This Policy applies between the User (“you”), and Practical Financial Exams Limited (“us” or “we”). This policy complies with EU and UK law including the General Data Protection Regulation (GDPR).
Practical Financial Exams Limited is registered with the Information Commissioner’s Office to process personal data under registration number A1100589. Practical Financial Exams Limited is the “data controller” which means that we determine how your data is processed.
This Policy does not extend to any external websites that can be accessed from the Practical Financial Exams Limited website such as YouTube and LinkedIn.
We may collect information from you in two ways:
Candidate Enrolment Forms
When enrolling for a qualification, you provide us with the following information via a Candidate Enrolment Form, for the following purposes:
This information enables us to understand and confirm candidates’ identities; and get in touch with candidates where required.
This information is for data analysis purposes, so that we can better understand what our customers do day-to-day and continue to meet their needs in future through the development of new and existing products. For example, if 80% of our customers indicated they worked as paraplanners, this would inform our product design going forward; new products would be developed with paraplanners in mind.
This information is required so that, where permitted by you, we can upon your employer’s request provide your them with your exam record, including any details of attempts and results. For example, this might be the case where your employer has paid for your qualification.
Furthermore, to enable us to better understand our customers by analysing which companies they’re working for, allowing us to continue to meet their needs in future through the development of new and existing products.
We also use this information to manage conflicts of interest. For example, to ensure that no candidate is also an Assessor for the same paper.
Other ways we gather information you provide to us
We may also gather information:
We use Stripe as our payment processor, and we also allow payment via PayPal. Practical Financial Exams Limited does not store your payment details; these are input and held with Stripe and PayPal.
We may need to gather information related to access arrangements, reasonable adjustments, and special considerations, which may include details of protected characteristics under the Equalities Act 2010 such as disability, gender/sexuality, and religion. This is to allow us to enable fair access to assessment for everyone, regardless of their protected characteristics. Examples may include:
If any of your information changes, please keep us up to date by e-mailing any new information to email@example.com.
This section explains how we collect information automatically.
We may automatically collect your IP address, geographical location, pages visited, and the dates, times, and frequency with which you use the website, which helps us make ongoing improvements to the website to deliver a better experience for our customers and prospective customers.
We may use analytics Cookies to learn more about how our Users are using the website, and to track the performance of the website.
Cookies can be enabled or disabled in your internet browser, and you can choose to delete them at any time, although you may lose information that enables you to access the website and our products and/or services more quickly and efficiently.
For more information about Cookies, please visit the Cookies page on the Information Commissioner’s Website: https://ico.org.uk/your-data-matters/online/cookies/.
If you subscribe to our mailing list, create and account, become a member, and/or become a customer, we can tell when and how you open and engage with our marketing campaign e-mails. This information is held on our GoDaddy account. This enables us to understand how effective our e-mail marketing campaigns are at engaging our customers and prospective customers and develop our e-mail marketing campaigns accordingly.
Information from Candidate Enrolment Forms
Information from Candidate Enrolment Forms is retained indefinitely because, over time, certificates may be lost, and to erase peoples’ achievements after an arbitrary retention period would be unfair to candidates who contact us years later requesting a replacement certificate, or where they require proof of qualification for an employer, or as part of a Recognition of Prior Learning process for another qualification provider or awarding body.
Furthermore, indefinite retention enables us to facilitate our Malpractice Policy, such as the enforcement of indefinite bans on assessment for candidates who commit, or who are suspected of committing, the most serious acts of malpractice, and so that we can challenge and/or withdraw awards from historic candidates where malpractice relevant to their assessment has subsequently been discovered.
We retain any sensitive personal information/special category data for one year following the latest assessment decision, including assessments and appeals, which enables the information to be available to the Scottish Qualifications Authority for the purpose of external verification.
Information on our Malpractice Log is usually retained for one year following the latest assessment decision, including assessments and appeals, which enables the information to be available to the Scottish Qualifications Authority for the purpose of external verification. However, where disciplinary action has been taken, such as bans on future exam sittings, this information is retained until one year following the end of any such action. For example, if a candidate were subject to a five-year ban on sitting assessments, this information would be held for six years. For lifetime bans, the information would be held indefinitely to enable the ban to be enforced.
Assessment evidence is retained for one year following the latest assessment decision, including assessments and appeals, which enables the information to be available to the Scottish Qualifications Authority for the purpose of external verification.
Assessment decisions (marks and grades) are updated to the Main Candidate Log (MCL) and stored indefinitely, the same as with candidates’ personal information (excluding special category data) for the same reason: there is no reasonable time limit for candidates potential need to request a replacement certificate or proof of qualification for personal, employment, or Recognition of Prior Learning purposes.
We will delete your data on request. However, even if we delete it, we may still hold it on a back-up hard drive for legal, tax, and/or regulatory purposes.
Subscribers, Members, and Customers
If you subscribe to our mailing list, create and account, and/or become a customer, you provide us with information such as your name, e-mail address, telephone number, and latest activity (e.g. e-mail viewed, completed new order, etc). We can also tell when and how you open and engage with our e-mails. This information enables us to contact you for marketing purposes. It is held on our GoDaddy account and as far as we know it is stored indefinitely. You can unsubscribe from our mailing list at any time by clicking “unsubscribe” on one of our e-mails, and/or request your information deleted or amended from our GoDaddy account anytime by e-mailing firstname.lastname@example.org.
We often communicate with our clients via social media such as LinkedIn and YouTube. For example, via private messaging and comments on posts. Information stored on these websites is according to their own Privacy Policies. As far as we know, this information is stored indefinitely.
The following information about assessment candidates is provided to our contractor Assessors:
Full name, Unique Candidate Number, postal address, postcode, and date of birth are provided to enable our contractor Assessors to confirm candidates’ identification. Date of enrolment and enrolment expiry are provided to enable our contractor Assessors to confirm that the assessment is taking place within the candidates’ enrolment period. Assessment evidence enables Assessors to grade candidates' work.
For practical reasons, information relating to access arrangements, reasonable adjustments, and special considerations may be shared with our contractor Assessors. This is communicated on an ad-hoc basis, depending on the specific requirements of the candidate.
We may also share personal information with the following groups of people for the following reasons:
Any information that cannot be used to identify you can be shared or published by us. This helps us market the business, provide prospective candidates with information like pass/fail rates, and evaluate our customer base.
We use the following third-party providers to enable us to operate our business and provide our products and services to you. Some of these have servers located in the United States of America. As a result, there will be a transfer of your data outside of the European Economic Area (EEA) to the USA. By using the Practical Financial Exams Limited products and/or services, you consent to our transferring your information to countries outside the EEA where and as necessary. Below are the third-party providers, with their purpose for Practical Financial Exams Limited and links to their privacy policies.
Purpose: Sending assessment evidence between PFE and its contractor Assessors
WeTransfer is based in Amsterdam, the Netherlands.
Purpose: Payment processor
Purpose: Payment processor
Provider: Microsoft Exchange
Purpose: E-mail server
We take reasonable steps both in terms of policy within the organisation and, also using technology, to keep your data secure. However, while we take these reasonable steps, we cannot guarantee the security of your data.
All personal information, such as from Candidate Enrolment Forms and Assessment decisions, is stored on the hard disk of the company’s computer, within a McAfee File Lock digital vault, protected by a complex password. Data is backed up daily onto an external hard drive.
Payment details are encrypted using SSL technology. Our SSL Certificate is issued by Go Daddy Secure Certificate Authority – G2.
Assessment evidence is password protected before being e-mailed between PFE and our contractor Assessors using Microsoft Office and, for larger files, WeTransfer Pro.
Assessment evidence is permanently deleted from the hard drives of our contractor Assessors once the relevant assessment evidence has been graded and returned to PFE.
If you suspect data misuse or unauthorised access, please contact us immediately at email@example.com.
Visit Get Safe Online at www.getsafeonline.org for information on how to protect yourself against a wide range of online problems such as fraud, identity theft, and viruses.
You have the following rights in relation to your Data:
Right to access
The right to request copies of the information we hold about you at any time, or that we modify, update or delete such information. If we provide you with access to the information that we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
Right to correct
The right to have your Data rectified if it is inaccurate or incomplete.
Right to erase
The right to request that we delete or remove your Data from our systems.
Right to restrict our use of your Data
The right to "block" us from using your Data or limit the way in which we can use it.
Right to data portability
The right to request that we move, copy, or transfer your Data.
Right to object
The right to object to our use of your Data including where we use it for our legitimate interests.
To enquire about or exercise any of the above rights, or withdraw consent for us processing your data, please contact us at firstname.lastname@example.org.
If you wish to make a complaint regarding to the processing of your data, please contact us at email@example.com. If for whatever reason we were unable to resolve the complaint, or you were unhappy with the way we handled your complaint, you may be able to refer your complaint to the Information Commissioner’s Office (ICO). You can contact the ICO here: https://ico.org.uk/.
You can contact us at firstname.lastname@example.org.