Training Privacy Policy

Welcome to the Dematic’s privacy notice. Dematic is a worldwide provider of automated material handling systems/solutions with intralogistics and ergonomic designs that optimises customer capability. Dematic is predominantly a business-to-business provider of products and services.

Dematic respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you engage with Dematic directly or via our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

Dematic is the Data Controller for any personal data provided by a person enrolled on any course with Dematic Limited. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Full name of legal entity: Dematic Limited

Name or title of DPO: Associate Corporate Counsel – Kelly Patel

Email address: Kelly.Patel@dematic.com

Postal address:  Dematic Limited, Banbury Business Park, Trinity Way, Adderbury, Banbury, OX17 3SN

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact the DPO in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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 during your relationship with us in-order to fulfil our contractual obligations to you once you have enrolled on a Dematic training course.

We have identified types of personal data that Dematic may hold about you:

• Personal contact details such as name, title, addresses, telephone numbers and personal email addresses, date of birth, gender, next of kin and emergency contact information;
• National insurance number, copy of passport, copy of driving licence or other ID;
• Bank account details, payroll records and tax status information - Transaction Data includes details about payments to and from you;
• Course details, reposts, training information, start date, end dates, reason for leaving, competency information, support provisions, course assessment and results (the Training Records);
• Previous qualification and course information and other information included in a CV or cover letter or as part of the application process;
• Performance information, feedback forms/emails, complaint, grievance information in-relation to the course.

We also collect, use and share Aggregated Data such as statistical or operational 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 Results Data to report to the awarding body. 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.

We do NOT collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Direct interactions: You may give us your Identity, Contact and/or Financial Data by filling in forms or by corresponding with us by post, phone, emails or otherwise. This includes personal data you provide when you engage with Dematic as your training provider.

Automated technologies or interactions. As you interact with our training timetable, we may collect Training Records as you progress through the course.

How we use your Personal Data  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform our contractual obligations to you as your training provider;
• To create a database to help Dematic understand its performance as a training provider and so that we may improve and plan varied training programs;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
• Where we need to comply with a contractual, legal and/or regulatory obligation.

Generally Dematic do not rely on consent as a legal basis for processing your personal data other than in relation to marketing communications. You have the right to withdraw consent to marketing at any time by contacting the DPO.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Your personal data may be disclosed to 3rd parties who will either be involved in the delivery of your training, services connected to your training and/or a regulatory or awarding body.

Where data is transferred under these circumstances we will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Dematic is an international business and we may share your personal data within the Dematic Group of companies. This will involve transferring your data outside the European Economic Area (EEA). Dematic will ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules. 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact the DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In the case of Training Records and connected personal information Dematic shall hold the personal data for a period of 6 years from the date the training course concluded or 6 years from your 21st birthday if you are not 21 when you commenced the training and thereafter the Training Records and connected personal information shall be deleted.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights include:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact the DPO.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Where a request is made, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Protection Legislation: shall include all applicable privacy and data protection laws including the General Data Protection Legislation ((EU) 2016/679) (GDPR) and any applicable national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2008 (SI2003/2426).

Where an issue arises the following principle shall be adhered to - if both parties (being the Dematic Group entity and the data subject/student) have their registered seat in the same jurisdiction, the relevant data protection law and regulations for that jurisdiction will be complied with by both parties. OR, if both parties have their registered seat in different jurisdictions the data protection law and regulations shall be in accordance with English Law.

Dematic reserves the right to modify this Notice.  If you submit additional personal information following the effective date of a modified Notice, your personal information will be handled in accordance with the Notice in effect at that time.