During the course of our contractual arrangement, we may process personal data on behalf of our customers. The customer is the data controller in this agreement and Titus is the data processor.
Titus is committed to the security of our customers’ personal data, and to meeting the legal requirements imposed by the Data Protection Act. Titus’ Information Security Policy details these commitments further.
Definition of Data Protection Terms
Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems.
Data subjects for the purpose of this policy include all living individuals about whom Titus holds personal data. A data subject does not need to be a UK national or resident. All data subjects have legal rights in relation to their personal information.
Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in possession of the company). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way. Mere mention of someone’s name in a document does not constitute personal data, but personal details such as someone’s contact details or salary would still fall within the scope of the Data Protection Act (2018) and the General Data Protection Regulation (GDPR) 2016 (“the Acts”).
Data controllers are the people or organisations who determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Acts.
Data Users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following the company’s data protection and security policies at all times.
Data Processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on the company’s behalf.
Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive Personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.
About the information we collect and hold
We will collect and/or hold the following information during our contractual agreement:
name, contact details, phone number, email address, learner information (including those of children) such as name, contact details.
Why and how we collect information
We collect the information to enable us to fulfill our contractual obligations. Information will be collected during the implementation phase of the project. As you are the data controller you control the information on your platform at all times. From time to time we may fulfill a request from you to assist in the uploading of data. During these times we will take instruction from you on how we receive the information for uploading.
From time to time we may contact you to see if you are still interested in the platform following your enquiry. We will hold your contact information for a maximum of three years from initial enquiry. If you no longer wish to hear from us you may opt out at any time by responding to the email.
How we may share information
We will never share your information with third parties, unless required to fulfil our contractual obligation
Where information may be held
Contractual information is stored on our CRM, Hubspot, which is access restricted to Titus employees only. Information in relation to your contract such as learner details is all held in your Moodle platform, hosted on AWS servers which are all located globally, as specified in the individual client contracts. All servers are encrypted and access restricted.
Please contact Sebastian Francis at firstname.lastname@example.org or on +44 (0)1133 200 346 if you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask Sebastian Francis for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way and limit access to your personal information to those who have a genuine business need. We are ISO27001 (certified by BSI, Certificate ref IS 726020). Our QA policy outlines our commitment to maintain a quality system that not only meets the requirements of ISO 9001 and ISO27001, but also fully supports our business strategy and objectives. Additionally, we are Cyber Essentials certified and currently working towards our Cyber Essentials Plus certification.