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Probity & Ethics

Privacy · Website and courses · CPD UK Accredited & Certified

Privacy Policy

Last updated
Applies to
This website and all our courses

Privacy policy

Who we are

This policy explains what we do with personal information about you when you use this website, ask us a question, or buy and take one of our courses.

We are the data controller for the information described here, which means we decide why and how it is used. Our contact details are under how to contact us.

The information we collect Existing clause

The Probity and Ethics respects your right to the privacy of any personal information that you provide to us. The personal information includes your name, profession/designation, contact details and any other personal information that you may provide. Unless you designate otherwise, your personal information will be known only to two parties – yourself and us the Probity and Ethics, unless required by the law.

In practice, that is:

  • Identity and contact details — your name, email address, telephone number, and your profession or job title where you tell us.
  • Your enquiry — whatever you choose to write to us, by email, by telephone or through the contact form.
  • Order and account information — the courses you buy, the date, the amount, your billing details, and your login if you create an account.
  • Course records — which courses you have started and completed, your answers to any post-course assessment, and the certificates issued to you.
  • Technical information — your IP address, browser and device, and how you move around the site. See cookies and analytics.

We do not ask for, and you do not need to give us, the details of any allegation or investigation you are involved in. See your regulatory situation stays with you.

Where an employer, trust or practice buys courses for you, they give us your name and email address so that we can set up your access. In that case they have decided to share it, and you may want to check their own privacy notice as well.

Why we use it, and our lawful basis

Data protection law requires us to have a lawful basis for using your personal information. Ours are as follows.

What we use it forOur lawful basis
Answering your enquiryOur legitimate interest in responding to people who contact us, or taking steps at your request before entering a contract
Taking payment and giving you access to a coursePerformance of our contract with you
Issuing and re-issuing CPD certificatesPerformance of our contract with you
Keeping accounting and tax recordsCompliance with a legal obligation
Keeping the website secure and workingOur legitimate interest in running a safe, functioning service
Understanding how the site is usedYour consent, given through the cookie banner
Sending you marketing emailsYour consent, which you can withdraw at any time
Using your feedback in anonymised formOur legitimate interest in describing our courses honestly, as set out in our terms and conditions

Payments Existing clause

You pay for our courses either via a bank transfer or using the online payment system on our website which is provided by Stripe payment service. You should only provide your personal information after reviewing their privacy policy and should only be for the purpose of processing payments.

We do not see or store your full card number. Card payments are handled by Stripe, who process them as a separate controller under their own privacy policy. What we receive from them is confirmation that a payment succeeded, together with the last four digits and card type shown on your order.

Your regulatory situation stays with you

Most people who write to us are in the middle of a regulatory process, and it is reasonable to want to know where that information goes. So, plainly:

  • We do not contact your regulator about you, and we have no reporting relationship with any regulator.
  • We do not contact your employer. There is one exception: where an organisation — an employer, but also a university, a recruitment agency or any other body — has bought a course seat and assigned it to you, that organisation can see, in its own account, that you completed the course and on what date, together with the certificate issued. It cannot see anything else about how you used the course.
  • We do not need the details of the allegation in order to help you, and you should not feel you have to explain it to us.
  • Courses are taken privately on your own device. Where you buy a course yourself, nobody is told that you enrolled. Where the course was bought for you on an organisation’s licence, you are shown and must accept a single sentence saying so before you begin, and you may always buy a course yourself instead, at the standard price, with nothing reported to anyone.
  • We do not publish your name in connection with a course. Where we quote feedback it is anonymised, as our terms and conditions state.
If you do tell us details

Anything you send us is held on the same basis as any other enquiry, and is not shared outside the people who need it to answer you. But there is no need to send it, and the safest course is not to.

Who we share it with

We do not sell your personal information, and we do not share it for anyone else's marketing.

We do use service providers who handle information on our behalf and on our instructions. They may only use it to provide their service to us. They are:

  • Our website and hosting provider, which stores the site and its database.
  • Stripe, for card payments.
  • Our email provider, which carries the messages between us.
  • Our course platform, which delivers the online courses and records completions.
  • Google, for the site analytics described in cookies and analytics, where you have consented to them.

We will also disclose information where the law requires it, or to establish or defend a legal claim.

Where your information is held

Your information is held in the United Kingdom and the European Economic Area wherever possible. Some of our providers, including Stripe and Google, are based in or process data in the United States.

Where information is transferred outside the UK, we rely on the safeguards that data protection law provides for those transfers, such as UK adequacy regulations or the International Data Transfer Agreement. You can ask us which applies to a particular provider.

How long we keep it

We keep personal information only for as long as we need it for the purpose it was collected for, and then delete it. In practice that means:

  • Enquiries that do not lead to a purchase are kept while we are dealing with them and for a short period afterwards, in case you come back to us.
  • Order and payment records are kept for at least six years after the end of the financial year they relate to, because HM Revenue & Customs requires business records to be kept for that long.
  • Course records and certificates are kept while your account is active, so that you can download a certificate again if you need it. Tell us if you would like them removed sooner.
  • Marketing consents are kept until you withdraw them, and a record of the withdrawal is kept so that we honour it.

Cookies and analytics

Cookies are small files a website stores on your device. This site uses two kinds.

Cookies that are necessary

These make the site work: keeping your basket, keeping you logged in, and protecting the checkout. The site cannot function without them, so they are set automatically.

Cookies that are not necessary

We use Google Tag Manager and Google Analytics to understand how people find and use the site, so that we can improve it. These are only set if you agree to them, and you can change your mind at any time through the cookie banner or by clearing cookies in your browser.

Analytics tells us things like which pages are read and how people arrive. It does not tell us who you are, and we do not try to identify individuals from it.

Your rights

Under UK data protection law you have the right to:

  • Be told what we do with your information, which is what this policy is for.
  • Ask for a copy of the personal information we hold about you.
  • Have it corrected if it is wrong or incomplete.
  • Have it deleted, where we no longer have a good reason to keep it.
  • Restrict or object to how we use it, including objecting to any use we base on our legitimate interests.
  • Receive it in a portable form, or have it sent to another provider, where we hold it under a contract with you or with your consent.
  • Withdraw consent at any time, where consent is what we relied on. Withdrawing it does not affect anything done before you withdrew it.

To exercise any of these, email us at mail@www.probityandethics.com. We will respond within one month. There is no charge.

If you are unhappy with how we have handled your information

Please tell us first, so that we can put it right. You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection, at ico.org.uk/make-a-complaint or on 0303 123 1113. You do not have to come to us first.

How we protect it

The site runs over an encrypted connection, payments are handled by a specialist provider rather than by us, and access to order and course records is limited to the people who need it.

No method of transmitting information over the internet is completely secure. Email in particular is not, which is why we ask you not to send us anything through the contact form or by email that you would not want in an ordinary email.

Changes to this policy, and how it fits with our terms Existing clause

The Probity and Ethics reserves the right to change our policies. You are responsible for regularly reviewing these policies.

These terms incorporate by reference all other policies, disclaimers and terms contained anywhere on www.www.probityandethics.com, provided, however, that in the event of a conflict between such other terms and these Terms, these Terms shall control.

The date this policy was last updated is shown at the top of the page. Where a change is significant we will say so on the page rather than leaving you to spot it.

How to contact us

Probity & Ethics, trading name of Harley MedAesthetics Ltd

Email mail@www.probityandethics.com

Telephone 020 7118 0703

London, United Kingdom

For anything about your personal information, email us and put “Privacy” in the subject line so that it reaches the right person quickly.

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