This Policy sets out the obligations of Skills for Logistics Ltd, a company registered in The United
Kingdom under number 09617811, whose registered office is at Skills for Logistics Ltd, The Old
Brewery, 9-11 Lodway, Pill, Bristol BS20 0DH (“the Company”) regarding data protection and
the rights of apprentices, employers, training providers, assessors, trainers and employees
(“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data
Protection Regulation (“GDPR”).
The GDPR 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
always be followed 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.
2. The Data Protection Principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following
principles with which any party handling personal data must comply. All personal data must
2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2.2 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.
2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for
which it is processed.
2.4 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.
2.5 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
Skills for Logistics Ltd
The Old Brewery
9 -11 Lodway, Pill
organisational measures required by the GDPR in order to safeguard the rights and
freedoms of the data subject.
2.6 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.
3. The Rights of Data Subjects
The GDPR sets out the following rights applicable to data subjects (please refer to the parts of
this policy indicated for further details):
3.1 The right to be informed (Section 12).
3.2 The right of access (Section 13);
3.3 The right to rectification (Section 14);
3.4 The right to erasure (also known as the ‘right to be forgotten’) (Section 15);
3.5 The right to restrict processing (Section 16);
3.6 The right to data portability (Section 17);
3.7 The right to object (Section 18); and
3.8 Rights with respect to automated decision-making and profiling (Sections 19 and 20).
4. Lawful, Fair, and Transparent Data Processing
4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and
transparently, without adversely affecting the rights of the data subject. The GDPR
states that processing of personal data shall be lawful if at least one of the following
4.1.1 The data subject has given consent to the processing of their personal data for
one or more specific purposes;
4.1.2 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;
4.1.3 The processing is necessary for compliance with a legal obligation to which the
data controller is subject;
4.1.4 The processing is necessary to protect the vital interests of the data subject or
of another natural person;
4.1.5 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
4.1.6 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.
4.2 If the personal data in question is “special category data” (also known as “sensitive
personal data”) (for example, data concerning the data subject’s race, ethnicity, politics,
religion, trade union membership, genetics, biometrics (if used for ID purposes), health,
sex life, or sexual orientation), at least one of the following conditions must be met:
4.2.1 The data subject has given their explicit consent to the processing of such data
for one or more specified purposes (unless EU or EU Member State law
prohibits them from doing so);
4.2.2 The processing is necessary for the purpose of carrying out the obligations and
exercising specific rights of the data controller or of the data subject in the field
of employment, social security, and social protection law.
4.2.3 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;
4.2.4 The data controller is a foundation, association, or other non-profit body with
a political, philosophical, religious aim, and the processing is carried out in the
course of its legitimate activities, provided that the processing relates solely to
the members or former members of that body or to persons who have regular
contact with it in connection with its purposes and that the personal data is
not disclosed outside the body without the consent of the data subjects;
4.2.5 The processing relates to personal data which is clearly made public by the
4.2.6 The processing is necessary for the conduct of legal claims or whenever courts
are acting in their judicial capacity;
4.2.7 The processing is necessary for substantial public interest reasons, on the basis
of EU or EU Member State law which shall be proportionate to the aim
pursued, shall respect the essence of the right to data protection, and shall
provide for suitable and specific measures to safeguard the fundamental rights
and interests of the data subject;
4.2.8 The processing is necessary for the purposes of preventative or occupational
medicine, for the assessment of the working capacity of an employee, for
medical diagnosis, for the provision of health or social care or treatment, or
the management of health or social care systems or services on the basis of EU
or EU Member State law or pursuant to a contract with a health professional,
subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
4.2.9 The processing is necessary for public interest reasons in the area of public
health, for example, protecting against serious cross-border threats to health
or ensuring high standards of quality and safety of health care and of medicinal
products or medical devices, on the basis of EU or EU Member State law which
provides for suitable and specific measures to safeguard the rights and
freedoms of the data subject (in particular, professional secrecy); or
4.2.10 The processing is necessary for archiving purposes in the public interest, or
historical research purposes, or statistical purposes in accordance with Article
89(1) of the GDPR based on EU or EU Member State law which shall be
proportionate to the aim pursued, respect the essence of the right to data
protection, and provide for suitable and specific measures to safeguard the
fundamental rights and the interests of the data subject.
5. Specified, Explicit, and Legitimate Purposes
5.1 The Company collects and processes the personal data set out in Section 21 of this
Policy. This includes:
5.1.1 Personal data collected directly from data subjects, our website and publicly
5.1.2 Personal data obtained from third parties.
5.2 The Company only collects, processes, and holds personal data for the specific purposes
set out in Section 21 of this Policy (or for other purposes expressly permitted by the
Data subjects are informed of the purpose or purposes for which the Company uses their
personal data. Please refer to Section 12 for more information on keeping data subjects
6. 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) as under Section 5, above, and as set out in Section 21, below.
7. Accuracy of Data and Keeping Data Up-to-Date
7.1 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, as set out in Section 14, below.
7.2 The accuracy of personal data shall be checked when it is collected. If any personal data
is found to be inaccurate or out-of-date at any time then all reasonable steps will be
taken without delay to amend or erase that data, as appropriate.
8. Data Retention
8.1 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
8.2 When personal data is no longer required, all reasonable steps will be taken to erase or
otherwise dispose of it without delay.
8.3 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
9. Secure Processing
The Company shall ensure that all personal data collected, held, and processed is kept secure
and protected against unauthorised or unlawful processing and against accidental loss,
destruction, or damage. Further details of the technical and organisational measures which
shall be taken are provided in Sections 22 to 27 of this Policy.
10. Accountability and Record-Keeping
10.1 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 GDPR and other applicable data protection
10.3 The Company shall keep written internal records of all personal data collection, holding,
and processing, which shall incorporate the following information:
10.3.1 The name and details of the Company, its Data Protection Officer, and any
applicable third-party data processors;
10.3.2 The purposes for which the Company collects, holds, and processes personal
10.3.3 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
10.3.4 Details of how long personal data will be retained by the Company (please
refer to the Company’s Data Retention Policy); and
10.3.5 Detailed descriptions of all technical and organisational measures taken by the
Company to ensure the security of personal data.
11. Data Protection Impact Assessments
11.1 The Company shall carry out Data Protection Impact Assessments for any new projects
and new uses of personal data which involve the use of new technologies and the
processing involved is likely to result in a high risk to the rights and freedoms of data
subjects under the GDPR.
11.2 Data Protection Impact Assessments shall be overseen by the Data Protection Officer
and shall address the following:
11.2.1 The type(s) of personal data that will be collected, held, and processed;
11.2.2 The purpose(s) for which personal data is to be used;
11.2.3 The Company’s objectives;
11.2.4 How personal data is to be used;
11.2.5 The parties (internal and/or external) who are to be consulted;
11.2.6 The necessity and proportionality of the data processing with respect to the
purpose(s) for which it is being processed;
11.2.7 Risks posed to data subjects;
11.2.8 Risks posed both within and to the Company; and
11.2.9 Proposed measures to minimise and handle identified risks.
12. Keeping Data Subjects Informed
12.1 The Company shall provide the information set out in Section 12.2 to every data subject:
12.1.1 Where personal data is collected directly from data subjects, those data
subjects will be informed of its purpose at the time of collection; and
12.1.2 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
if the personal data is to be transferred to another party, before that transfer
is made; or
b) as soon as reasonably possible and in any event not more than one month
after the personal data is obtained.
12.2 The following information shall be provided:
12.2.1 Details of the Company including, but not limited to, the identity of its Data
12.2.2 The purpose(s) for which the personal data is being collected and will be
processed (as detailed in Section 21 of this Policy) and the legal basis justifying
that collection and processing;
12.2.3 Where applicable, the legitimate interests upon which the Company is
justifying its collection and processing of the personal data;
12.2.4 Where the personal data is not obtained directly from the data subject, the
categories of personal data collected and processed;
12.2.5 Where the personal data is to be transferred to one or more third parties,
details of those parties;
12.2.6 Details of data retention;
12.2.7 Details of the data subject’s rights under the GDPR;
12.2.8 Details of the data subject’s right to withdraw their consent to the Company’s
processing of their personal data at any time;
12.2.9 Details of the data subject’s right to complain to the Information
Commissioner’s Office (the “supervisory authority” under the GDPR);
12.2.10 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
12.2.11 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.
13. Data Subject Access
13.1 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.
13.2 Employees wishing to make a SAR should do using a Subject Access Request Form,
sending the form to the Company’s Data Protection Officer at Skills for Logistics Ltd, The
Old Brewery, 9-11 Lodway, Pill, Bristol BS20 0DH
13.3 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.
13.4 All SARs received shall be handled by the Company’s Data Protection Officer.
13.5 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.
14. Rectification of Personal Data
14.1 Data subjects have the right to require the Company to rectify any of their personal data
that is inaccurate or incomplete.
14.2 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.
14.3 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.
15. Erasure of Personal Data
15.1 Data subjects have the right to request that the Company erases the personal data it
holds about them in the following circumstances:
15.1.1 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;
15.1.2 The data subject wishes to withdraw their consent to the Company holding
and processing their personal data;
15.1.3 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) (see Section 18 of this Policy for further details concerning
the right to object);
15.1.4 The personal data has been processed unlawfully;
15.1.5 The personal data needs to be erased for the Company to comply with a
particular legal obligation.
15.2 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.
15.3 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).
16. Restriction of Personal Data Processing
16.1 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.
16.2 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).
17. Data Portability
17.1 The Company does not process personal data using automated means.
17.2 Where data subjects have given their consent to the Company to process their personal
data in such a manner, or the processing is otherwise required for the performance of a
contract between the Company and the data subject, data subjects have the right, under
the GDPR, to receive a copy of their personal data and to use it for other purposes
(namely transmitting it to other data controllers).
17.3 Where technically feasible, if requested by a data subject, personal data shall be sent
directly to the required data controller.
17.4 All requests for copies of personal data shall be complied with within one month of the
data subject’s request. The period can be extended by up to two months in the case of
complex or numerous requests. If such additional time is required, the data subject shall
18. Objections to Personal Data Processing
18.1 Data subjects have the right to object to the Company processing their personal data
based on legitimate interests, direct marketing (including profiling).
18.2 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.
18.3 Where a data subject objects to the Company processing their personal data for
historical research and statistics purposes, the data subject must, under the GDPR,
“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.
19. Personal Data Collected, Held, and Processed
The following personal data is collected, held, and processed by the Company (for details of
data retention, please refer to the Company’s Data Retention Policy):
|Type of Data||Purpose of Data|
|Name||All data subjects- Identification purposes|
|Telephone/Mobile||All data subjects – to enable contact|
|All data subjects – to enable contact|
|Address||Employees – Contact purposes, Payroll/HMRC|
Employers – Contact purposes
Apprentices – Contact purposes
Training providers – Contact purposes
Assessors – Contact purposes
|Date of Birth||Employees – Taxation purposes|
Apprentices – Identify if under 18
|Education||Employees- Suitable for the job role|
Apprentices – Meet requirement for End-Point assessment
|Qualifications||Employees- Suitable for the job role|
Apprentices – Meet requirement for End-Point assessment
Assessors – Suitable for the role
|Photo ID||Apprentices/trainees – Identification and proof they have completed relevant driving qualifications|
Employees- Identification and proof of who they are.
|Next of Kin||Employees - For health & safety purposes (vital interests).|
Apprentices - For health & safety purposes (vital interests).
|Family Circumstances||Employees – assessing suitability for a role|
|Opinions/ Interview Notes||Employees – to evaluate suitability for a particular role or future roles|
|Referees/References||Employees – References for previous employment|
Assessors – References of previous employment
20. 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:
20.1 All emails containing personal data must be encrypted or password protected.
20.2 Personal data may be transmitted over secure networks only; transmission over
unsecured networks is not permitted in any circumstances;
20.3 Personal data may not be transmitted over a wireless network if there is a wired
alternative that is reasonably practicable;
20.4 Where personal data is to be transferred in hardcopy form it should be passed directly
to the recipient .
21. Data Security - Storage
The Company shall ensure that the following measures are taken with respect to the storage of
21.1 All electronic copies of personal data shall be stored securely using passwords and data
encryption; see Data Retention Policy for more information.
21.2 All hardcopies of personal data, shall be stored securely in a locked box, drawer, cabinet,
21.3 All personal data stored electronically is backed up daily with backups stored onsite and
offsite. All backups are encrypted.
21.4 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 a director 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.
21.5 No personal data will 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 GDPR (which
may include demonstrating to the Company that all suitable technical and organisational
measures have been taken).
22. 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 will be deleted and any hard copy
data will be shred using on-site shredding machine. For further information on the deletion
and disposal of personal data, please refer to the Company’s Data Retention Policy.
23. Data Security - Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of
23.1 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 Data Protection Officer.
23.2 Personal data must always be handled with care and should not be left unattended or
on view to unauthorised employees, agents, sub-contractors, or other parties at any
23.3 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 their PC unattended.
24. Data Security - IT Security
The Company shall ensure that the following measures are taken with respect to IT and
24.1 All passwords used to protect personal data are changed regularly. All passwords
contain a combination of uppercase and lowercase letters, numbers, and symbols. All
software used by the Company is designed to require such passwords.;
24.2 Under no circumstances are passwords 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, then the Operations
Manager will issue a new one upon request.
24.3 All software (including, but not limited to, applications and operating systems) shall be
kept up-to-date. The user/Company’s IT services provider are responsible for installing
security-related updates as soon as reasonably and practically possible, unless there are
valid technical reasons not to do so.
24.4 No software may be installed on any Company-owned computer or device without the
prior approval of Neil Buzzard at Computer Problem Solutions Ltd (IT Services Provider).
25. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection,
holding, and processing of personal data:
25.1 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 GDPR and under this Policy, and shall be provided with a copy
of this Policy;
25.2 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;
25.3 All employees, agents, contractors, or other parties working on behalf of the Company
handling personal data will be appropriately trained to do so;
25.4 All employees, agents, contractors, or other parties working on behalf of the Company
handling personal data will be appropriately supervised;
25.5 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;
25.6 Methods of collecting, holding, and processing personal data shall be regularly
evaluated and reviewed;
25.7 All personal data held by the Company shall be reviewed periodically, as set out in the
Company’s Data Retention Policy;
25.8 The performance of those employees, agents, contractors, or other parties working on
behalf of the Company handling personal data shall be reviewed regularly.
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
GDPR and this Policy;
25.9 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 GDPR; and
25.10 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.
26. Transferring Personal Data to a Country Outside the UK
26.1 The Company does not transfer (‘transfer’ includes making available remotely) personal
data to countries outside the UK.
27. Data Breach Notification
27.1 All personal data breaches must be reported immediately to the Company’s Data
27.2 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.
27.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher
risk than that described under Section 29.2) 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.
27.4 Data breach notifications shall include the following information:
27.4.1 The categories and approximate number of data subjects concerned;
27.4.2 The categories and approximate number of personal data records concerned;
27.4.3 The name and contact details of the Company’s Data Protection Officer (or
other contact point where more information can be obtained);
27.4.4 The likely consequences of the breach;
27.4.5 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.
28. Implementation of Policy
This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have
retroactive effect and shall thus apply only to matters occurring on or after this date.
Approval date: 19th March 2021
Validity: One Year
Review Date: 19th March 2022