This policy explains how we collect, use, and protect your personal information. We are committed to safeguarding your data and ensuring transparency regarding its usage. Below you will find detailed information on our data practices and your rights concerning your personal data.

IKON Training Limited is committed to protecting the privacy and security of all information.

This privacy policy describes how we collect and use personal information during in accordance with the General Data Protection Regulation (GDPR).

It applies to all employees, training delegates, clients, and contractors.

IKON Training Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information. We are required under data protection legislation to publish information contained in the privacy policy. This policy applies to current and former employees, delegates, clients and contractors and does not form part of any contract of employment or other contract to provide services. We may update this policy at any time. It also applies to commissioning organisations.

Prior to developing and delivering training we will agree on how and why information will be stored, and shared in line with data protection laws. It is important to read this policy, together with any privacy notice we may provide on specific occasions when we are collecting or processing personal information, to understand how and why we use information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes.
6. Kept securely.

The kind of information we hold

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). There are “special categories” of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information:

• Personal contact details such as name, title, addresses, telephone numbers
• Personal email addresses
• Date of birth
• Gender
• Next of kin and emergency contact information
• National Insurance number
• Bank account details, payroll records and tax status information
• Salary, annual leave, pension, and benefits information
• Start date
• Location of employment or workplace
• Copy of driving licence
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Employment records (including job titles, work history, working hours, training records and professional memberships)
• Performance information
• Disciplinary and grievance information
• Information about your use of our information and communications systems
• Photographs

We may also collect, store, and use the following “special categories” of more sensitive personal information:

• Information about your health, including any medical condition, health, and sickness records. Information about criminal convictions and offences

How is personal information collected?

We typically collect personal information about employees, workers and associates through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We will collect additional personal information during job-related activities throughout the period of you working for us.

How we will use this information

We will only use personal information when the law allows us to. Most commonly, we will use personal information in the following circumstances:

1. Where we need to perform a contract
2. Where we need to comply with a legal obligation
3. Where it is necessary for legitimate interests and fundamental rights do not override those interests.

We may also use personal information in the following situations, which are likely to be rare:

1. Where we need to protect interests
2. Where it is needed in the public interest

Situations in which we will use personal information

We need all the categories of information in the list above primarily to allow us to perform our contract and to enable us to comply with legal obligations. In
some cases, we may use personal information to pursue legitimate interests of our own or those of third parties, provided interests and fundamental rights do not override those interests.

The situations in which we will process personal information are listed below.

• Making a decision about recruitment or appointment.
• Determining the terms of work.
• Checking legal entitlement to work in the UK.
• Paying deducting tax and National Insurance contributions.
• Liaising with a pension provider.
• Administering the contract.
• Business management and planning, including accounting and auditing.
• Conducting performance reviews, and determining performance requirements.
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a job or task, including decisions about promotions.
• Gathering evidence for possible grievance or disciplinary hearings.
• Making decisions about continued employment or engagement.
• Making arrangements for the termination of a working relationship.
• Education, training and development requirements.
• Dealing with legal disputes, including accidents at work.
• Ascertaining fitness to work.
• Managing sickness absence.
• Complying with health and safety obligations.
• To prevent fraud.
• To monitor use of our information and communication systems.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
• Equal opportunities monitoring.

Failure to provide personal information

Failure to provide certain information when requested means we may not be able to perform the contract we have entered or we may be prevented from
complying with our legal obligations.

Change of purpose

We will only use personal information 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 we need to use personal information for an unrelated purpose, we will notify and explain the legal basis which allows us to do so.

Please note that we may process personal information without knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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 may process special categories of personal information in the following circumstances:

1. In limited circumstances, with explicit written consent.
2. Where we need to carry out our legal obligations and in line with data protection policy.
3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy.
4. Where it is needed to assess working capacity on health grounds, subject to confidentiality.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect interests or where information is public.

Our obligations as an employer

We will use particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and
  other laws
• We will use information about physical or mental health, or disability status, to ensure health and safety in the workplace and to assess fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and administer benefits.

We will use information about race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual life or sexual orientation, to ensure
meaningful equal opportunity monitoring and reporting

Do we need consent?

We do not need consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach individuals for written consent to allow us to process certain particularly sensitive data. If we do so, we will provide full details of the information that we would like and the reason we need it, so that careful consideration be made to consent. Be aware that it is not a condition of contract with to agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided, we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect interests (or someone else’s interests) and people are not capable of giving consent, or where information is public. We do not envisage that we will hold information about criminal convictions.

Automated decision-making

We do not envisage that any decisions will be taken using automated means, however we will notify people in writing if this position changes.

Data sharing

We may have to share data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of data and to treat it in accordance with the law. We may transfer personal information outside the EU.

If we do, expect a similar degree of protection in respect of personal information.

Why might you share personal information with third parties?

We may share personal information with third parties where required by law, where it is necessary to administer the working relationship or where we have another legitimate interest in doing so.

Which third-party service providers process personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: Human Resources, payroll, pension administration, benefits provision and administration, IT services.

How secure is information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect personal information in line with our policies. We do not allow our third-party service providers to use personal data for their own purposes. We only permit them to process personal data for specified purposes and in accordance with our instructions.

When might you share personal information with other entities in the group?

We will share personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of information. Details of these measures are available upon request. Third parties will only process personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Directors. We have put in place procedures to deal with any suspected data security breach and will notify any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will we use information for?

We will only retain personal information 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. 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 personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise personal information so that it can no longer be associated, in which case we may use such information without further notice. Once someone is no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.

Rights in connection with personal information

Under certain circumstances, by law people have the right to:

• Request access to personal information (commonly known as a “data subject access request”). This enables a copy of the personal information we hold and to check that we are lawfully processing it.
• Request correction of the personal information that we hold. This enables any incomplete or inaccurate information we hold corrected.
• Request erasure of personal information. This enables to delete or remove personal information where there is no good reason for us continuing to process it and the right to ask us to delete or remove personal information where someone has exercised a right to object to processing (see below).
• Object to processing of personal information where we are relying on a legitimate interest (or those of a third party) and there is something about a particular situation which makes someone object to processing on this ground. People have the right to object where we are processing personal information for direct marketing purposes.
• Request the restriction of processing of personal information. This enables you to ask us to suspend the processing of personal information, for example to establish accuracy or the reason for processing it.
• Request the transfer of personal information to another party.
• To review, verify, correct or request erasure of personal information, object to the processing of your personal data, or request that we transfer a copy of personal information to another party, people can contact the Directors in writing.

No fee usually required

No one will have to pay a fee to access personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need

We may need to request specific information to help us confirm identity and ensure right to access the information (or to exercise any of other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where consent to the collection, processing and transfer of personal information for a specific purpose, the right to withdraw your consent for that specific processing at any time. To withdraw consent, please contact the Directors. Once we have received notification of withdrawn consent, we will no longer process information for the purpose or purposes originally agreed to, unless we have another legitimate basis for doing so in law.

Data Protection Complaints

At IKON Training, we are committed to protecting personal information and handling it fairly, lawfully and transparently. If an individual believes we have not processed their personal data in accordance with data protection legislation, they have the right to raise a data protection complaint.

A complaint may relate to any aspect of how IKON Training has collected, stored, used, shared or otherwise processed personal data.

How to make a complaint

Complaints can be submitted by email, in writing or by completing our Data Protection Complaint Form available via our website.

Please include:

• Your name and contact details.
• Details of the concern or complaint.
• Relevant dates or correspondence.
• The outcome you are seeking.
• Any supporting information you believe may assist our investigation.

Complaints should be sent to:

Email: [email protected]

Our process

Upon receiving a complaint, IKON Training will:

• Acknowledge receipt within 30 calendar days.
• Review the complaint objectively and investigate the circumstances.
• Contact you if further information is required.
• Provide a response outlining our findings and any actions taken without undue delay.

Where appropriate, we will take reasonable steps to rectify any identified issues and improve our processes.

Escalating a complaint

If you remain dissatisfied after receiving our response, you have the right to raise your concerns with the Information Commissioner’s Office (ICO).

Website: https://ico.org.uk

Data protection officer

We have a data protection officer (DPO) to oversee compliance with this privacy notice. Any questions about this privacy notice or how we handle your personal
information, contact the DPO. People 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.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide a new privacy notice when we make any substantial updates.

For any enquiries about this policy or your personal information, please contact our Data Protection Officer: Louise Ballard, Operations Director at [email protected], or via post at IKON Training Ltd, Unit 5, Three Rivers Business Centre, Felixstowe Road, Ipswich, IP10 0BF.

This policy was last updated: 2026