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Privacy Policy

At Fathom Global Maritime Training (FaGMT), (‘We’) are committed to protecting and respecting your privacy in line with this published Privacy Policy. This policy (together with our Terms of Use and any other documents referred within) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For collecting data covered by the General Data Protection Regulations (GDPR), the Data Controller is FaGMT as applicable in the United Kingdom. GDPR is recognised internationally as having the most stringent measures in protecting the privacy rights of individuals and is applicable to all personal data irrespective of the location or nationality of the users of our Services. FaGMT is committed to applying the highest privacy standards for all its users.


What is ‘Personal Data’?

Personal data is information that relates to an identified or identifiable individual. Examples of such data include an individual’s name, photographs, videos, email address, residential or correspondence address. Personal Data, for the purpose of this Policy also includes the data related to training courses that our clients or customers may attend. This includes but is not limited to course details, tests, examinations and other information submitted as part of the training course requirements.

Who are we?

FaGMT develops, provides training and learning materials and courses (services) to customers and clients across the world, both at sea and ashore. As the ‘Learners’ undertake training through our systems, their details will become part of a professional training record over the working life of the individual, we collect, process and store data relevant to the individuals and, where applicable, their employer(s). A customer or client’s contact details include personally identifiable information. We are committed to protecting the privacy of the individual and security of the data we process and hold. FaGMT is a private limited company and has certain powers and obligations. Most of our client or customer’s data is processed for compliance with legal obligations which includes the discharge of the company’s statutory functions and powers. When exercising these powers or duties it is necessary to process personal data for all personnel using the company’s services. We will always take into account your interests and rights.

Which are the other Data Controllers we work with?

  • PayPal for payment processing.
  • Course approving bodies where they require access to learner’s details.
We may need to share your personal data we hold with them so that they can carry out their responsibilities to the company. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the company and the other data controllers may be ‘joint data controllers’ which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller. A description of what personal data We processes and for what purposes is set out in this Privacy Notice.

What Personal Data is Processed?

The company will process some or all of the following personal data where necessary to perform its tasks:
  • Names, titles and/or aliases
  • Photographs
  • Contact details such as telephone numbers, addresses, and email addresses
  • Where they are relevant to the services provided by a company, or where you provide them to us, we may process information such as gender, age, marital status, nationality, education/work history, academic/professional qualifications, hobbies, family composition, and dependants, racial or ethnic origin or religious beliefs
  • Where you pay for activities such as training courses, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers
  • The personal data we process may include sensitive or other special categories of personal data such as mental and physical health, details of injuries, medication/treatment received

How is Personal Data Processed 

In order to comply with legal requirements and obligations to third parties, We may process sensitive personal data including, as appropriate:
  • information about your physical or mental health or condition in order to take decisions on your fitness for our courses
  • your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation and meal requirements
Some data is described in the GDPR as ‘Special categories of data’ which requires higher levels of protection. The GDPR defines special category data as:
  • personal data revealing racial or ethnic origin
  • personal data revealing political opinions
  • personal data revealing religious or philosophical beliefs
  • personal data revealing trade union membership
  • data concerning health
  • data concerning a person’s sex life
  • data concerning a person’s sexual orientation

  • We may process special categories of personal data in the following circumstances:
  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations.
  • Where it is needed in the public interest.
Less commonly, we may process this type of personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Would we ask for your Consent to Process Your Personal Data?

In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. We will comply with data protection law which requires us that the personal data we hold about you must be:
  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
We may use your personal data for some or all of the following purposes:
  • For marketing purposes, we may provide you with information on products and services which may be of interest
  • For prevention, detection or investigation of fraud or security incidents
  • For statistical or analytical purposes
  • Our processing may also include, where applicable, the use of CCTV systems for the prevention and prosecution of crime.
  • To contact you by post, email, telephone or using social media (e.g., LinkedIn, Facebook, Twitter, WhatsApp)
  • To enable us to meet all legal and statutory obligations
  • To help us build up a picture of how we are performing
  • To improve our products and services
  • To maintain our own accounts and records
  • To notify you of changes to our facilities, services, events and staff, and other role holders
  • To process any transactions or financial payments required for goods or services
  • To promote the interests of the company
  • To provide our members and stakeholders with tools   models, consultancy and support, guidance, industry systems, reports, training, standards, networks, groups & conferences, research and news
  • To seek views or comments, including inviting you to participate in surveys or consultations
  • To seek your views, opinions or comments
  • To send you communications which you have requested and that may be of interest to you. These may include information about courses, new projects or initiatives and changes in policies
  • To work with our staff members and business to create a safer, sustainable, more efficient railway
  • Using data for statistical or analytical purposes
  • Where your information is used other than in accordance with one of these legal bases, we will inform you

What is the Legal Basis for Processing Your Personal Data?

We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with the direct delivery of a training course or services, online or by other means, or the processing of the data for provision of a course operated by one of our training partners. Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use. If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

How do we Share your Personal Data?

This section provides information about the third parties with whom the company may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):
  • The data controllers listed above under the heading ‘Other data controllers the company works with’
  • Our agents, suppliers and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, or to maintain our database software
What is the Duration for which we keep your Personal Data? We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations as an internationally approved training provider. For example, copies of STCW Certificates issued by the company are required by international maritime law to be kept until your 75th birthday. The company is also permitted to retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims. We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.

What are Your Rights with respect to Your Personal Data

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using our usual methods. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. If you believe that we have done something wrong by not complying with GDPR please contact us in the first instance to make a complaint for which we aim to resolve. Should you not be happy with this resolution, you do have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office. You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the GDPR.

Changes to this Policy

We keep this Privacy Policy under regular review and we will place any updates on www.fagmt.co.uk. This Notice was last updated in December 2020.

Contact Details

Please contact us if you have any questions, comments and requests regarding this privacy policy using our usual contact methods.

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