By submitting an application via a third party link on, or registering as a user on, the site, you understand that we will be processing your personal data. If, as an applicant, you have made an application for a course with ACLT via a third party link on the site, you are agreeing to share your personal data with ACLT for the purposes of processing your application and, if approved, enrolling you on an ACLT course on our online learning environment, Canvas.
The information contained in your application or user profile may also be used for statistical analysis. Further information about the way in which ACLT will use submitted data and regulate access to it, is set out below, and you should read and understand this before entering your details on the ACLT website and/or application form.
Changes to the policy
2 What personal data do we collect and process?
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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth and Contact Data includes billing address, email address and telephone numbers.
Application Data includes details you have provided about current and previous employers, qualifications and references as part of an application form submission
Financial Data includes bank account and/or payment card details entered via our third party payments systems Stripe and Xero.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us via our third party payments systems Stripe and Xero.
Technical Data includes internet protocol (IP) address, your login data.
Profile Data includes your username and password, applications made by you.
Usage Data includes anonymised information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us, any third parties and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. 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, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3 How do we collect personal data?
Applicant or registered user information is only accessible to those users who have registered for an account and issued with a login username and password via the site. Users will be restricted to accessing information associated with their reason for accessing the site, including any application form; these roles are as follows:
An enquirer - no access to data submitted (name, email, job title, employer) but ability to request changes under 7. Your rights
An applicant – access to their own application data;
A registered user - access to their own profile data;
An ACLT administrator – access to all information contained within and submitted via the ACLT site.
4 What do we use your personal data for?
We have set out in this section the reasons why we use your personal data and the legal basis for using your personal data for that particular purpose.
We may use your information:
(i) To process your application for courses for which you have applied:
Legal basis for use:
We use your personal data for this reason because it is in our legitimate interests to process your personal data in relation to your application.
(i) To give you access to a user account on the site for which you have registered:
Legal basis for use:
We use your personal data for this reason because it is in our legitimate interests to process your personal data in relation to your account creation.
(ii) To inform you of changes to the ACLT site:
We may contact you if the ACLT site is part of a re-organisational change where we may need to transfer some or all of your personal data to a relevant third party (or its advisors). Your personal data would continue to be used for the same purposes set out in this policy or for the purpose of analysing any reorganisation.
Legal basis for use:
We may need to use your information to achieve the legitimate interest of allowing us to make changes to how ACLT operates.
(iv) For statistical analysis purposes:
We may use your personal data for statistical analysis purposes to, amongst other things, produce reports which show the types of applicants applying for ACLT courses. Final reports do not contain any personal data.
Legal basis for use:
We may need to use your information to achieve the legitimate interest of allowing us to undertake statistical analysis of the students on ACLT courses, as outlined above.
5 Who do we share your personal data with?
Disclosures to ACLT
- via access and processing on central IT systems; and
- via internal reports;
Disclosures to ACL
Personal data (name and email address) is shared with the Association of Costs Lawyers (ACL) for the purposes of enabling them to set up trainee membership for you if you have been enrolled on an ACLT course, unless you specifically opt out of being a ACL member. Following course completion or withdrawal, we will also provide ACL with the date that this occurred and the final course grade awarded, as applicable.
Disclosures to CLSB
Personal data (name and email address) is shared with the Costs Lawyers Standards Board (CLSB) for the purposes of notifying them of the date of your course completion, enabling them to contact you regarding a Qualifying Experience submission and application for a CLSB Practising Certificate.
Third party service providers
6 How long do we keep your personal data for?
If you submit an application for a course, we will retain that application data in full for six years after the completion of, or withdrawal from, the course.
If you create a draft application and it was not submitted, we will delete that application two years after the closing date of the application window.
Where legal claims are contemplated we will retain your personal data for this purpose, where we reasonably believe that information will be necessary to defend or prosecute or make a claim against you, us or a third party, for six years after the circumstances have arisen which may give rise to a claim.
For statistical analysis of submitted applications we will retain your personal data for this purpose for up to six years after the account was created (if not enrolled) or after the completion of, or withdrawal from, the course (if enrolled).
7 Your rights
You have certain rights under data protection legislation in relation to the personal data that we hold about you. These rights are subject to certain exemptions such as public interest (e.g. prevention of crime) and our interests (e.g. maintaining legal privilege). Your rights include:
- the right to access your personal data;
- the right to rectification of your personal data;
- the right to erasure of your personal data;
- the right to restrict or object to the processing of your personal data;
- the right to withdraw your consent to the processing of your personal data at any time where such processing is based on your consent;
- the right to data portability;
- the right to object to receiving marketing; and
- the right to complain to your supervisory authority about the use of your personal data. In the UK this is the Information Commissioner's Office.
If you would like to contact us about your rights, please see email us at firstname.lastname@example.org