Privacy Policy
Smart Training and Recruitment is committed to protecting your data. This policy explains how and why we use your data to ensure you remain informed and in control of your information.
How we use your information
Smart Training and Recruitment is committed to protecting your information. This policy explains what we collect, why we collect it, who we share it with, how long we keep it and what you can ask us to do about it. It applies to everyone we deal with — learners, apprentices, employers, enquirers, job applicants and visitors to our website.
1. Who we are
Smart Training and Recruitment Limited is registered in England and Wales, company number 04735396, registered office Suite 18, Mill Court Business Centre, Furrlongs, Newport, Isle of Wight, PO30 2AA. Our UK Provider Reference Number is 10005927.
We are the data controller for the information described in this policy — meaning we decide what is collected and why.
Questions about this policy, or about information we hold on you: GDPR@smarttar.co.uk, for the attention of our Data Protection Lead, or write to the address above. General enquiries: askus@smarttar.co.uk or 01983 475006.
2. Who this policy covers
- Learners and apprentices on our programmes, and people applying to join one.
- Employers and the workplace managers and mentors we deal with.
- Enquirers who contact us through our websites, by phone or at an event.
- Job applicants and people applying for work with Smart.
3. What we collect
What we hold depends on our relationship with you.
| Who you are | What we typically hold |
|---|---|
| Enquirers | Name, organisation, email, phone, the qualification you asked about and anything you wrote to us |
| Learners and apprentices | Contact and identity details, date of birth, prior learning and qualifications, employment details, programme progress, assessments and evidence, attendance, support needs, and records of the advice and guidance we give you |
| Employers | Business contact details, the roles and programmes involved, agreements and invoicing details |
| Job applicants | Your application, CV, references and right-to-work checks |
4. Sensitive information
As a training provider we sometimes need information that the law treats as sensitive — for example ethnicity, health conditions, additional learning needs, and safeguarding information.
We collect it for specific reasons: to make reasonable adjustments and give you the support you need, to meet the equality and funding duties placed on us as a government-funded provider, and to keep learners safe. We only collect what we need, and we limit who can see it.
5. Why we use your information
| What we use it for | Our lawful basis |
|---|---|
| Replying to your enquiry | Our legitimate interests — you asked us about our courses |
| Enrolling and delivering your programme, and awarding your qualification | Performing our contract with you or your employer |
| Reporting to the Department for Education, funding bodies, awarding organisations and Ofsted | Meeting our legal and funding obligations |
| Safeguarding learners and meeting our Prevent duty | Meeting our legal obligations, and protecting people from harm |
| Improving our teaching, support and quality of provision | Our legitimate interests in running a good training organisation |
| Sending you news, courses and offers | Your consent — you opt in, and you can opt out at any time |
We group our contacts by sector and interest so that what we send is relevant. We do not make automated decisions about you that have legal or similarly significant effects, and we never sell your information.
6. Who we share it with
- Your employer, where you are on a programme through work — progress, attendance and reviews.
- The Department for Education and funding bodies, through the Individualised Learner Record and related returns. The Department is a data controller for that information in its own right and publishes its own privacy notice.
- Awarding organisations and end-point assessment organisations, so your work can be assessed, certificated and quality assured.
- Ofsted, auditors and quality assurance bodies, as part of inspection, audit and accreditation.
- Our suppliers, including Microsoft for our email and systems, and the providers of our learning platform and e-portfolio. They act on our instructions under contracts that require them to keep your information confidential and secure.
- Statutory partners, such as the police, local authority safeguarding teams or health services, where there is a safeguarding concern or we are legally required to share.
We do not share your information with anyone else without telling you.
7. Marketing
We ask you to opt in before we send you marketing. Every marketing email carries an unsubscribe link, and you can also tell us to stop at any time by emailing askus@smarttar.co.uk. If you ask us to stop, we keep a record of that preference so that we do not contact you again by mistake.
8. Where we keep it, and how we protect it
Your information is processed and stored within the United Kingdom, on Microsoft 365 and Microsoft Azure.
We control who can see what, both physically and electronically. Our staff are trained in data protection and follow set procedures for handling personal information. We never store payment card details.
9. How long we keep it
| Information | How long we keep it |
|---|---|
| Enquiries that do not lead to a booking or enrolment | 24 months from our last contact with you |
| Learner and apprentice records | At least six years after your programme ends, as required by funding and audit rules |
| Employer and customer records | Six years after the end of our relationship, in line with business and tax record rules |
| Unsuccessful job applications | Six months after the recruitment process closes |
| Marketing preferences | For as long as we need them to respect your choice |
We review what we hold and delete what is no longer needed.
10. Young people and adults at risk
We work with learners under 18 and with adults at risk. Where a learner is under 18 we involve parents, carers or the employer as appropriate, and we handle safeguarding information under our Safeguarding and Prevent policy.
11. Your rights
Under UK data protection law you can ask us to:
- Show you what we hold about you — a subject access request
- Correct anything that is wrong
- Delete it where we have no continuing reason to keep it
- Stop or limit how we use it
- Object to our use of it where we rely on legitimate interests, or to marketing at any time
- Send it elsewhere in a portable format, where that right applies
Email GDPR@smarttar.co.uk and we will respond within one month. We can send you a subject access request form with guidance on making your request, which helps us respond more quickly — just ask.
Some rights have exceptions — for example, we cannot delete records we are required to keep for funding or audit purposes while we still need them. We will always explain our reasoning.
12. Accessible formats
If you would like this policy in large print, as plain text, in an easy-read version or read aloud, email askus@smarttar.co.uk and we will provide it.
13. Complaints
If you are unhappy with how we have handled your information, contact our Data Protection Lead at GDPR@smarttar.co.uk so we can put it right. Complaints that are not about your information are handled under our Complaints Procedure.
You also have the right to complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
14. Other websites
Our website links to other organisations’ websites. We are not responsible for their content, and this policy does not cover any information you give them — please read their own privacy notices before sharing anything. If you buy goods or services from a business we link to, your contract is with them and not with Smart Training and Recruitment.
15. Changes and review
We review this policy at least once a year and whenever we change how we use your information. The current version is always published on our website.
Last updated: September 2026. Next review: September 2027.
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