How do we collect information about you?

Information is provided to Avado by:

1. If we believe your organisation may be interested in purchasing our training courses for your employees
2. Your business if your course or apprenticeship is funded by the employer

What information do we need?

When you speak to our course advisors or enrol on a course, we may ask for the following information:

• Your full name, email address, telephone number, postal address and date of birth
• Your education and work experience, where relevant to the course
• Your company name, company size and industry type
• Your job title, job level, team size
• Payment information including credit card number and bank account details
• Copy of your identification, either passport of driving license

Why do we need your data and the legal basis we use to process it?

Business Contacts: We use personal contact details of business contacts (including agents, contractors and individuals that represent our suppliers and business partners) for our own legitimate interests of running our business.

Employer Reporting: Where an employer has purchased training on your behalf, any information you share on the campus (including feedback and project work) may be shared with the company stakeholder, to fulfil our contractual requirements

How long your personal data will be kept?

Where a purchase has been made and training is provided, your data will be held for a period of 7 years in line with our regulatory and governing body requirements, where there may be a requirement to hold your data to evidence the completion of studies or for audit purposes.

Where you have supplied your consent to receive future communications about our products that maybe relevant to your enquiry or the sector of training being undertaken, we will hold your information for an indefinite period of time. Your information will be kept with us until you notify us that you no longer wish to receive this information. You have the right to withdraw consent at any time.

How do we collect information about you?

Information is provided to Avado by:

1. Job application forms
2. Third party agency which you are using for recruitment purposes or have your CV’s with

What information do we need?

We may ask for the following information:

• Your full name, email address, telephone number, postal address and date of birth
• Your education and work experience
• Your next of kin’s full name, telephone number and postal address
• Your bank account details
• Copy of your identification, either passport of driving license

Why do we need your data and the legal basis we use to process it?

Job Applications: We collect personal information in the context of processing job applications as necessary to comply with our legal and regulatory obligations to ensure that our application processes comply with applicable laws to ensure that candidates are appropriately qualified and suitable for working with us. Such processing may also be necessary for us to take steps before entering into an employment contract with a candidate.

Employment: We collect personal information in the context of processing job applications as necessary to comply with our legal and regulatory obligations. We will rely upon contractual obligation as the lawful basis for the processing your personal information.

How long your personal data will be kept?

If you are an unsuccessful applicant, we will keep your details for up to 2 years, if we feel you would be suitable for a position in our organisation we will contact you.

We only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, for employment details this is usually 7 years. Details of retention periods for different aspects of your personal information are available in our retention policy.

How do we collect information about you?

To deliver the Skills Ignition training program, as well as accessing the funding correlating to the program, we will need to process the following data items about yourself:

• Full name
• NRIC Number
• Gender
• Date of Birth
• Contact Number
• Email Address
• Nationality
• Mailing Address

If you are eligible and utilizing the job placement services from Avado in line with the Skills Ignition SG program, we would further process the following information:

• Employment history

The information you have provided will be shared with prospective employers.

Delivery of Service:

Program Funding & Participation: Where Avado is offering governmental or other funding for its courses for individuals or corporate customers, it will process personal data as requested by the funding body and legal obligations, it’s agencies or third parties as outlined within the funding rules. Avado will be processing the personal information collected where necessary under the following circumstances:

Why do we need your data and the legal basis we use to process it?

Avado needs the information outlined above for the following purposes:

• Assessment of eligibility of the applicants for the training program
• To provide the resources and access to the training program
• To fulfil the contractual requirements under the funding programs
• To communicate the applicant information with the government, nominated other governmental agencies and contractors, for the purposes of vetting and approval onto the training program and access to the relevant funding
• To provide information, advice and guidance in regards of the service offerings
• To fulfil regulatory and legal requirements
• To help successful candidates to be placed within job roles in Singapore

How long will your personal data be kept?

Candidates who have successfully completed the course, or candidates which have been enrolled but withdrawn from the course, will have the information kept for 3 years, in line with governmental requirements of data retention, from the end of the course.

Successful candidates which further utilize the job placement services from Avado will have their additional personal data kept for the duration of 6 months after their graduation for the purpose of finding them employment.

Personal information of candidates which unfortunately have not been successful, will be removed within 2 months of us becoming aware.

All personal data will be processed in line with the Personal Data Protection Act of Singapore and governmental requirements under the relevant funding programs.

You are in control of what information we collect about you.

We may ask for information about you when you register for promotions or when you request brochures or other information. We may also invite you to complete surveys or provide us with feedback.

We and our business partners collect information about your use of the website from cookies. For information about our use of cookies and how to decline them please read our Cookies Policy.

We use your data to improve the service we offer you and to try and ensure that you get the best from our website.

Non-marketing use

We will use the information you enter on the site for administration purposes and any other purposes made clear in the data entry forms themselves, in any relevant terms or conditions and on any pages or emails which link to such forms. If you click on a ‘submit my details’ button on the website, your contact details will be used to send you servicing information related to your selection or ultimate objective. Very occasionally, we may also invite you to participate in a customer survey to improve our service to you.

Website customisation and targeting of adverts

We use the data you give us about yourself to build up a picture of your interests - we then try to ensure that when you visit the site, you don’t miss the offers and information relevant to you.

We and our reputable third-party companies will collect website usage information about visitors to our website for the purposes of statistical analysis, sales and marketing research, tracking page usage and paths used by visitors through our site, targeting the site content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites and tracking use of our Internet banner advertisements and other links from our marketing partners’ websites to our website.

For this purpose, we and our third-party companies note information on the path you take to get to our site and on some of the pages you visit on our website (including, for example, the options you select and the search terms you use) through the use of cookies.

We may also combine this web usage data with other information we have collected about you, we store this information so that we have a better and more specific understanding of the way customers are using our site and their preferences and interests. We may use it to undertake sales and marketing research and to tailor our site, our marketing campaigns and email communications specifically to you, and your recent activity on our site.

Direct marketing and how you can change your preference

We offer you the opportunity to receive information from our company. We may use your history to communicate information we think may interest you. To improve our picture of your interests we may link the data you give us about yourself with any data we have gathered (via cookies) about your use of the site.

We try to ensure that customers do not receive duplicate communications even if we have more than one enquiry from the same customer.

Your details may be shared within the Avado Group. You will not receive direct marketing from companies outside Avado as a result of giving your details to us. If, in exceptional circumstances, we ever wanted to allow a third party to send you direct marketing, we would seek your consent before sharing your data with that third party.

We will send direct marketing by your chosen method of communication as set out on the home page of our website. 

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be told how to unsubscribe. In any event, if you wish for us to stop sending direct marketing to you, you can contact us:

Telephone: +44 (0)203 893 5400

Email: dataprotection@Avadolearning.com

If you receive marketing communications when you used the site for any reason, you can tell us that you do not wish to receive any more by writing, with your full name, address and other contact details (to enable us to find your records), to:

Avado

Scale Space

Imperial College White City Campus

58 Wood Lane

London

W12 7RZ

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way.

The following security procedures, and technical and organisational measures to safeguard your personal information have been put in place:  

• In cases where personal data is being processed by third parties, a rigorous adequacy process is being performed to ensure that your data is always secured.
• Firewalls, intrusion detection and prevention, anti-virus and anti-malware and backup and disaster recovery is in place to prevent data loss or deletion. 
• 24/7 security guard, closed circuit television and door access control to authorized personnel secures office and data center. 
• Applications operated by Avado are engineered and secured by industry standards to minimize security vulnerabilities and updates on a regular basis. 
• Intrusion detection and prevention secures the network traffic to the servers and applications.
• Anti-malware and anti-virus software is deployed to all of our servers and regularly scan and update with the latest anti-malware and virus signatures.
• Employees undergo background screening and selection processes ensuring that only employees with highest security clearance are allowed physical access to network infrastructure. Employee access is logged and secured through personal access control cards. 
• Access to infrastructure, elevated privileges and network are granted on an as-needed basis. 
• Infrastructure and web applications operated by Avado is backed up on a regular basis and business continuity and disaster recovery is tested on a regular basis.
• We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

“Automated Decision Making” refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.

“Profiling” is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

We may in some cases use automated decision-making if you have provided an explicit consent. You can always request a manual decision- making process instead, express your opinion or contest a decision based solely on automated processing, including profiling, if such a decision significantly affected you. Profiling uses automated processing, which may use automated decision-making algorithms.

If you are an Enrolled or Former Student, we may use automated decision processes to carry out an evaluation on your learning performance, and progression of your studies; which may be used to help us understand how to improve our learning experiences, to support with recruitment/employment opportunities and creating learner profile reports, which can be shared with the employment partners, which may increase your chances of future employment.

When using automated decision-making we can provide you with further information about the data used, the logic involved, as well as the rationale behind any decisions.

Legal basis for processing: Your explicit consent pursuant to Article 22 (2) c.

Your rights in regards to our automated decision making and profiling activities:

• You have the right to request a team member to review the output of automated decision making
• Where you have given explicit consent, you have the right to remove the consent at any time

We routinely share your personal information with third parties listed below. This data sharing enables the performance of any contract we enter into with you. Some of those third-party recipients may be based outside the European Economic Area, for further information including on how we safeguard your personal data when this occurs, see ‘Overseas transfers’.

Trusted third parties:

• Contracted Apprenticeship Partners to support enrolment on funded courses for Apprentices
• Contracted FastFutures Partners to support your 12-week programme and to help you find employment
• Awarding Bodies – Registration and Certification of your qualification, including CIPD whose privacy policy can be found at https://www.cipd.co.uk/privacy-policy
• Examination and Workshop venues – arrangement of workshops and exams
• The National Apprenticeship Service for Apprenticeships
• Your personally assigned tutor and assessor
• Publishers – to supply textbooks relevant to your studying
• Business Analytics tools – to help inform business decisions/intelligence.
• Cloud based Customer Relationship Systems (CRM)
• Cloud based hosting services & systems
• Cloud based training tools to support learning progression and tracking
• Third Party developers – to improve our technology and system
• Technology providers who provide protection against abuse/spam online through automated means, such as Google re-captcha
• To undertake further eligibility assessments and check on potential students, where necessary
• Tracing and recovery of debt.
• Where we partner with other organisations, we may also share information with them (for example if you register to attend an event jointly held by us and another organisation). We will only share information where necessary and we will make sure to notify you first.

Where we outsource any of our business functions under which we collect or store your data, we will endeavour to ensure that any such service provider adheres to their obligations of security with regards to your data as undertaken by us.

We will share personal information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms & Conditions and other agreements; or to protect our rights, property, or safety of our employees, our customers, or others. This includes exchanging information with other companies or organisations for the purposes of fraud protection and credit risk.

Additionally, we may ask your permission to share your data for the purposes of our courses in order that you can conduct the group work as part of the course structure.  We will contact you for your specific consent if this is applicable to you.

Coursework and assessment submissions will only be shared securely based on the terms of the agreement; for example, with a designated person or department in the relevant Awarding Organisation.

We will not share your personal information with any other third party.

A complete list of our trusted third parties can be obtained by writing to: dataprotection@Avadolearning.com

Overseas transfers

The information you provide may be transferred to countries outside the European Economic Area (EEA) that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information, you consent to these transfers for the purposes specified above.

We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows: 

If you would like further information, please contact us. We will not otherwise transfer your personal data outside of the EEA or to any organisation or subordinate bodies governed by public international law or which is set up under any agreement between two or more countries.

Who your data can be disclosed to?

Other companies in the Avado Group acting as joint controllers or processors and who are based in the United Kingdom, Hong Kong, Singapore and United States of America and provide IT and system administration services and undertake leadership reporting.

• Avado Asia Pacific PTE. LTD Registered Address: 6A Shenton Way #04-02/08 Singapore (068815) Company Registration: 201540373Z
• Avado Hong Kong Pte Limited is a fully owned subsidiary of Avado Asia Pacific Pte Ltd. Registered Address: 1703 Wing On Centre, 111 Connaught Road Central, Sheung Wan, Hong Kong. Company Registration No: 2390921.
• Utalk LLC (US) Registered Address: 116 W. Houston Street, Floor 3 New York, NY 10012, Company Registration: 3987504
• Avado Learning Limited. Registered in England with number 06177616. Registered office: Avado, Scale Space, Imperial College White City Campus, 58 Wood Lane, London W12 7RZ. VAT Registration number: 918560018. Authorised and regulated by the Financial Conduct Authority – Firm Reference Number: 718054
• BC Arch Limited. Registered in England with number 08151723. Registered office address: Scale Space, Imperial College White City Campus, 58 Wood Lane, London W12 7RZ. VAT Registration number: 918560018
• FastFutures Limited. Registered in England with number 09225093. Registered office address: Scale Space, Imperial College White City Campus, 58 Wood Lane, London W12 7RZ. VAT Registration number: 918560018

For more details about our group, please visit the website.  We share information with them, so they can assist us in providing services to you and so that we can understand more about you.

You will only be sent marketing emails from other companies within our group where you have provided consent to those companies.

In addition, disclosure of your data to others may be necessary to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described above. If you consent to direct marketing, your details will be used and disclosed in the manner set out under the heading “Direct Marketing and how you can change your marketing preference”.