Privacy Policy

Effective Date: 1 August 2024

Competence Development Ltd ("Competence Development", "us", "we", or "our") operates the hosted service including the Competence software and underlying database (the "Hosted Service") on behalf of its licensed customers, processing data in respect of customers' users ("Users", "you").

This Privacy Policy informs customers' users of the policies operated in respect of the collection, use and any disclosure of users' personal data when the Hosted Service is licensed by a customer, and the rights of customers' users in respect of that personal data.

Who We Are

Competence Development is a data processor, not a data controller. Your personal data is shared with Competence Development by the customer — usually your employer or education provider — for the purposes of your use of the Competence application and its underlying database. The legal obligation of compliance with all national data protection laws remains the responsibility of the customer, not Competence Development.

However, Competence Development acts as data processor on behalf of the customer, collecting and processing users' personal and transactional data as detailed below, with full account of privacy legislation.

Types of Data Collected

Personal Data

While using the Hosted Service under the customer's control, you will provide certain personally identifiable information used to identify you ("Personal Data") and transactional data processed within the Hosted Service. Personally identifiable information may include, but is not limited to:

  • Names, addresses, email addresses, and phone numbers
  • Employer information and gender
  • Passwords (stored in hashed format only)
  • Additional personal data fields as configured by your employer
  • Transactional data processed within Competence
  • Analytics and usage data

Competence Development and its technical staff who may have access to your personal data will not disclose your personal data to any third party except to the customer or your employer.

Competence Development will not use your email address to send you announcements or information about other products or services. Your personal data will not be given to third parties for marketing purposes.

We may use your email address to send you notices related to the Hosted Service, including notices required by law.

Special Categories of Personal Data

The following special categories of personal data have the potential to be recorded in the system, dependent on the customer's choice of usage: ethnicity and religion. These are only recorded where the customer has obtained the appropriate consent from individuals.

Analytics and Usage Data

When you access the Hosted Service by or through a mobile device, we may collect certain usage data automatically, including the type of mobile device you use, your mobile operating system, the type of mobile internet browser you use, customer account identifier, app version and other diagnostic data.

Cached Data

Competence is a cloud-based application. Your data is stored on a secure server under Competence Development's licensed usage and control. When you install Competence on your device, a copy of certain personal data may also be stored locally. This is known as a cached copy and is used for speed purposes and to allow use while offline. The only personal data cached on a device are your first and last name, and job title.

How We Use Your Data

Competence Development uses collected data for the following purposes:

  • To provide and maintain the Hosted Service
  • To notify you about changes to the Hosted Service
  • To allow you to participate in interactive features of the Hosted Service
  • To provide customer care and support
  • To provide analysis to improve the Hosted Service
  • To monitor usage of the Hosted Service
  • To detect, prevent and address technical issues

Data Transfer and Storage

All personal data relating to users in the United Kingdom is stored and processed within the United Kingdom. Competence Development will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your personal data will take place to an organisation or country unless there are adequate controls in place, including the security of your data and other personal information.

Disclosure of Data

Competence Development may disclose your personal data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of Competence Development
  • Prevent or investigate possible wrongdoing in connection with the Hosted Service
  • Protect the personal safety of users or the public
  • Protect against legal liability

Security of Data

The security of your data is important to us. All personal data sent to and from the Hosted Service is encrypted in transit using industry-standard TLS encryption. All data is encrypted at rest using AES-256 encryption. The Hosted Service is hosted on Amazon Web Services (AWS) in the UK (eu-west-2, London region).

Service Providers

We use Amazon Web Services (AWS) to provide the hosting infrastructure for the Hosted Service, and Kaltura for video hosting and streaming functionality. These providers have access to your personal data only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

Device Permissions

The mobile app requests use of the following device permissions as and when they are needed:

  • Internet — to communicate with our servers and access links to other sites
  • Internal Storage — to cache reusable information and downloaded files
  • Camera — to capture pictures or video for uploading as evidence
  • Microphone — to capture audio or activate the voice-to-text feature
  • Photo Library — to allow previously captured pictures or video to be uploaded from your device

Your Rights

Under UK GDPR you have the following rights in respect of your personal data:

  • The right to be informed about how your data is used
  • The right to access your personal data
  • The right to rectification of inaccurate data
  • The right to erasure ("the right to be forgotten")
  • The right to restrict processing
  • The right to data portability
  • The right to object to processing
  • Rights related to automated decision-making and profiling

To exercise any of these rights, please contact us at the address below. We will respond to all requests within one calendar month.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the effective date. Where changes are material, we will also notify you by email or by a prominent notice within the Hosted Service prior to the change becoming effective.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us:

Competence Development Ltd, Robin Park, Loire Drive, Wigan, WN5 0UL

Email: support@competence.team