Privacy Policy.

Last updated 6th June 2023

Introduction 
Welcome to BQSL’s privacy policy. This privacy policy applies to Study Centre’s, prospective Study Centre’s, Candidates and prospective Candidates who are interested in or taking a course with a Study Centre for the purpose of the Candidate/prospective Candidate obtaining a qualification.BQSL respects your privacy and is committed to protecting your Personal Data. This privacy policy will inform you as to how we look after your Personal Data and tell you about your privacy rights and how the law protects you. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE2. THE DATA WE COLLECT ABOUT YOU3. HOW IS YOUR DATA COLLECTED?4. HOW WE USE YOUR DATA 5. DISCLOSURES OF YOUR DATA 6. INTERNATIONAL TRANSFERS7. DATA SECURITY8. DATA RETENTION9. YOUR LEGAL RIGHTS10. GLOSSARY


1. Important information and who we are
Purpose of this privacy policy
This privacy policy describes the types of Personal Data we may collect from you or that you may provide on the www.bsql.org website (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Data. It also describes the choices available to you regarding our use of your Personal Data and how you can access and update it and explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint.

This privacy policy is a legally binding agreement between you (“User”, “you” or “your”) and BSQL Limited (“we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this privacy policy. This privacy policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).  We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to products and services we offer to individuals and our wider operations in the European Economic Area (EEA).

The website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.

Controller
BQSL Limited trading as BQSL is the controller and responsible for processing your Personal Data (collectively referred to as “we”, “us”, or “our” in this privacy policy). BQSL Limited (company number 12988087) is a company registered in England and Wales, the registered office address of which is at BQSL Limited, Suite 3, 2nd Floor, Didsbury House, 748 - 754 Wilmslow Road,Manchester, United Kingdom, M20 2DW.  We are registered as a data controller with the Information Commissioner’s Office (ICO) under registration number ZB239856.

We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: BQSL Limited
Email address: privacy@bqsl.org
Postal address: BQSLLimited, Suite 3, 2nd Floor, Didsbury House, 748 - 754 Wilmslow Road,Manchester, United Kingdom, M20 2DW.
Telephone number: 01244 683689

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 10th October 2023.

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.

Third-party links and Third Parties
This website 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 statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

2.The data we collect about youPersonal 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:

• Identity Data includes first name, maiden name, last name, job title, organisation name, username or similar identifier and login credentials to our services, marital status, title, date of birth and gender.
• Contact Data includes billing address, shipping/delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details, fraud check details.
• Order Details such as reference numbers or words that you have added to your order that may refer to personal details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 our own websites.  It also includes the type of mobile device you use, a unique device identifier, your mobile operating system and time zone setting.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use our websites, mobile application, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Email content, postal content and telephone content data which includes information that you have provided or that we have requested from you by email, post or telephone.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will 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.

We do not collect any of the following Special Categories of Personal Data about you (this includes 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 biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide 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 Personal 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 provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. How is your data collected?

We use different methods to collect Personal Data from and about you including through:

Direct interactions.
You may give us your Identity, Contact, Financial, Profile and Email Personal 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 our services;
• create an account on our website (or when an account is created for you);
• subscribe to our service or publications;
• sign up to our newsletters;• request marketing information or literature to be sent to you;
• request a quotation;
• enter a competition, promotion or survey; or
• give us feedback or contact us by email, telephone or post.

Automated technologies or interactions.
As you interact with our website and use our services, we will 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.  Please see our cookie policy at www.bqsl.org/cookie-policy for further details.

Third parties or publicly available sources.
We may receive Personal Data about you from various third parties and public sources as set out below:

Technical Data from the following parties:
(a) analytics providers such as Google based inside the UK; and
(b) search information providers such as Google based inside the UK.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based the UK.
• Identity Data from credit check companies;
• Identity and Contact Data from data brokers or aggregators;
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
• Fraud risk data from providers of payment support; and
• Payment and address data.

4. How we use your 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.• 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 obligation.

• Where you have specifically consented to us using your Personal Data in a particular way (for example, when you consent to our use of non-essential cookies or to receiving our publications or newsletters). You have the right to withdraw consent at any time. Please see the “Opting out” section below for more information on how to unsubscribe from marketing.

Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing and promotional emails 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 of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity
Type of data
Lawful basis for  processing including basis of legitimate interest
To register you as a new member (including access to any portal we may provide)
(a) Identity
(b) Contact
(a) Necessary for our legitimate interests (to enable you  to register with the business in anticipation of completing an order,  enabling the formation and performance of a contract with you)
(b) Performance of a contract with you  
To register you as a new customer or candidate
(a) Identity
(b) Contact
Performance of a contract with you
To register you as a new BQSL portal and/orWebsite User
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (to enable you to register with the business in anticipation of completing an order, enabling the formation and performance of a contract with you)
(b) Performance of a contract with you
To process and deliver the services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Order
(e) Profile
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover  debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) 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
(a) Performance of a contract with you
(b) 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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) 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)
(b) Necessary to comply with a legal obligation
To deliver relevant website 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, products/services, marketing, customer 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 updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(e) Email
Necessary for our legitimate interests (to develop our products/services and grow our business)
Enquiry handling and ongoing support
(a) Identity
(b) Contact
(c) Profile
(d) Email
Necessary for our legitimate interests (to assist you with products and service selection, to recommend suitable products for your requirements, to assist and support you with your purchase, to provide the support that we aim to deliver to all customers, and to ensure the safety of our customers when using our products and services)
To receive and respond to enquiries from you about our services including potential members
(a)Identity
(b)Contact
(c) Marketing and Communications
(a)  Necessary for our legitimate interests (to engage with you and to facilitate  the growth of our business)
(b)  Necessary to comply with a legal or regulatory obligation


Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:

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 services from us and you have not opted out of receiving that marketing, if you provided us with details by subscribing to our newsletters, if you provided us with details when you entered a competition or registered for a promotion, and in in each case,  you have not opted out of receiving that marketing or promotional content.

Third-party marketing
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a service purchase, service experience or other transactions.

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 www.bqsl.org/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.

In some circumstances you can ask us to delete your data: see section 9. headed Your Legal Rights.

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.

5. Disclosures of your data

We may share your Personal Data with the parties set out below for the purposes set out in the table Purposes for which we will use your Personal Data above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table Purposes for which we will use your Personal Data above.  
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. International transfers

Many of our external third parties are based outside the UK so their processing of your Personal Data will involve a transfer of data outside the UK.

Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give Personal Data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK.

7. 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.

Access to the BQSL portal account is controlled by a password and username that is unique to you.

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.

8. Data retention

How long will you use my Personal Data for?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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, regulatory, tax, accounting or other requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:
• Request access to your Personal Data.
• Request correction of your Personal Data.
• Request erasure of your Personal Data.
• Object to processing of your Personal Data.
• Request restriction of processing your Personal Data.
• Request transfer of your Personal Data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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 could 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 could 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

External Third Parties
• Service providers acting as processors based in the United Kingdom and European Union who provide IT and system administration services.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Third party suppliers or subcontractors based in the United Kingdom that may provide services directly to you in pursuance of an order placed with us. In this instance we may provide your name, address, email address and telephone number to a supplier in order for that third party supplier or subcontractor to deliver a service directly to you.  As part of this delivery of service, your details may also be passed to a postal or courier service to effect delivery.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If this happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice.

Personal Data means collectively all information that you submit to BQSL via the Website, over the phone, via the hardware and software (including for the avoidance web application) provided or any other method of contact that you choose. This definition incorporates, where applicable, the definitions provided in data protection laws. When providing the data of a third party (i.e., a candidate/prospective candidate) you must ensure you have their permission to share their Personal Data with us for all the purposes detailed in the Section ‘Purposes for which we will use your Personal Data’.

Website means www.bsql.org, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

YOUR LEGAL RIGHTS
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.
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.
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 freedoms.
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 Personal Data's accuracy.
• Where our use of the Personal Data is unlawful, but you do not want us to erase it.
• Where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your Personal Data, but we need to verify whether we have overriding legitimate grounds to use it.

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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