What information does TrainFX collect?

TrainFX collects and processes a range of information about our clients. This includes:

• your name, address and contact details, including email address and telephone number;
• the terms and conditions of business we have with you as a client;
• contact details for your nominated staff members dealing with us to provide goods and services to you, including names, email addresses and telephone numbers;
• CCTV images of you should you visit our site;
• information about client billing and costs associated with the provision of goods and services to you; and
• details of your bank account and VAT registration details.

TrainFX collects this information in a variety of ways. For example, data is collected from forms completed by you at the start of or during our engagement and from correspondence with you.

Why does TrainFX process personal data?

TrainFX needs to process data to deliver the goods and support requested by you, our client. For example, we need to process your data to provide you with bespoke goods and services. In these cases, TrainFX has a legitimate interest (Article 6.1.f UK GDPR) in processing personal data before, during and after the end of the client engagement. Processing client data allows TrainFX to:

• maintain accurate and up-to-date contact details and record any required terms of business and/or client goods and services agreements, including client supplier agreements;
• operate and keep a record of the duration of service provision to enable accurate billing; and
• ensure effective general business administration.

Who has access to data?

Client information will be shared internally, with members performing an administrative or finance function in relation to client billing and approved TrainFX Ltd staff and contractors. TrainFX managers, staff and contractors will only access the specific data necessary for the performance of their roles. TrainFX will only share client data with TrainFX Ltd contractors in connection with the provision of specialist goods and support services once approved by you.

TrainFX Ltd utilise a secure storage, access system for your personal data.

How does TrainFX protect data?

TrainFX takes the security of your data very seriously. TrainFX has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees or approved contractors in the performance of their duties. For more information please request a copy of the Subject Access Request and Data Breach policies from the data protection lead.

Where TrainFX engages contractors to assist with the provision of goods and services to you, they do so on the basis of formal instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does TrainFX keep data?

TrainFX will hold your personal data after the conclusion of the provision of direct support to you. The periods for which your data is held will usually be 7 years, in order to comply with HMRC guidance. The period we will hold your personal data after the conclusion of the provision of direct support to you may be longer than 7 years where the contract we have with you stipulates that a longer retention period is required.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require TrainFX to rectify incorrect or incomplete data;
• require TrainFX to delete your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where TrainFX is relying on its legitimate interests as the legal ground for processing; and
• ask TrainFX to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override TrainFX’s legitimate grounds for processing data.

If you would like to exercise any of these rights or submit a subject access request, please contact TrainFX Ltd Data protection lead, Martin Lyons in writing.  Martin can be contacted at martinl@trainfx.com. If you believe that TrainFX Ltd has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

In order to support you with the provision of bespoke goods and services you may be requested to provide relevant personal data (i.e. contact details or bank details for billing purposes).

Certain information, such as contact details and payment details, have to be provided to enable TrainFX to provide you with goods and services. If you do not provide relevant information, this will hinder TrainFX’s ability to provide you with relevant goods and services efficiently and effectively.

Automated decision-making

Decisions relating to client requirements are not based automated decision-making.

You have the right to complain to Information Commissioner’s Office if you believe TrainFX has infringed your rights. They can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF.

Helpline number: 0303 123 1113

TrainFX Ltd Data protection lead

The TrainFX Ltd Data protection lead is Martin Lyons.  Martin can be contacted at martinl@trainfx.com