Scope

We respect the right to privacy of every individual and to the right to the protection of their personal data. We are fully committed to upholding the rights and principles of the Data Protection Act 2018. We provide a robust regime of protections and we cultivate a culture of data protection throughout the organisation. The purpose of this privacy policy is to provide information related to the processing of personal data by FRS Employability, how we collect, use and safeguard personal data.

Personal data can be obtained by FRS E in the following ways:

  1. Directly from the Department of Communities

  2. Via our on-line registration website where individuals may provide personal data

  3. Through the Sub-contractors we engage to deliver training modules

  4. Via cookies and other related technologies.

Usage Data

We may collect information about visitors to our website that your browser sends when you visit our site or access it through a mobile device. This usage data may include information such as your computer’s internet protocol address, browser type, browser version, the pages of our site that you visit, time spent on the site, unique identifiers and other diagnostic data. When accessed via a mobile device, the data may include your mobile device unique id, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser used, unique identifiers and other diagnostic data.

Tracking and Cookies Data

We use cookies and similar tracking technologies to track the activity on our website. Cookies are files with a small amount of data which may include an anonymous unique identifier.  Cookies are sent to your browser from a website and stored on your device. 

You can set your browser to refuse all cookies and to indicate when a cookie is being sent. However, in some cases, some of our website features may not function as a result. Please refer to the Cookies policy on our website for more detailed information.

Data Controller

FRS Employability is a Data Processor, we are responsible for the protection of your rights on behalf of the Department of Communications who is the Data Controller under the UK General Data Protection Regulations (UK GDPR) and the Data Protection Act  2018. A ‘data controller’ means “the natural or legal person, public authority, agency, or other body which, alone or in conjunction with others determines the purposes and means of the processing of personal data”.

 

Data Processor

A Data Processor is anyone who acts on behalf of the Data Controller for the processing of personal data.
A data processor means “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”.

 

Sub-Processors

We engage the services of Sub-Contractors who may process your personal data. The agreement between FRS Employability and each Third-Party processor will contain a signed written data processing agreement which provides for the same protection of your data protection rights.  The sub-processors we engage are:-

  • Bolster Community - Unit 1 Whitegates Business Park, Newry BT35 6UA

  • Include Youth - 5th Floor 14 College Square North, Belfast, BT1 6AS

  • Stepping Stones - 39 Seymour Street, Lisburn BT27 4SY

Data that may be shared with FRS Employability

The Department of Communities for the purpose of providing training services either in house, on-line, or at our premises, may share personal data at the time of referral to the training program for registration purposes. The data categories that may be shared include the following: -

  • Claimant name;

  • Claimant address;

  • Claimant contact details;

  • WRES module/s to be delivered;

  • Claimant’s choice of delivery method of each module/s

  • Where appropriate that the claimant is receiving JSA

FRS Employability may collect additional data while you are on a training program with us, this may include the following: -

  • Competencies, qualifications, certifications, you have gained with us

  • Data relating to any change of your circumstances, such as change of address or contact details

  • Data that identifies any other training needs or skills gaps,

  • Data relating to any future courses you may wish to attend

FRS Employability will only process Sensitive, Special Categories of Personal Data if this data is provided by the data subject and where explicit consent is given. This may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data. The sensitive data that we process is generally related to health data for the purpose of identifying any special requirements the participant may have.

Special Category questions related to unspent criminal convictions may be processed only where explicit consent of the participant has been provided

Data Processing

Information collected will primarily be used to manage training course registration as well as provide end users with a personalized internet training experience that delivers information, resources, and services that are most relevant and professionally helpful. We will not share information you provide to us, without your consent, unless we say so in this Privacy Policy, or when we believe in good faith that the law requires it.

FRS Employability fully respects your right to privacy and will not collect any personal information about you on this website without your explicit permission (where applicable). Any personal information which you volunteer to us will be treated with the highest degree of security, integrity and confidentiality, in accordance with our obligations outlined under the General Data Protection Regulation (GDPR), the Data Protection Acts Ireland 2018, Electronic Communication Regulation and other similar legislation.

By accessing our websites and availing of our services, you agree to this Privacy Policy and to be bound by our terms of use.

 

New Registrations

When a new user registers on our website, a login account will be created for one or more of the purposes outlined below;

  1. registration for programs and services

  2. registration for events or courses online

  3. participation in online surveys, submitting questions or comments

Once the account is created, a notification will be sent to the email address provided. A registered member will be able to manage his or her account the same way existing members manage their accounts by updating their details, registering for courses or opting-out of some or all future communication.

Children

We do not knowingly solicit data online from or market online to children under the age of 16.  Parental consent is required for anyone who wishes to participate who is under the age of 16 years

Consent

Customers referred for training courses are asked to provide specific written consent in areas, they are: 

  • Consent to process Health Data

  • Consent to process criminality questions      

Where consent is the lawful basis relied upon for processing, you have the right to revoke this consent without detriment, as freely as it was given. You may revoke consent in writing or email to the Data Protection Officer at the address listed below.   

 

Data Security

FRS Employability have implemented appropriate technical and organisational measures to ensure a very high level of security and encryption for the personal data that we hold.  We use industry standard technologies and security measures to safeguard your information, and we keep strict security monitoring standards to ensure the confidentiality and integrity of the data and to protect the data against unauthorized access, unauthorized alteration, accidental loss, destruction or damage.  This data protection policy is supported by our Information Security policies, and ongoing employee training and awareness programs.

Safeguarding Information

FRS Employability understands the importance of technical and online security, and as such has taken several steps to enhance the protection of personal information sent to or from FRS Employability over the Internet. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts and best intentions, FRS Employability cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services.

  

Links to Non-FRS Websites

Please be aware that despite efforts and measures we have taken to protect personal data, other Internet sites that link to the FRS site or to an FRS email may contain online privacy provisions that differ from these. To ensure your privacy is protected, we recommend that you review the privacy statements of other Internet sites you visit.

Disclosures

All information you provide to us will be treated with strictest confidence in line with national and EU data protection laws, unless mandated by law or with your explicit consent, FRS Employability will not disclose any personal or personally identifiable information about you to a third party under any circumstances unless;

  • disclosure reasonably necessary to perform a service or deliver a product or publication;

  • you have given explicit consent;

  • disclosure permitted under this Privacy Policy;

  • disclosure is required by statute, regulation or court order

  • such disclosure is in the good-faith belief that such action is necessary to:

  1. conform to legal requirements or comply with legal process served on FRS Employability

  2. protect and defend the legitimate rights of FRS Employability

  3. protect the personal safety of FRS personnel or members of the public in urgent circumstances;

  4. enforce our Privacy Policy.

Internal purposes: FRS will avail of summary reports, which will be used to assess and measure the effectiveness of the course initiative. It may also highlight useful trends that require some action to be taken e.g., advising participants of suggested courses to take, to help them achieve their professional objectives, unless you have chosen to opt out of future notification.

Transfer of Data

FRS Employability shall not permit any party to process (including holding, rendering, transferring or storing) any personal data outside of the European Economic Area (EEA is the EU 27 plus Iceland, Norway and Liechtenstein), without either and ‘Adequacy Decision’ under Article 45, or the appropriate safeguards as required in Article 46 e.g., Standard Contractual Clauses being in place to ensure the protection of the data.

 

Data Retention

We will only hold data as long as is necessary in accordance with the Operational Requirements of the Data Controller i.e., The Dept. for Communities. Data will be retained in compliance with UK GDPR Article 5 1(e) i.e., “kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are being processed”.  Data will be retained for up to six years for the purpose of the program.   The data shall either be deleted or destroyed when the data is no longer required by FRS Employability for the purpose for which it was collected.  Data required for statistical or research purposes will be anonymised in a form that does not make the data subject identifiable or re-identifiable.

Rights of the Data Subject

 

1. Right of Access

To obtain a copy of your personal information, you can email or write to us at at the address listed below.  You can also formally email us at dpofficer@frsemployability.ie. Please note that all access requests received via email will be responded to in like manner unless otherwise agreed. You may be required to provide us with one form of identification such as a copy of your passport or driver’s license. It will be destroyed once the subject access request has been honoured.

To facilitate and speed up your request, you are advised to provide as much information as possible. Requesting for “all information” may be deemed disproportionate and can result in unnecessary delays to your request. If you require specific information, please be clear about the information you require.

 

2. Right to have inaccuracies corrected

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.  Factually, incorrect data can be rectified however; it is your responsibility to provide us with accurate and truthful personal information. FRS Employability Ltd. will not be held liable for any information that is provided to us that is incorrect.

3. Right to the erasure of personal data

  1.  You have the right to request erasure of your personal data where one of the following conditions applies;

  2. You withdraw consent to processing of your personal data and there are no subsequent grounds for further processing;

  3. We must comply with a legislative requirement (e.g. we will retain financial transactional information for seven years in compliance with requirement of the Finance Acts);

4. Right to object to processing of personal data

You have the right to prevent use of your personal details. You have the right to refuse your data to be used for other purpose(s) e.g. statistical analysis or research. 

You have the right to prevent use of your personal data for direct marketing purpose.

 

 5. Right to object to automated decision making

An automated decision is a decision which is made entirely by a computer system, without the intervention of a person. FRS Employability Ltd. systems do not use automated processes to make decisions about our customers without the intervention of an individual.

6. Right to data portability

Data subjects (customers) have the right to request their data from one controller so that it can be given to another controller (company). FRS Employability Ltd. will act on the instructions of the data subject if this request is made.

 

7. Right to be notified of a data breach

FRS Employability Ltd. will without undue delay notify you when we reasonably believe that there has been a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data processed by the company.  We will investigate the Incident, take necessary steps to eliminate or contain the impact of the Incident and keep you advised of the status of the Incident and all related matters.  We will write out to you to confirm what happened and which of your data was affected.  We will also inform the Office of the Data Protection Commission; of any such breach should they wish to undertake an investigation

Right to complain

As well as the rights detailed above, you also have the right to complain if you feel that your personal data has been illegally accessed, please contact: -

 

  1. FRS Employability Ltd. Data Protection Officer – see contact details listed below

 

You also have the right to complain to the Supervisory Authority at the Information Commissioner’s Office (ICO)– see contact details listed below

 

Marketing

From time to time, we may use your personal data to contact you with details about our, services and events which we feel may be of interest to you. We may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our website or by contacting us (see contact information at section ‘Who we are’ and who is responsible for your personal data above). You can also unsubscribe from any email marketing using the links provided in the emails we send to you.

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 or by contacting us at any time.

 

FRS Employability Data Protection Training and Awareness

In addition to the technical and organisational security measures we have in place, every FRS Employability Ltd. staff member completes data protection training at induction. Data production training is further enhanced by the completion by all staff of a data protection training module and assessment which is completed on an annual basis.   Data protection is supported through ongoing reviews of all our office locations, and by Data Champions who help to ensure that staff remain vigilant on a day to day basis about the protection of the personal data that we hold.  FRS Employability Ltd. employees participate in an annual information security awareness campaign.

Changes to our privacy policy

FRS Employability Ltd. keeps this privacy policy under regular review, any updates made are placed on this web page. We reserve the right to amend this without notice to end users at any time, for any reason, and will signal a change by revising the "Last updated" date at the bottom of this page.

We may occasionally update this privacy statement to reflect regulatory changes or industry best practices. Therefore, we would suggest you periodically review this statement to stay informed about how we are meeting our obligations under the Data Protection Acts. Your continual use of the service constitutes your agreement to this privacy statement and any updates.

Contact Details

Email: hello@frsemployability.co.uk, dpo@frsemployability.co.uk

Phone: 0800 029 1244

Post: DPO, FRS Employability, 6B Upper Water Street, Newry, BT34 1DJ

Supervisory Authority – Information Commissioner’s Office - Click here