Data Protection Policy 17.05.21


This policy applies to all staff, employees, part time employees, learners, Training Consultants, centre personnel of Proactive Training Scotland Ltd.

Proactive Training Scotland Ltd. will ensure that it informs all clients about data protection issues and their rights to access their own personal data. Proactive Training Scotland Ltd. holds personal data and will ensure compliance with the Data Protection Act 2018.

The Act and any subsequent updates, protects employees (clients etc) against the misuse of personal data, and covers both manual and electronic records.

The Act requires that any personal data held should be:

• processed fairly and lawfully;
• obtained and processed only for specified and lawful purposes;
• adequate, relevant and not excessive;
• accurate and kept up to date;
• held securely and for no longer than is necessary; and
• Not transferred to a country outside the European Economic Area unless there is an adequate level of data protection in that Country.

Purposes for which personal data may be held (learners, centres and Resources customers)

• To maintain or process records
• To help improve our service to learners

From time to time, employees of Proactive Training Scotland Ltd., its subsidiaries, joint venture partners and related companies may send out information to learners about new products or other information that may be of interest to learners.

Transfer of data

Certain personal information may be transferred or made available to:

• Other third party contractors and suppliers to Proactive Training Scotland Ltd. for the purposes of storing information, processing requests or arranging delivery of the product or service you have requested
• Other third parties who audit systems and information
• Government organisations / statutory bodies to fulfil regulatory requirements

We will not disclose, rent, sell or otherwise transfer your personal information without your consent other than the criteria set out above.

All of our service providers and contractors are required to maintain the confidentiality and security of your personal information and to use it only in compliance with applicable data privacy laws, and are prohibited from using or disclosing your personal information for

any purpose other than providing the services on our behalf or as otherwise required by applicable law.

Purposes for which personal data may be held

Personal data relating to employees that have been trained by Proactive Training Scotland Ltd. may be collected primarily for the purposes of:

• recruitment, promotion, training, redeployment, and/or career development;
• administration and payment of wages and sick pay;
• calculation of certain benefits including pensions;
• disciplinary or performance management purposes;
• performance review;
• recording of communication with employees/students and their representatives;
• compliance with legislation;
• provision of references to financial institutions, to facilitate entry onto educational courses and/or to assist future potential employers; and
• Staff, volunteers and students, staffing levels and career planning.

Proactive Training Scotland Ltd considers that the following personal data falls within the categories set out above:

• Personal details including name, address, age, status and qualifications. Where specific monitoring systems are in place, ethnic origin and nationality will also be deemed as relevant;
• references and CVs;
• emergency contact details;
• notes on discussions between management and the employee/student;
• appraisals and documents relating to grievance, discipline, promotion, demotion, or termination of employment;
• training records;
• salary, benefits and bank/building society details; and
• Absence and sickness information.

Employees, potential employees, volunteers and students will be advised of the personal data which has been obtained or retained, its source, and the purposes for which the personal data may be used or to whom it will be disclosed.

Proactive Training Scotland Ltd will review the nature of the information being collected and held on an annual basis to ensure there is a sound business reason for requiring the information to be retained.

Responsibility for the processing of personal data

Proactive Training Scotland Ltd’s Data Controller is Steven Morrison. who is responsible for ensuring all personal data is controlled in compliance with the Data Protection Act 2018.

Employees, volunteers and students who have access to personal data must comply with this Policy and adhere to the procedures. Failure to comply with the Policy and procedures may result in disciplinary action up to and including summary dismissal – (this can only apply to employees).

Use of personal data

To ensure compliance with the Data Protection Act 2018 and in the interests of privacy, employee/student confidence and good employee/student relations, the disclosure and use of information held by Proactive Training Scotland Ltd is governed by the following conditions:

• personal data must only be used for one or more of the purposes specified in this Policy;
• Documents may only be used in accordance with the statement within each document stating its intended use; and
• provided that the identification of the individual employees/students is not disclosed, aggregate or statistical information may be used to respond to any legitimate internal or external requests for data (e.g., surveys, staff, volunteers and students, staffing level figures); and
• Personal data must not be disclosed, either within or outside Proactive Training Scotland Ltd, to any unauthorised recipient.

Personal data held for equal opportunities monitoring purposes

Where personal data obtained about candidates is to be held for the purpose of Equal Opportunities monitoring, all such data must be made anonymous.

Disclosure of personal data

Personal data may only be disclosed outside Proactive Training Scotland Ltd with the employee’s/student’s written consent, where disclosure is required by law or where there is immediate danger to the employee’s/student’s health.

Accuracy of personal data

Proactive Training Scotland Ltd will review personal data regularly to ensure that it is accurate, relevant and up to date.

In order to ensure that our files are accurate and up to date, and so that Proactive Training Scotland Ltd is able to contact the employee/student or, in the case of an emergency, another designated person, employees/students must notify their line manager or the Chief Executive as soon as possible of any change in their personal details (e.g., change of name, address; telephone number; loss of driving license where relevant; next of kin details, etc).

Access to personal data (“Subject Access Requests”)

Employees/Students have the right to access personal data held about them. The Company will arrange for the employee/student to see or hear all personal data held about them within (GDPR allows 1 calendar month – so around 30 days) of receipt of a written request.

Retention of records – refer to the data retention and erasure policy

Opt-In or Opt Out

Any communication with you via email, flyers, letters or other means directly connected with marketing our services or products will always provide you with the opportunity to opt-in or opt-out of receiving emails relating to our services or products, by positively opting-in or opting-out (declining to consent to receive the information we intend to send to you). If you decide to opt out of receiving emails from us, we will withdraw your details from our database as soon as we can; should you wish to opt-in at any time in the future you will need to let us know.

You will see the following message on any marketing communication sent to you:

This message was sent to your email address because you asked us to keep you up to date with the latest news and services related to our training services. If you do not wish to receive these emails, please unsubscribe by email to

S Morrison
Proactive Training Scotland Ltd.