment and well-being related purposes, including for research. This will only take place where the law allows it and the sharing is in compliance with data protection legislation.
The English European Social Fund (ESF) Managing Authority (or agents acting on its behalf) may contact you in order for them to carry out research and evaluation to inform the effectiveness of training.
You can agree to be contacted for other purposes by ticking the relevant boxes within your funding paperwork.
Further information about use of and access to your personal data, details of organisations with whom we regularly share data, information about how long we retain your data, and how to change your consent to being contacted, please visit:
Privacy information: key stage 4 and 5 and adult education - GOV.UK (www.gov.uk)
Personal Learning Record (LRS)
The information you supply is used by the the Department for Education (DfE), to issue you with a Unique Number (ULN) and to create your Personal Learning Record, as part of the functions of the DfE. For more information about how your information is processed, and to access your Personal Learning Record, please refer to:
https://www.gov.uk/government/publications/lrs-privacy-notices
Awarding Bodies
We use Pearson Edexcel, Open Awards, Highfield College, and the Construction EPA company as the awarding bodies for our qualifications and our End Point Assessments. These companies require your information in order to award the qualifications that you achieve.
Privacy policy | Legal information | Pearson
privacy-policy-centres.pdf (openawards.org.uk)
Privacy Policy | We Take Your Data Seriously | Highfield (highfieldqualifications.com)
End point assessment platform
ACE360 is an End-Point Assessment Platform that enables us to manage standards delivery and assessment efficiently, securely and without paper. It links into our Management System to ensure that data is accurate and joined up. It covers the whole learner journey, all the way through from enrolment to certification.
Global Privacy Policy - ACE360
Our e-portfolio provider
Our e-portfolios are called VQManager and Onefile, and these are used by all apprenticeship, level 2, level 3, and level 4s, along with our ACPT programme. They are hosted on a server or cloud that belongs to the developer and holds some of your personal information.
Privacy Policy - The leading e-portfolio software for training providers (skillwise.net)
Our management system
The b-Hive is our Management System (LMS) and is where your course materials are accessed. b-Hive is hosted on the developer’s server. The developer’s servers are based in the UK.
Buttercups provides an online learning experience to learners and to selected sponsoring employers through b-Hive. The online learning platforms are also accessed by Buttercups staff in order to deliver courses and programmes to learners. Within the platforms the following data sharing is in operation:
- Your name and course or programme
- You may also elect to share your photo, a short biography and personal email address with other users (this is voluntary).
- Your participation in online sessions (such as webinars, online teaching, forums or chatrooms), including your text, audio or video content may be recorded and shared.
- The platforms may plug in to other software/platforms used by Buttercups (such as Zoom) where these platforms/software are used to provide training or assessment services to you.
- Third Parties chosen by Buttercups may review your interaction with the platforms to help Buttercups continuously improve the service.
- Exam or assessment results in the platforms may also be combined to derive benchmarks of performance to allow learners to assess their performance in their chosen programme. These will only be presented in aggregate and individual results will not be disclosed.
- Any assignment or assessment uploaded or completed through the platforms will be shared with the appropriate Buttercups staff for the purposes of assessment.
- Platform data relevant to assessing your progress within the course or programme may also be shared with your sponsoring employer or third party tuition provider.
Ofsted
For those s whose funding contract is fulfilled by Buttercups, we would be required to share your personal information with Ofsted during a period of inspection.
Zoho
We use Zoho for cloud-based application and storage provider. All services the Buttercups Training utilise are based in the EU.
Microsoft
We use Office 365, Onedrive and Azure for cloud-based services, data processing and storage. The data centres utilised by Buttercups Training are UK based.
Microsoft Privacy Statement – Microsoft privacy
AWS
The bHive is hosted on Amazon Web Services. For further information see AWS privacy notice and security policies.
Venues
Venues or assessment centres you may attend as part of your studies with Buttercups Training, including assessment (such as exam halls, or study day venues).
Our advisors
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HMRC
HM Revenue & Customs, the UK Home Office, regulators and other authorities acting as independent controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Crime prevention
The police or governmental body, where the police/ governmental body make a request for personal information (including recordings from closed circuit television) to Buttercups as and when we consider necessary for the purpose of crime / fraud prevention.
The ambulance service if there is any immediate concern regarding your physical health or mental wellbeing.
Totum
We share data with Totum wherever you request Buttercups confirm your learner status to these bodies to allow you to register for their services/learner discounts.
All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will share your personal information with other Buttercups Training parties as part of our regular reporting activities on departmental performance, in the context of a business reorganisation or restructuring exercise, for system maintenance support and hosting of data; business planning/talent management initiatives, succession planning, statistical analysis; and the general management and functioning of Buttercups Training. If required, we will need to share your personal information with a regulator such as Ofsted or to otherwise comply with the law.
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 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. Your personal data may be held on the IT system of Buttercups (e.g. for the purpose of providing training or educational services to you) and/or on the IT system of another third party company (within or outside of Buttercups) within or outside the UK which is providing IT hosting or other data processing services, in accordance with Buttercups’ arrangement in place with that company.
All information that you provide to us is stored on secure servers.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites or apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements.
In some circumstances we may 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.
Your legal rights
Your duty to inform us of changes:
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please be aware that this right does not apply to exam scripts or exam marks.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and o freedoms. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
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 may 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 may 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