VestraPath

Legal

Privacy notice

Last updated: [date]

This notice explains what personal information VestraPath collects, why we collect it, who sees it and the choices you have.

Template for legal review — placeholders in [brackets]

On this page

1. Who we are

VestraPath (“we”, “us”, “our”) is a trading name of [Company legal name], a company registered in England and Wales with company number [company number] and its registered office at [registered office address].

We are the data controller of the personal information described in this notice. That means we decide how and why it is used. Our ICO registration number is [ICO registration number].

This notice applies when you visit our website, apply to VestraPath or take part in the programme. Our service is for people aged 18 or over [confirm minimum age].

For any question about this notice, or to use your rights, contact us at [privacy email] or write to [registered office address]. [Name and contact details of data protection officer or privacy lead, if one is appointed.]

2. The information we collect

We collect most of it from you directly. The categories are:

  • Application details. Your name, email address, university, course, year of study and the banking roles you are interested in. [Confirm the fields collected.]
  • Entrance-assessment answers and scores. Your answers to the entrance assessment and the snapshot we produce from them.
  • Skill-assessment results. Results from the assessments you take during the programme.
  • Account details. Your login email and a password, which we store in hashed form [confirm], and your account settings.
  • Payment details. Payments are taken by our payment provider, [payment provider]. We receive confirmation of the payment, the amount and the date. [Confirm that we do not receive or store your full card details.]
  • Communications. Messages you send to us or to your coach, support requests and any feedback you give.
  • Technical data and cookies. Your IP address, browser and device type, the pages you visit and how you use the site. See section 9.

[Confirm whether any special category data is collected, for example information about a disability or the adjustments you need. If it is, state the condition relied on, such as explicit consent.]

3. How we use it and our lawful bases

UK data protection law requires us to have a lawful basis for each use of your information. This table sets out what we do and why.

PurposeInformation usedLawful basis
Assessing your applicationApplication details; entrance-assessment answers and scoresContract (steps taken at your request before you join). Legitimate interests (running a fair, selective admissions process).
Running the programmeAccount details; skill-assessment results; communicationsContract.
Taking payment and keeping financial recordsPayment confirmation; billing detailsContract. Legal obligation (accounting and tax records).
Service emails, such as decisions, reminders and changesName; email address; programme statusContract.
Improving the programmeAssessment results and usage data, de-identified or aggregated where possibleLegitimate interests (understanding what works and improving it).
Keeping the service secure and preventing misuseTechnical data; account activityLegitimate interests. Legal obligation where it applies.
Analytics cookiesTechnical dataConsent.
Marketing emailsName; email address; preferencesConsent. You can withdraw it at any time.

Where we rely on legitimate interests, we have weighed them against your rights and expectations. You can object to this use (see section 8).

4. Who reviews your application

A person reviews every application. Your entrance-assessment score gives you an instant snapshot and helps the reviewer, but it does not decide the outcome on its own.

We do not make decisions about admission solely by automated means where they would have a legal or similarly significant effect on you. If you disagree with a decision, you can ask us to take another look by contacting [privacy email]. [Describe the review process and timescale.]

5. Who we share it with

We do not sell your personal information. We share it only where it is needed:

  • Service providers that host our website and data, send our emails and help us run the programme, acting on our instructions. [List categories or named providers.]
  • Our payment provider, [payment provider], which processes your payment under its own privacy notice.
  • Coaches and specialists involved in your programme, who see what they need in order to support you. [Confirm whether coaches are employees or contractors.]
  • Our university partner, but only with your consent, and only what you agree to share. [Confirm what, if anything, is shared.]
  • Professional advisers, regulators, law enforcement or courts where the law requires it or to protect our legal rights.
  • A buyer or successor if our business is reorganised or sold, who must keep to this notice.

6. International transfers

Some of our providers may process information outside the United Kingdom. When that happens we make sure your information stays protected, for example by relying on UK adequacy regulations or by using the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. [List providers and countries involved.]

You can ask us for a copy of the safeguards we use by contacting [privacy email].

7. How long we keep it

We keep personal information only as long as we need it for the purposes above. Our current periods are:

  • Unsuccessful applications: [12 months] after our decision.
  • Programme participants: [12 months] after the programme ends.
  • Payment and accounting records: [6 years], as required by law. [Confirm with your accountant.]
  • Marketing preferences: until you withdraw consent, then a record of that choice for [period].
  • Cookies: for the periods set out in our cookie settings.

When the period ends we delete the information or anonymise it so that it can no longer identify you.

8. Your rights

Under UK data protection law you have the right to:

  • Access the personal information we hold about you and receive a copy.
  • Correct information that is inaccurate or incomplete.
  • Erase your information in certain circumstances.
  • Restrict how we use your information in certain circumstances.
  • Receive your information in a portable format, or ask us to send it to another organisation, where we use it on the basis of consent or contract.
  • Object to uses based on legitimate interests, and to direct marketing at any time.
  • Withdraw your consent at any time, where we rely on it. This does not affect what we did before.

To use any of these rights, email [privacy email]. We will reply within one month and will not charge a fee unless a request is clearly unfounded or excessive. We may ask you to confirm your identity first.

If you are unhappy with how we have handled your information, please tell us first so we can try to put it right. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator, at ico.org.uk/make-a-complaint.

9. Cookies

Cookies are small files that a website stores on your device. We use two kinds:

  • Essential cookies keep you signed in and the site secure. The site cannot work without them, so we do not ask for consent.
  • Analytics cookies help us understand how the site is used so we can improve it. We set these only if you agree. [Name the analytics provider and list the cookies.]

[Confirm that no advertising cookies are used.] You can change your choice at any time in [link to cookie settings]. You can also block or delete cookies in your browser settings, although parts of the site may then stop working.

10. Changes to this notice

We may update this notice from time to time. The date at the top shows when it last changed. If we make a significant change, we will tell you by email or on the website before it takes effect.

11. Contact us

Questions about this notice or your information:

  • Email: [privacy email]
  • Post: [Company legal name], [registered office address]