Terms and Conditions - CAC Training UK

Terms and Conditions

At CAC Training we commit to provide you with the best possible service at all times. If you would like to make any comments, suggestions, raise a query or make a complaint about the service you have received, please contact us on info@cactraining.co.uk. We will respond to your query within 3 – 5 working days. This policy will be kept up to date, to reflect changes in the nature and size of the business. To ensure this, the policy and its effectiveness will be reviewed annually. All Trainers will be trained in customer service standards; will exhibit candidate friendly service skills; and be knowledgeable, professional and courteous in meeting the needs of our candidates. CAC Training seeks fair, just and prompt solutions when possible to any complaints and appeals. All such issues should be directed to the Managing Director in the first instance, where they will be acknowledged and directed to the attention of the appropriate person. A complaints process is in place for they will be acknowledged and directed to the attention of the appropriate person. A complaints process is in place for any disputes; copies are available from our office.

Data Protection Statement: The information that you provide on this form will be used by CAC Training to provide you training services. In providing this service to you, your consent to your personal data being included on a computerised database. We may also use or pass to certain third parties information to present or detect crime, to protect public funds, or in other way permitted or required by law.

Marketing: From time to time we would like to contact you with course information, news and offers which we think you might find useful. If you would prefer not to receive these please contact us on info@cactraining.co.uk

Access to information: We comply fully with the provisions of the Data Protection Act 1998. Any personal or confidential information held by us about a Candidate is fully accessible to that person or body for review or editing by contacting the Managing Director.

Data Protection Act –Your sponsor will be informed of your results, progress and attendance unless your sponsor chooses not to receive this information.

You have the right to cancel the course within a 14-day cooling-off period, starting from the day of your registration. However, this 14-day cooling-off period does not apply if you have attended two or more sessions. A session is defined as two booked time slots, as explained during the induction.

No refund will be given should you wish to cancel your training once it has commenced/ you have attended the induction. Administration fees of 50% will be applied should you wish to cancel your training before starting the program. All cancellations must be in writing: by letter to: Centre of Accountancy Careers & Training, Unit CC3.47 1 – 3 Brixton Road, Oval, London SW9 6DE. Email: info@cactraining.co.uk and in each case, you must state your name, the course details and say that you would like to cancel your course. In the event of the course’s commencement, it shall be understood that the primary and exclusive duty to establish communication with the designated educational entity, hereinafter referred to as “the centre,” shall be categorically vested within the sphere of the participants, hereinafter labelled as “the students,” and not within the domain of the aforementioned “centre.” Should the aforesaid “student” fail to diligently undertake their obligatory obligation to engage in communicative interaction with the designated “training centre” throughout the predetermined temporal interval, commonly denoted as “the specified time period of the course,” then, by operation of the present clause, the course shall be deemed to have consummated its pursuit of educational objectives and met its finality upon the conclusive termination of the aforesaid “specified time period”. In pursuance of full disclosure, it is to be noted that, regrettably, fees remitted for the availing of the said educational services shall, by the weighty application of this clause, be rendered nonredeemable.

If you have selected a financing payment option, your financing arrangement will be facilitated through a third-party finance company with whom we maintain a business relationship. Upon commencement of training activities, inclusive of completion of induction or provision of portal access, the agreed-upon monthly instalment plan becomes effective. Subsequently, the agreed monthly instalments will be automatically debited from your designated account on a monthly basis, commencing from the initiation of your training.

Students must complete their training within the term limit; failure to do so may result in an automatic conclusion of the contract. Students cannot downgrade once the training has commenced. They may do so, if they have not yet started the training.

In case of missing payments or not abiding the payment plan, the student will be liable to pay the full outstanding plus any legal and incidental cost that may be incurred by the third party on behalf of CAC Training. After paying a deposit to secure a place with the program, you will have up to 4 weeks to start the training, otherwise the deposited amount will not be refunded.

CAC Training does not take any Responsibility for your personal items at the training centre. You are expected to keep your personal belongings safely. CAC Training expects cleanliness from all our candidates. You shall be asked to clear your workstation before you leave the centre. CAC Training has the right to use my picture and testimonials for marketing.

All the above terms apply to all students willing to extend and/or book for individual courses.

Data Protection Act 2018 Policy

Introduction

This Policy sets out the obligations of Centre of Accountancy Careers & Training Limited,(“the Company”) regarding data protection and the rights of customers and business contacts (“data subjects”) in respect of their personal data under Data Protection Act 2018 (Formally EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)). The Data Protection Act 2018 defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

The Data Protection Principles

This Policy aims to ensure compliance with the Data Protection Act 2018. The Data Protection Act 2018 sets out the following principles with which any party handling personal data must comply. All personal data must be:

Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the Data Protection Act 2018 in order to safeguard the rights and freedoms of the data subject.
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

The Rights of Data Subjects

The Data Protection Act 2018 sets out the following rights applicable to data subjects
The right to be informed
The right of access,
The right to rectification,
The right to erasure (also known as the ‘right to be forgotten’),
The right to restrict processing,
The right to data portability,
The right to object; and
Rights with respect to automated decision-making and profiling.

Lawful, Fair, and Transparent Data Processing

The Data Protection Act 2018 seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Data Protection Act 2018 states that processing of personal data shall be lawful if at least one of the following applies:

The data subject has given consent to the processing of their personal data for one or more specific purposes;
The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
The processing is necessary for compliance with a legal obligation to which the data controller is subject;
The processing is necessary to protect the vital interests of the data subject or of another natural person;
The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met:
The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless UK, EU or EU Member State law prohibits them from doing so);
The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
The processing relates to personal data which is clearly made public by the data subject;
The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in this Policy.

This includes:

Personal data collected directly from data subjects OR
Personal data obtained from third parties.
The Company only collects, processes, and holds personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Data Protection Act 2018).
Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.

Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed).

Accuracy of Data and Keeping Data Up-to-Date

The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.
The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

Data Retention

The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the Data Protection Act 2018 and other applicable data protection legislation.

The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
The purposes for which the Company collects, holds, and processes personal data;
Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
Details of how long personal data will be retained by the Company; and
Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

Data Protection Impact Assessments

The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data.
Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

The type(s) of personal data that will be collected, held, and processed;
The purpose(s) for which personal data is to be used;
The Company’s objectives;
How personal data is to be used;
The parties (internal and/or external) who are to be consulted;
The necessity and proportionality of the data processing with respect to the
purpose(s) for which it is being processed;
Risks posed to data subjects;
Risks posed both within and to the Company; and
Proposed measures to minimize and handle identified risks.

Keeping Data Subjects Informed

The Company shall provide the information set out in section (i) below to every data subject:

Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

a) If the personal data is used to communicate with the data subject, when the first communication is made; or
b) If the personal data is to be transferred to another party, before that transfer is made; or
c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

The following information shall be provided:
Details of the Company including, but not limited to, the identity of its Data Protection Officer;
The purpose(s) for which the personal data is being collected and will be processed (as detailed in this Policy) and the legal basis justifying that collection and processing;
Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
Where the personal data is to be transferred to one or more third parties, details of those parties;
Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place,
Details of data retention;
Details of the data subject’s rights under the Data Protection Act 2018;
Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the Data Protection Act 2018);
Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

Data Subject Access

Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer at [Centre of Accountancy Careers & Training Limited., [Unit CC3.47, 1 – 3 Brixton Road, Oval, London SW9 6DE] Tel: [02 081 586 775 / 02 081 469 666] Email:[ info@cactraining.co.uk]
Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
All SARs received shall be handled by the Company’s Data Protection Officer.
The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

Rectification of Personal Data

Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so),
d) The personal data has been processed unlawfully;
e) The personal data needs to be erased in order for the Company to comply with

a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Restriction of Personal Data Processing

Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

Objections to Personal Data Processing

Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling) and processing for scientific and/or historical research and statistics purposes.

Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Data Protection Act 2018, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company:

Data Collected

We may collect the following Data, which includes personal Data, from you:
1. Name;
2. Date of birth;
3. Gender;
4. Job title;
5. Profession;
6. Contact information such as email addresses and telephone numbers;
7. Demographic information such as postcode, preferences and interests;
8. Financial information such as credit / debit card number;
9. IP address (automatically collected);
10. Web browser type and version (automatically collected);
11. Operating system (automatically collected);
12. A list of URLs stating with a referencing site, your activity on this Website, and the site you exit to (automatically collected); in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:
1. Data is given to us by you;
2. Data is received from other sources; and
3. Data is collected automatically.

Data that is given to us by you

Centre of Accountancy Careers & Training Ltd will collect your Data in a number of ways, for example:
1. When you contact us through the Website, by telephone, post, e-mail or through any other means;
2. When you register with us and set up an account to receive our products/services
3. When you complete surveys that we use for research purposes (although you are not obliged to respond to them);
4. When you make payment to us, through this Website or otherwise;
5. When you elect to receive marketing communications from us;
6. When you use our services;

in each case, in accordance with this privacy policy.

Data that is received from third parties

Centre of Accountancy Careers & Training Ltd will receive Data about you from
1. Reed
2. Total Jobs
3. Social Media
4. Third Party Vendors

Data that is received from publicly available third parties sources

We will receive Data about you from the following publicly available third party sources:
1. Publically available third party sources

Data that is collected automatically

The extent that you access the Website, we will collect your Data automatically, for example:
1. We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the data, times and frequency with your access the Website and the way you use and interact with its content.
2. We will collect your data automatically via cookies, in line with the cookies settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when suing our Website. Specifically, Data may be used by us for the following reasons:
1. Internal record keeping;
2. Improvement of our products / services;
3. Transmission by email od marketing materials that be of interest to you;
4. Contact for market research purpose which may be done using email, telephone, fax, or mail. Such information may be used to customise or update the Website;

in each case, in accordance to the privacy policy.

We may use your Data for above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
For the delivery of direct marketing to you via email, we’ll need your consent, whether via an opt-in or soft-opt-in:
1. Soft-opt-in is specific type of consent which applies when you previously engaged with us (for example, you contact us to ask us for more details about a particular product / services, and we are marketing similar products / services). Under “soft-opt-in” consent, we will take your consent as given unless you opt-out.
2. For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box what we’ll provide.
3. If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and or taking steps, at your request, to enter into such contract.

Who we Share Data with

We may share your Data with the following groups of people for the following reasons:
1. Our employees, agents and or professional advisers, to obtain advice from professional advisers;
2. Relevant authorities, to facilitate the detection of crime or the collection of taxes or duties; in each case, in accordance with this privacy policy.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example
1. Access to your account is controlled by a password and a user name that is unique to you.
2. We store your Data on secure servers.
3. Payment details are encrypted using SSL technology (typically you will see a lick icon or green address bar (or both) in your browser when we use this technology.
Technical and organisation measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: info@cactraining.co.uk
If you want detailed information from Get Safe Online on how to protect your information and your computer and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for period necessary to fulfil the purpose outlined in this privacy policy or until you request that the Data be deleted.
Even if we delete your data, it may persist on backup or archive media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:
1. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with the access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reason why.
2. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
3. Right to erase – the right to request that we delete or remove your Data from our systems.
4. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
5. Right to data portability – the right to request that we move, copy or transfer your Data.
6. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where is our legal basis for processing your Data), please contact us via this e-mail address: info@cactraining.co.uk
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

All emails containing personal data must be encrypted using Encryption software;
All emails containing personal data must be marked “confidential”;
Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using deletion software;
Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Registered or 1st or 2nd Class Signed For post; and
All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

All electronic copies of personal data should be stored securely using passwords and data encryption;
All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
All personal data stored electronically should be backed up at least daily with backups stored onsite. All backups should be encrypted using data encryption’
No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Data Protection Act 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

Data Security – Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from The Data Protection Officer,
No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of The Data Protection Officer,
Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of [Adnan Syed and Umar Riaz] to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates after the updates are made available by the publisher or manufacturer, unless there are valid technical reasons not to do so; and
No software may be installed on any Company-owned computer or device without the prior approval of the Company.

Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Data Protection Act 2018 and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Data Protection Act 2018 and this Policy by contract;
All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Data Protection Act 2018; and
Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Transferring Personal Data to a Country Outside the EEA

The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Data Protection Act 2018); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
The transfer is made with the informed consent of the relevant data subject(s);
The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
The transfer is necessary for important public interest reasons;
The transfer is necessary for the conduct of legal claims;
The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

Data Breach Notification

All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
Data breach notifications shall include the following information:
The categories and approximate number of data subjects concerned;
The categories and approximate number of personal data records concerned;
The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
The likely consequences of the breach;
Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

Registered Office

Centre of Accountancy Careers & Training Ltd

3^rd floor Unit 3.47 Canterbury Court

1 – 3 Brixton Road, Oval, London SW9 6DE