Last update: 01.11.2023
This notice describes how we collect and process users’ data through https://acpmglobal.com website, https://acpmglobal.co.uk website, https://my.acpmglobal.com website (collectively “the Platform”). The terms “we”, “us”, “our” refer to ACADEMY OF CERTIFIED PROFESSIONAL MANAGERS LIMITED, a legal person incorporated under the laws of England and Wales.
Controller details: ACADEMY OF CERTIFIED PROFESSIONAL MANAGERS LIMITED
Registered address: 6 St. Davids Square, Westferry Road, London, E14 3WA, United Kingdom
Data Protection Officer:
Table of contents:
- Data we collect
- Legal basis for processing your Personal Data
- Data storage and retention
- Third-party access to Personal Data
- Your rights
- Security of Personal Data
- Changes to this Notice
Data we collect
Personal Data you give to us
We collect personal data that you provide to us when you register for an account, update or change information for your account, purchase products or services, take an exam, sign-up for email updates, send us email messages.
We may use the personal data that you provide to respond to your questions, to send training supplements upon your request, provide you the specific services you select, provide you with results of your exam and send you email messages about the Platform maintenance or updates, sending marketing emails with your consent.
The Platform is not for use by children under 13 years and we will not knowingly collect or use the personal data of children. If you are under the age of 13 please do not provide any personal data even if prompted to do so. If we become aware that we have inadvertently received personal information from a user under the age of 13, we will delete the information from our records.
- Platform Registration
If you want to use Platform functionality, you will have to register an account. We will ask you for your email address and account password.
If you apply to undertake an assessment service provided by, or through us, the Platform may collect personal profile details such as first and last name, contact details (email, phone number), country of residence. Your education qualifications and employment history occupation may be provided to us optionally with your consent to help us to understand our audience and personalise our services.
This will also include copies of documents you provide to us as proof of identity – e.g. copies of your passport or driving licence.
The Platform maintains copies of these documents for 60 days from the date of the exam taken after which, if there is no need to resolve disputes, enforce our legal agreements with you, it is deleted.
- Exam Registration
If you are willing to register for an exam, you need to provide the Platform with information necessary to schedule an exam such as discipline chosen and preferable date of the exam.
- Remote Proctoring
The Platform enables test candidates to get access remotely to an exam on their computer while allowing the Platform to conduct an exam and to check if any fraud is committed during the exam.
The Platform has engaged Examus online proctoring software for test candidates to take exams online in synchronous mode which involves remote online monitoring by Examus and control of the examination process by a proctor designated by the Platform.
Specifically, Examus will collect test candidat’s photograph and photo identifications and use artificial intelligence to confirm that they are the same person for the purpose of preventing exam fraud.
In addition, test candidates may be asked to show their environment to demonstrate that they do not have materials at hand that could assist them in answering the questions (e.g. cheating).
The candidates’ testing experience will be recorded by Examus and the Platform will collect a phone number in case the candidates’ online connection is disrupted or fraud is being detected.
During Examus online proctoring when a test candidate applies to sit the test through the Platform the following data will be collected: first and last name, audio-video recording of the test, recording of the screen, candidate, candidates’ photograph, candidate's behaviour during the test (face position; disconnections from the Internet network; attempts to use the mouse or trackpad to switch between applications or to exit the system, applications in use), chat history.
At the same time a designated by the Platform exam proctor will monitor the exam process in real time.
The data is being collected during online proctoring by Examus (third party processor on behalf of the Platform) which is the subject to the Data Processing Agreement.
Examus maintains this data for 30 days after which, if there is no appeal of the exam experience by the candidate, it is deleted.
The Platform does not store the recording of online proctoring.
The Platform will collect your exam results and, in conjunction with maintaining your diploma (s), your record of participation in continuing education.
Diplomas will be issued in an encrypted app by a third party provider - Emercoin.
The following records will be stored in the blockchain: unique record identifier, discipline name, date of the exam.
The Platform relies upon a contract fulfilment basis to process personal data associated with providing diploma service.
Information we collect about you through third party providers
For payments, you will be prompted to a third-party payment processing provider, who will store and process your payment information. We will only receive information about payment confirmation from that provider.
Information we collect automatically about you
- Technical data
This data includes your login data, registration date and last logon time.
Legal Basis for processing your Personal Data
We will only process personal data where we have a lawful basis to do so. The basis for processing your personal data varies depending on the activity we collected it for. In some occurrences, we may have more than one lawful basis for processing.
The information below summarises the basis on which the Platform may process personal information:
The Platform processes personal data which is necessary for the performance of a contract for your exam. This includes, but not limited to, the Platform registration, payments, identity checks, conducting exams remotely, test scheduling, test administration, scoring, analyzing the test, certificate issuance.
The Platform processes personal data in order to meet our legitimate interests as a global provider of UK Learning Providers. This includes, but is not limited to responding to general enquiries, supporting test takers, the Platform administration, detecting and preventing fraudulent activity, analyzing of our audience and improving our services.
We process your Personal Data when we need to comply with a legal obligation, meet our on-going regulatory and compliance obligations, including in relation to disclosures to tax authorities and other regulatory and governmental bodies, and to investigate security incidents and prevent crime.
The Platform processes personal data where you have provided your consent to do so. For example, where your personal data is used for marketing purposes or for participation in a survey. You may withdraw consent at any time.
Data storage and retention
Personal data that we have collected from you may be stored on the servers of the cloud provider within the European Union (currently in Germany). In exceptional cases, data processing takes place in a country outside the European Union, we only allow this if the legally required security and privacy measures are met.
We will store your account data, including the categories from the above sections for as long as you have the account with us. After deactivation of the account, the Platform will delete the information within one month. In the case of inactivity, the Platform will deactivate your account 36 months after the last session.
For the activities that are based on consent, you can withdraw your consent at any time by contacting us directly. The withdrawal will not affect the lawfulness of processing based on consent before. You can also opt-out of the e-mail subscription by clicking the appropriate button in our emails to you.
Third-party access to Personal Data
We may also use other organisations to process your personal information to carry out services on our behalf:
- IT support and remote exam invigilation service providers;
- client relationship management software to manage and perform our marketing (email) activities;
- email notification providers;
- cloud hosting providers to store and process collected data;
- third-party advertisement providers;
- website personalisation tools;
- payments processing;
- analytics providers to analyse our efficiency and conduct marketing research;
- carrying out fraud or other legal investigations;
- auditors, external consultants;
- other third party service providers who may be appointed as data processors to perform functions and services on our behalf.
The providers listed above will process personal data based on our instructions only and in a reasonable scope in relation to the purpose for which data is processed. Where we use third party providers we make sure that your personal information is protected and remains in our control.
We reserve the right to transfer personal data about you in the event that we sell or transfer all or a portion of our business or assets, in accordance with applicable law.
When using the analytics services, we collect details of the use of the Platform, including, but not limited to traffic data, location data, length visit, and other communication data.
Non-personally identifiable information is collected and processed, among other services, by Google Analytics in an anonymised and aggregated way to improve our app’s usability and for marketing purposes. Google Analytics is a web analytics service that tracks and reports user traffic on apps and websites. Google Analytics uses the data collected to track and monitor the use of the platform. This data may also be shared with other Google services. For more information on the privacy practices of Google, you can check its Policies at www.google.com/analytics/policies/.
In addition to the disclosures for the purposes identified before, we may disclose information about you:
- if we are required to do so by law;
- in connection with any legal proceedings;
- to establish, exercise or defend our legal rights; and
- in case we sell, license or otherwise assign our company, corporate rights, the Platform or its separate parts or features to third parties.
Except as provided in this privacy notice, we will not sell, share or rent your information to third parties.
You may exercise the UK GDPR rights regarding your personal data. In particular, you have the right to:
- The right to object against the processing of your information
If we process your information for our legitimate interests (e.g., for direct marketing emails or for our marketing research purposes), you can object against it. Let us know what you object against and we will consider your request. If there are no compelling interests for us to refuse to perform your request, we will stop the processing for such purposes. If we believe our compelling interests outweigh your right to privacy, we will clarify this to you.
- The right to access your information
You have the right to know what personal data we process. As such you can obtain the disclosure of the data involved in the processing and you can obtain a copy of the information undergoing processing.
- The right to verify your information and seek its rectification
If you find that we process inaccurate or out-of-date information, you can verify the accuracy of your information and/or ask for it to be updated or corrected;
- The right to restrict the processing of your information
When you contest the accuracy of your information, believe we process it unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will stop processing your data (other than storing it) until we are able to provide you with evidence of its lawful processing;
- The right to have your personal data deleted
If we are not under the obligation to keep the data for legal compliance and your data is not needed in the scope of an active contract or claim, we will remove your information upon your request.
- The right to have your personal data transferred to another organisation
Where we process your personal data on the legal basis of consent you provided us or on the necessity to perform a contract, we can make, at your request, your data available to you or to an organisation of your choosing.
- The right not to be the subject to solely automated decisions, which have a legal or similarly significant effect on you
The Platform uses technology to support the invigilators in the marking and grading. This includes semi-automated and automated analysis of the submitted exam and is reviewed by the invigilators responsible for the grading before the grade is final.
If you believe that our use of personal information violates your rights, or if you are dissatisfied with a response you received to a request you formulated to us, you have the right to lodge a complaint with the competent data protection authority of your choice.
Security of Personal Data
We will take all necessary measures to protect your information from unauthorised or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. As we use the services of third-party software providers across several countries outside of the United Kingdom and the European Union, we may transfer the collected data to those countries for further processing. In such cases, we will make sure that relevant safeguards such as Standard Contractual Clauses are in place. More information on international safeguards can be provided upon request.
Immediate access to the data is only allowed to our authorised employees involved in maintaining the Platform. Such employees keep strict confidentiality and prevent unauthorised third-party access to personal information.
Changes to this Notice
We may update this privacy notice from time-to-time by posting a new version on our website. We advise you to check this page occasionally to ensure you are happy with any changes. However, as far as technically and legally feasible, we will endeavour to provide you with an announcement about any significant changes.