Valid from: 2025-06-02
Version: 01.00
1. Introduction
1.1 This Data Protection and Privacy Notice (hereinafter – Notice) describes how Entry Point North Group when acting in the role of a controller, collects and processes personal data about data subjects such as employees, students/ trainees, clients, suppliers and other individuals for a variety of business purposes.
1.2 All personal data is treated with respect and according to the General Data Protection Regulation (GDPR) which includes adequate protection of personal data and limitation to business purposes only.
2. Collecting personal data with cookies
2.1 By visiting and using our website, personal data collected with cookies will be processed.
3. Types of personal data processed
3.1 We process personal data about our data subjects when this is necessary and in accordance with the applicable legislation. Depending on the specific circumstances, the processed personal data include the following types of personal data:
- Name
- Phone number
- E-mail address
- Assessment reports
- CVs
- Photos
4. Purposes of processing the personal data
4.1 We will only process your personal data if we have a legitimate purpose and in that case in accordance with the rules of GDPR. The personal data we collect about you is processed for the following purposes:
- Compliance with our legal, regulatory and corporate governance obligations and good practice;
- Gathering information as part of oversight by regulatory bodies or regarding legal proceedings or requests;
- Operational reasons such as ensuring that the Entry Point North Group processes, procedures and policies are adhered to;
- Checking references, ensuring safe working practices, monitoring and managing staff, access to systems and facilities and staff absences, administration and assessments;
- Monitoring records of persons undertaking or having undertaken training and establish and maintain a system for recording the professional qualification of staff.
- Instructor feedback, staff conduct and disciplinary matters;
The personal data is treated fairly and lawfully in accordance with individuals’ rights and by procedures laid down in Entry Point North Group’s Privacy Notice. Entry Point North Group retains personal data for no longer than necessary and thereafter the personal data is removed according to Entry Point North Group’s data retention plan.
5. Legal basis for processing personal data
5.1 We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:
- The processing is necessary for the performance of a contract to which the data subject is a party in accordance with GDPR, Article 6(1)(b), the first indent.
- The legal basis for the processing of such personal data is consent, in accordance with GDPR, Article 6(1)(a). You can withdraw your consent at any time by contacting us via the contact details provided at the end of this Notice. If you withdraw your consent, the personal data processed will be deleted, unless it can or must be processed in order to comply with legal obligations.
- The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract in accordance with GDPR, Article 6(1)(b), last indent.
- The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in accordance with GDPR, Article 6(1)(f).
6. Disclosure and transfer of personal data
6.1 We only transfer personal data to other entities when it is legally permitted or required.
6.2 We transfer personal data to the following recipients from the EU/EEA:
- Processors
- Suppliers
- Other recipients at your request
- Banks (for example in connection with payments etc.)
6.3 From time to time we use external entities as suppliers to assist us in delivering our services. The external suppliers will not receive or process personal data unless applicable law allows for such transfer and processing. Where the external parties are acting in the role of processors, the processing is always based on a data processing agreement in accordance with the requirements under GDPR. Where the external parties are acting in the role of controllers, the processing of personal data is based on such external parties’ data privacy policy and the relevant legal bases which the external parties are obligated to inform about unless the applicable legislation allows otherwise.
6.4 If you have any questions about our use of processors, cooperation with other controllers, including our subsidiaries, or the transfer of data to third countries, you may contact us for more information or documentation of our legal basis for such transfers.
7. Erasure and retention of personal data
7.1 We ensure that the personal data is deleted when it is no longer necessary for the processing purposes described above. However, we retain your personal data to the extent that we are legally obligated, as is the case with for example accounting and bookkeeping materials and records. If you have any questions about our retention of your personal data, you may contact us by using the email mentioned in the last section of this Notice.
8. Data subject rights
8.1 As a data subject under GDPR, you have a number of rights.
8.1.1 You have the right to request access to the personal data we process about you, the purposes we process the personal data, and whether we disclose or transfer your personal data to others.
8.1.2 You have the right to have incorrect information rectified.
8.1.3 You have the right to have certain personal data deleted.
8.1.4 You may have the right to restriction of our processing of your personal data.
8.1.5 You may have the right to object to our processing of your personal data based on reasons and circumstances that pertain to your particular situation. Objection can also be to the processing of personal data for the purpose of direct marketing.
8.1.6 You have the right not to be subject to a decision based solely on automated means, without human interference unless the decision (1) is necessary for entering into, or performance of a contract between you and the Organization, (2) is authorised by law, or (3) is based on your explicit consent.
8.1.7 If the processing of your personal data is based on your consent, you are entitled to withdraw such consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing carried out prior to your withdrawal.
8.1.8 You are entitled to receive personal data which you have provided to us in a structured, commonly used, and machine-readable format (data portability).
8.1.9 You can always lodge a complaint with the data protection authority.
8.2 Your rights may be subject to conditions or restrictions. Accordingly, there is no certainty that you will be entitled to for example data portability in the specific situation; it will depend on the circumstances of the processing.
8.3 More information about data subject rights can be found in the guidelines of the national data protection authorities.
8.4 Please use you the contact details below if you want to use your rights.
8.5 We try to meet your wishes about our processing of personal data, but you can always file a complaint to the data protection authorities.
9. Changes to this Notice
9.1 We reserve the right to update and amend this Notice. If we do, we correct the date and the version at the top of this Notice. If we make significant changes, we will provide notification by way of a visible notice, for example on our website or by direct message.
10. Contact
10.1 You may contact us at the below specified email if you:
a) disagree with our processing or consider our processing of your personal data infringes on the law,
b) have questions or comments to this Notice, or
c) want to invoke one or more of your rights as a data subject described in this Notice.
If you have questions or comments to this Notice or if you would like to invoke one or more data subject rights, please contact us at privacy@entrypointnorth.com.