e-Learn Design is committed to the security of our clients’ personal data. This privacy policy details how we may collect and process personal data during the course of any contractual agreement.

e-Learn Design is a Data Processor registered with the ICO ref: Z2107917. For the purposes of this policy, clients are Data Controllers, retaining control of their data and remaining responsible for their compliance obligations under the Data Protection Legislation, including but not limited to providing any required notices and obtaining any required consents and for the written processing instructions they give to e-Learn Design.

The processing of personal data should be lawful, fair and transparent.

Personal data should only be collected for specific, explicit and legitimate purposes.

The processing of personal data must be adequate, relevant and limited to what is necessary.

Personal data must be accurate and, where necessary, kept up to date.

Personal data should not be kept longer than necessary.

Personal data should always be processed in a manner which ensures security.

The Acts refer collectively to the Data Protection Act (2018) and the General Data Protection Regulation (GDPR) 2016

Data subjects include all living individuals about who e-Learn Design holds personal data.

Personal data is data relating to a living individual who can be identified from that data or from that data and other information the company holds. This information must have the data subject as its focus and affect the individual’s privacy in some way. The mere mention of someone’s name in a document does not constitute personal data, but other personal details (address, email) would fall within the scope of the Acts.

Data Controllers are the people or organisations who determine the purposes for which any personal data is used and the manner in which it is processed.

Data Processors include anyone who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition, but it could include suppliers who handle personal data on the company’s behalf.

Processing is any activity that involves using the data, including gathering, recording, storing, organising, amending, retrieving, disclosing or destroying it. This also includes the transfer of personal data to third parties.

Data Users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following the company’s data protection and security policies at all times.

How your personal information may be collected

1. e-Learn Design gathers information on individual clients by request, particularly main client contacts and invoicing details, as well as through our helpdesk support system. The amount and type of information that we gather depends on the nature of the interaction. For example:

we may ask clients who use our helpdesk to provide a username, email address, and full name of an end-user experiencing difficulties diagnosing a technical problem, and only insofar as necessary or appropriate to fulfil the client’s support request

All client and support ticket information is held in a database; this is only accessible via users and/or accounts with sufficient privileges for support or administration.

2. Individual client Moodle installations collect the following types of personal information:

names and email addresses, country of origin of account, city of origin of account

3. Some client Moodle installations also collect additional user information as identified in the optional user account profile fields chosen by the client, such as:

phone numbers, billing information, etc.

This information is stored in individual client Moodle databases that are only available to specified system accounts; all passwords are encrypted.

How your personal information may be shared

e-Learn Design will only release personal information under the following circumstances:

• where release is required by our contractual obligations;
• where release is required by law or regulation, or is requested by an agency for governmental investigative purposes or governmental proceedings;
• where our records indicate a company may be engaged in fraudulent activity or other deceptive practices that a governmental agency should be made aware of;
• to debt collection agencies or to the Court;
• to HMRC if obliged to do so by law;
• to our appointed professional advisers, including our accountants, lawyers and bankers, to the extent that they require in order to properly advise us; or
• to appropriate persons, where your communication suggests possible harm to others.

How your personal information may be used

e-Learn Design may use the information held about you in the following ways:

• to comply with our contractual obligations to you;
• to enforce the terms of any contractual arrangement you have entered into with us;
• to help protect your information and prevent unauthorised access to it;
• to ensure the proper operation and protection of our systems;
• to deal with any queries, problems or complaints reported by you;
• to notify you of any changes to our terms of business;
• to notify you of any information relevant to the delivery of your services;
• for the purposes of payment verification or debt recovery; and
• if required to do so by law.

How your personal information may be stored

Contractual information is held in e-Learn Design’s Freshdesk CRM system, while information relevant to your contracted services (e.g. learner details) is held in your Moodle or IOMAD platform, hosted on OVH servers, which are EU and/or UK-located as required, and AWS servers in Ireland for backups. We will:

• take the appropriate security measures to help safeguard your personal information from unauthorised access and disclosure;
• store your personal information for as long as is necessary in order to fulfil the purpose/s for which it was collected; and
• retain personal information provided to us in connection with contractual obligations for 7 years after the conclusion of our contract with you.

How long your personal information may be retained

e-Learn Design will only retain your personal data for as long as necessary to fulfil the purpose/s it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data, and the applicable legal requirements.

All of our servers are subject to a 30-day backup policy.

You can exercise the following rights by contacting us at mydata@e-learndesign.co.uk or in writing to e-Learn Design, Baltic Chambers, Suite 142, 50 Wellington Street, Glasgow, G2 6HJ:

• to access personal information held about you and to obtain a copy of it;
• to prevent any processing of personal information that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
• to obtain the rectification of personal information which is inaccurate or incomplete;
• to restrict or object to the processing of your personal information and to request its erasure (the ‘right to be forgotten’) under certain circumstances;
• to lodge a complaint about the way in which your personal data is being used;
• to ask us not to process your personal data for marketing purposes; and
• to withdraw your consent to any use of your personal data by us other than for one of the legitimate purposes set out above.

e-Learn Design logs non-personally-identifying information of the sort that web browsers and servers typically make available (for example, via cookies), such as:

browser type, language preference, referring site, date and time of individual request

e-Learn Design does not hold this information; logs are overwritten daily.

Our website may include links to third-party websites, including through social media sharing buttons. e-Learn Design does not control these third-party websites and is not responsible for their data privacy or cookie policies. Clicking on those links may allow third parties to collect or share data about you, so we recommend reading the privacy notices and cookie policies of all websites visited.

e-Learn Design reserves the right to change this policy at any time. While clients will be notified in writing of substantive changes, we encourage you to check this page frequently for any amendments. Your use of this site constitutes your acceptance of the collection and use of your data as detailed above.