Chapter One (Jersey) Limited (“Chapter One”) respects your privacy and is committed to protecting your personal data.
This privacy notice provides information on how Chapter One collects, processes and protects personal data received about you, through you using this Chapter One website and/or through the provision of Chapter One’s services and/or through other dealings.
It is important that you read and understand this privacy notice together with any related privacy related policies that may be issued by Chapter One in order that you may be aware of how and why Chapter One is using personal data.
Chapter One was incorporated in Jersey on 23 October 2019 with registered number 130135. Chapter One is a data controller and responsible for your personal data.
Chapter One’s registered office and postal address is First Floor, 3 The Forum, Grenville Street, St. Helier, Jersey JE2 4UF.
Chapter One keeps this privacy notice under regular review. It is important that the personal data Chapter One holds about you is accurate and current. Chapter One should be informed if your personal data changes during your relationship with Chapter One.
Should you have any questions surrounding this notice, including wishing to make a subject access request in writing, please contact info@chapteronetraining.com.
What is Personal Data or Personal Information?
Personal 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 (i.e. anonymous data).
Through Chapter One’s website and through the provision of services, Chapter One may collect, use, store and transfer different kinds of personal data about you which is grouped together as follows:
- Identity Data includes your name or similar identifier, first name, maiden name, last name, previous names, title and date of birth.
- Employment Data includes information about your current or previous employer and any qualifications which you have gained during any periods of employment with any employer in the Island of Jersey or elsewhere.
- Contact Data includes billing address, postal and email address and landline and mobile telephone numbers.
- Financial Data includes details about payments and bank account details.
- Technical Data includes internet protocol (IP) address, 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 utilise to access Chapter One’s website.
- Usage Data includes information about how you use Chapter One’s website.
- Marketing and Communications Data includes your preferences in receiving marketing from Chapter One and Chapter One’s third parties and your communication preferences together with any opinions expressed when participating in market research.
Chapter One also collects, uses and shares aggregated data such as statistical or demographic data for data analysis purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, Chapter One may aggregate your Usage Data to calculate the percentage of users accessing a specific Chapter One site feature. However, if Chapter One combines or connects aggregated data with your personal data so that it can directly or indirectly identify you, Chapter One treats the combined data as personal data which will be used in accordance with this privacy notice.
Chapter One does not collect any 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).
How is Personal Data collected?
Chapter One uses different methods to collect data from and about you including through:
- Direct input by you. You may provide Chapter One with your identity and contact data by completing booking request forms, contacting Chapter One by email and/or post and/or by corresponding with Chapter One via this website or through alternative communication and web applications.
- Automated technologies or interactions. As you interact with Chapter One’s website, Chapter One may automatically collect technical data about your equipment, browsing actions and patterns. Chapter One collects this personal data by using cookies, and other similar technologies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is utilised by Chapter One to track visitor use of the website and to compile statistical reports on website activity.
- Third parties or publicly available sources. Chapter One may receive personal and technical data about you from various third parties and public sources including analytics providers.
How is Personal Data used?
Chapter One will only use personal data in the manner permitted by the law. Most commonly, Chapter One will use personal data in the following circumstances:
- In order to send you further information about Chapter One’s services.
- Where Chapter One needs to perform contractual services with you.
- Where it is necessary for Chapter One’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where Chapter One needs to comply with a legal or regulatory obligation.
- Where Chapter One needs to pursue our legitimate interest.
- To process the information to enter into or carry out an agreement with you.
- The need to establish, exercise or defend Chapter One’s legal rights.
Chapter One does not rely on consent as a legal basis for processing personal data other than in relation to sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting info@chapteronetraining.com.
Purposes for which Personal Data is used?
Chapter One has set out below, a description of how it plans to use personal data, and which of the legal bases it relies upon to do so. Chapter One has identified the legitimate interests where appropriate.
Legitimate interest means the interest of Chapter One in conducting and managing the business to enable it to give you the best service/product and the best and most secure experience. Chapter One makes sure it considers and balances any potential impact to you (both positive and negative) and your rights before it processes your personal data for its legitimate interests. Chapter One does not use your personal data for activities where Chapter One’s interests are overridden by the impact on you (unless it has your consent or are otherwise required or permitted to by law).
Chapter One may process your personal data for more than one lawful ground depending on the specific purpose.
Please contact info@chapteronetraining.com should you require further details about the specific legal ground Chapter One is relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity
To register you as a potential new customer or intermediary.
Type of data
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest
Necessary for legitimate interests to expand Chapter One’s customer base to allow for the growth of the business.
Purpose/Activity
To manage the relationship with a customer including notifying you of changes to Chapter One’s terms and conditions or privacy notice and any request to provide feedback, undertake a review or a survey.
Type of data
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
Necessary for the performance of a contract with you.
Necessary to comply with a legal obligation.
Necessary for legitimate interests to keep Chapter One’s records updated and to understand how customers’ use Chapter One’s services.
Purpose/Activity
To administer and protect Chapter One’s business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
Necessary to comply with a legal obligation.
Necessary for legitimate interests (for the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation).
Purpose/Activity
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising.
Type of data
(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical
Lawful basis for processing including basis of legitimate interest
Necessary for legitimate interests (to study how customers use Chapter One’s products/services, to develop them, to grow the business and to inform Chapter One’s marketing strategy).
Purpose/Activity
To use data analytics to improve Chapter One’s website, products/services, marketing, customer relationships and experiences.
Type of data
(a) Usage
(b) Technical
Lawful basis for processing including basis of legitimate interest
Necessary for legitimate interests (to define types of customers for Chapter One’s products and services, to keep the website updated and relevant, to develop the business and to inform Chapter One’s marketing strategy).
Purpose/Activity
To make suggestions and recommendations to you about goods or services that may be of interest.
Type of data
(a) Identity
(b) Contact
(c) Usage
(d) Technical
Lawful basis for processing including basis of legitimate interest
Necessary for legitimate interests (to develop Chapter One’s products/services and grow the business).
Change of Purpose
Chapter One will only use your personal data for the purposes for which it was collected, unless Chapter One reasonably considers that it is needed to be utilised 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 info@chapteronetraining.com.
If Chapter One needs to use your personal data for an unrelated purpose, Chapter One will notify you and will explain the legal basis which allows Chapter One to do so, where it is permitted to do so by law.
Data Security
Chapter One has established appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, Chapter One limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Such parties will only process your personal data on Chapter One’s instructions and are subject to a duty of confidentiality.
Chapter One 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.
Sending information over the internet to Chapter One is generally not completely secure, and Chapter One cannot guarantee the security of your data while it is in transit. Chapter One has procedures and security features in place to keep data secure once it is received.
Data Sharing
Chapter One may pass your personal data to a third-party service providers contracted to Chapter One as a consequence of providing services to you.
If an employer is paying for your course, Chapter One will share your data, course attendance, course feedback and any applicable results with the employer. Chapter One will also share your data with ACCA and ICSA institutions.
Chapter One requires that all third parties respect the security of your personal data and treat it in accordance with the Data Protection (Jersey) Law 2018 or relevant EU data protection legislation.
Chapter One does not allow third-party service providers to use your personal data for their own purposes and Chapter One only permits them to process your personal data for specified purposes and in accordance with Chapter One’s instructions.
Transferring information overseas
In the event that we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that your personal data is transferred only to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
How long will Personal Data be kept?
Chapter One will only retain your personal data for as long as necessary to fulfil the purposes it has been collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, Chapter One considers 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 Chapter One processes your personal data and whether Chapter One can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask Chapter One to delete your data.
In some circumstances Chapter One may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case Chapter One may use this information indefinitely without further notice to you as this will no longer constitute personal data.
Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 Chapter One holds about you and to check that Chapter One is lawfully processing it.
- Request correction of the personal data that Chapter One holds about you. This enables you to have any incomplete or inaccurate data held by Chapter One corrected, though Chapter One may need to verify the accuracy of the new data provided.
- Request erasure of personal data. This enables you to ask Chapter One to delete or remove personal data where there is no good reason for continuing to process it. You also have the right to ask Chapter One to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where Chapter One may have processed your information unlawfully or where Chapter One is required to erase your personal data to comply with local law. Note, however, that Chapter One may not always be able to comply with your request of erasure for specific legal reasons which will be notified, if applicable, at the time of a request.
- Object to processing of your personal data where Chapter One is 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 Chapter One is processing your personal data for direct marketing purposes. In some cases, Chapter One may demonstrate that it has compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask Chapter One to suspend the processing of your personal data in the following scenarios:
- If you want Chapter One to establish the data’s accuracy.
- Where Chapter One’s use of the data is unlawful but you do not want Chapter One to erase it.
- Where you need Chapter One to hold the data even if Chapter One no longer requires it as you need it to establish, exercise or defend legal claims.
- You have objected to the use of your data but Chapter One needs to verify whether it has overriding legitimate grounds to use it. - Request the transfer of your personal data to yourself or to a third party. Chapter One will provide to you, or the chosen third party, 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 Chapter One to use or where Chapter One used the information to perform a contract with you.
- Withdraw consent at any time where Chapter One is 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, Chapter One may not be able to provide certain services to you. Chapter One will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact info@chapteronetraining.com. You also have the right to complain to the data protection regulator in the country where you live and work. In Jersey this is the Jersey Office of the Information Commissioner (https://jerseyoic.org/).
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, Chapter One may charge a reasonable fee if the request is deemed to be unfounded, repetitive or excessive. Alternatively, Chapter One could refuse to comply with your request in these circumstances.
What Chapter One may require from you
Chapter One may need to request specific information to help 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. Chapter One may also contact you to ask for further information in relation to the request to speed up Chapter One’s response.
Response Times
Chapter One will aim to respond to all legitimate requests within one month. Occasionally it could take longer than a month if the request is particularly complex or you have made a number of requests. In this case, Chapter One will notify you and keep you updated.
What we need you to do
You are responsible for making sure the information you provide to us is accurate and up to date. You must tell us if anything changes as soon as possible. If you provide information to someone else e.g. your employer you should direct them to this notice. If we need that person’s consent, we will ask you to confirm that you have obtained such consent and may request you to provide proof of obtaining the consent.
Amendments
Chapter One may change this notice from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This notice is effective from 1st January 2020.