Training Ways assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.
1 Information we collect
Training Ways, holds personal data as part of conducting a professional training service. The data comes under the following headings: Notification of training events, Training event records, General Administration data, Financial records
1.1 Subscription to Training Ways
In order to notify subscribers to Training Ways for notification of training events that we schedule, we collect the following information:
- E-mail address
- Profession or Parental status
Subscribers may unsubscribe at any time by clicking ‘unsubscribe’ at the bottom of any email they are sent.
1.2 Training Event Records
When an individual signs up to a training event, we collect the following information:
- E-mail address
- Postal Address
- Telephone Number
1.3 General administrative records
Training Ways may hold information regarding attendance reports and accident report forms.
1.4 Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Training Ways may hold data in relation to payments: receipts and invoices. Information will include name of bill payer, client name, address, method of payment and record of invoices and payments made.
2 Where we get our information
Personal data will be provided by the client through subscription to our mailing list or submission of request to join a training programme.
2.1 Subscription to Training Ways
Data is collected by individuals who sign up to receive notifications via and the electronic sign- up form on www.trainingways.com which is a WordPress site hosted by Site Ground.
2.2 Training Event Records
Data is collected from individuals who purchase a training product through our website on www.trainingways.com. Data can also be collected by phone or manual hard-copy application.
3 How we use the information that we collect
3.1 Subscription to Training Ways
We use the information we collect to notify subscribers of upcoming training events.
3.2 Training Event Records
We use data collected when purchasing product data to process the training event applications.
4 Data retention periods
The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.
4.1 Subscriber Information
Data collected when a person subscribes to Training Ways is retained until such time that the subscriber opts out of the subscription process. The subscriber has the option to opt out at any time.
4.2 Training Event Records
Training Ways keeps both physical and electronic records of training events in order to provide a service.
- The preferred format for product data is electronic format.
- Training records are deleted confidentially and destroyed after 2 years from the date of the training taking place.
4.3 Financial Records
Training Ways keeps paper records of financial data from those who use our services.
Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.
- Financial Data is kept for 6 years to adhere to Revenue guidelines.
- Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.
If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.
5 Sharing Data
5.1 Legal requirements
Training Ways is required to share data with external parties in the following circumstances:
- Compliance with law enforcement.
5.2 Financial requirements
Training Ways also is required to share Financial data with Eamonn Harrigan, (the Accountant), in order to comply with local tax laws. Training Ways is obtaining a copy of the Accountant’s own Data protection policy.
6 How we protect your data
In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:
6.1 By limiting the data that we collect in the first instance
All data collected by us will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. Furthermore, all data collected by us will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected.
6.2 By keeping only the data that is required,
6.3 By deleting the data
within two years of the completion of training event. Where data is required to be held by us for longer than the period of two years, we will put in place appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These may include measures such as the encryption of electronic devices, pseudonymisation of personal data, and/or safe and secure storage facilities for paper/electronic records.
6.4 By retaining the data for only as long as is required
which in this case is two years, except for circumstances in which retention of data is required in certain specific circumstances as set out at Article 23(1) of the GDPR.
6.5 By deleting the data securely and confidentially after the period of retention has elapsed.
This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.
6.6 By ensuring that any personal data collected and retained is both accurate and up-to-date.
Training Ways is aware of the need for privacy. As such, we aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.
All persons working in, and with Training Way in a professional capacity are briefed on the proper management, storage and safekeeping of data.
All data used by Training Ways, including personal data may be retained either in Electronic Data, or Physical Files
Where applicable, Training Ways may convert physical files to electronic records to allow us to provide a better service to course attendees.
7.1 Data Security
Training Ways understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Training Ways use to ensure that the data is kept safe.
7.1.1 Electronic Data
All electronic data is contained in the following systems. Each system is accessed through user id and is password protected.
7.1.2 Physical Files
All physical data is located at Training Ways, Tyrone, Kilcolgan, Co. Galway. These records are kept in a container secured with a lock and key.
7.2 Security Policy
Training Ways understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Training Ways reviews the electronic and physical storage options available to Training Ways every 12 months.
All physical devices used by persons working in Training Ways which may contain any identifiable personal data are enabled, where it is possible, with loss or theft tracking and remote wipe abilities
All persons working in Training Ways are aware and briefed on and refresh the requirements for good data hygiene every 12 months. This briefing compliance is monitored by the Training Ways data controller and includes, but is not limited to:
- Awareness of client conversations in unsecure locations.
- Enabling auto-lock on devices when leaving them unattended, even within Training Ways locations.
- Use of non-identifiable note taking options. (initials, not names).
- The awareness of Training Ways procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.
If you have any questions regarding this policy, or your dealings with our website, please contact us at Email: firstname.lastname@example.org or in writing to Training Ways, Tyrone, Kilcolgan, Co. Galway. Ireland