Fair processing notice: Apprentices

Last updated: 15 February 2022

This fair processing notice applies to apprentices taking End Point Assessments.

The data we collect about you

  • Your name and contact details
  • Personal details like your date of birth, gender, ethnic background and Unique Learner Number
  • Employment details like your employer name and job title
  • Any other relevant personal information contained in your submitted portfolio of workplace evidence.

What we do with your data and on what grounds

We can only process your personal data if we have a basis to do so which is permitted by law. This may be that you have given your consent, or it may be one of the other lawful bases for data processing. These comprise situations where it is necessary:

  • for our performance of a contract with you. We process your personal data where it’s necessary in order to fulfil a contract with you or to take steps, at your request, before entering into such a contract
  • for our legitimate interests. We process your personal data as and when necessary to do so in order to conduct and manage our business to provide you with the best service and experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We don’t use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law)
  • to meet our legal obligations. We process your personal data where it’s necessary for compliance with legal or regulatory obligations.
Purpose/activityLawful basis for processing including basis of legitimate interest
Assessment delivery and support, including to fulfil our legal obligations to ensure appropriate levels of assessment support for students who require reasonable adjustments or special consideration due to specific impairments
  • Performance of a contract with you
  • Compliance with our legal obligations
  • Your consent (in respect of sensitive personal data)
To inform you, your training provider and your employers of your EPA results.
  • Legitimate interests (for running our business)
  • Performance of a contract with you

Customer support in relation to your EPA registration and assessment, including:

  • addressing enquiries and resolving issues
  • enabling access to third-party services.
  • Performance of a contract with you
  • Supporting activities performed under your consent and in the substantial public interest (in respect of sensitive personal data)
Managing payment, including enabling training providers to pay EPA fees
  • Performance of a contract with you
  • Legitimate interests (recovering sums owed to us)
To make important communications relevant to your EPA
  • Legitimate interests (for running our business)
  • Performance of a contract with you

Marketing and promotional communications, including to:

  • have a bank of case studies available to contact for inclusion in marketing and promotional material
  • market to existing apprentices via social media
  • market to existing apprentices on behalf of third parties
  • invite people to participate in surveys, research and focus groups to provide feedback about an AAT product or service, and process feedback received and follow up with responses if appropriate
  • communicate third-party campaigns to AAT apprentices
  • communicate non-essential information and send relevant promotional information
  • Your consent (if received)
  • Legitimate interests (to improve our business offerings)

To meet our legal obligations, including:

  • data management, including to assess and maintain the quality of data stored, and deal with returned mail and bounced emails, whilst performing analysis on the completeness and correctness of data
  • to meet our regulatory reporting obligations
  • To meet our legal obligations
  • Supporting activities performed under your consent and the substantial public interest (in respect of sensitive personal data)

Product development and quality control, including to:

  • recruit end users to test the website and other services
  • maintain internal quality levels by conducting call, email and CRM audits
  • identify trends and gather insight relating to AAT products and services
  • monitor engagement with third party services
  • ensure that an appropriate level of quality and consistency is provided by training providers, and maintained throughout assessments and marking, and that assessments are fair and accessible to a diverse range of apprentices
  • Legitimate interests (to improve our business offerings)
  • Supporting activities performed in the substantial public interest (in respect of sensitive personal data)
  • Necessary to meet our legal obligations
IT system administration, to administer internal systems including maintaining access rights, troubleshooting issues and maintaining databases and backups
  • Performance of a contract with you
  • Legitimate interests (for running our business)
Archiving your collected data to support assessment queries, professional standards investigations and general customer queries
  • Performance of a contract with you
  • To meet our legal obligations

Who we share your personal data with

  • Our third-party service providers of payment, user testing, IT and mailing services
  • Your accredited employer and training provider to provide your assessment results
  • Independent Assessors and Chief Independent Assessors for assessment review and marking
  • Our pages on social media platforms, such as Facebook, Twitter and LinkedIn
  • Supervisory/regulatory bodies, law enforcement and independent investigators relating to disciplinary investigations, complaints and regulatory reporting requirements (including the Financial Conduct Authority, Department for Education, Institute for Apprenticeships and Technical Education, Education Skills Funding Agency, and Office of Qualification and Examinations Regulation)
  • Your assessment results details will be stored on our Centre assessment results and Centre statements of achievements services, which will be available to view by your current and any previous training providers

Where we get your data from

Other than directly from you, we may also receive personal data from the following third-party sources:

  • training providers
  • employers
  • Independent Assessors
  • publicly available sources, such as returned post
  • our third-party service providers of IT, career management consultancy and benefits and rewards services.

How long we keep your data

We will retain most of your data for 10 years following the end of your apprenticeship. This may cover registration information and any correspondence between you and AAT. The exceptions to this are below.

  • Your basic student records, such as name, address history, membership statuses, work experience history and other awarding bodies and practice management details will be retained for 70 years from the end of your membership to support other required reporting and professional queries.
  • If you’ve undertaken any AAT assessments, information on these will be retained for 70 years from the date of assessment as will information on qualifications awarded.
  • If you’ve submitted any medical evidence to support Reasonable Adjustment and Special Consideration requests, this will be retained for seven years from the end of the adjustment period.
  • Credit card details will be managed in line with the Payment Card Industry Data Security Standard (PCI DSS) compliance.
  • Direct Debit instructions will be retained for two years from the last payment receipt.

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