List of active policies

Full policy

Last updated: October 2026. Next review: October 2027.

1. Who we are

SmartEdge is the short course academy and a trading name of Smart Training and Recruitment Limited, registered in England and Wales, company number 04735396. Our registered office is Suite 18, Mill Court Business Centre, Furrlongs, Newport, Isle of Wight, PO30 2AA.

Smart Training and Recruitment Limited is the data controller for your learner information. That means we decide what information is collected and why.

This notice covers your time as a learner: your account on our learning platform at moodle.smartedgetraining.com, your workshops, your assessments and your certification. Our website privacy notice covers enquiries, paying online and the cookies on our main website.

• About your course: askus@smartedgetraining.com or 01983 475006.
• About your information: GDPR@smarttar.co.uk, for the attention of our Data Protection Officer, Jon Rogers, or write to the registered office above.

2. What we collect, and why

Your learning account

When you enrol and pay, we use the details you gave us to create your account on the learning platform.

What we hold	Why we hold it
Your name and email address	To create your account, let you log in and send you course messages
Your employer’s name	To keep your learner record accurate and, where your employer is paying, to place you in the right group
Your name as it should appear on your certificate, your date of birth and your personal email address, which you give us on the enrolment form	To register you with CMI so you can be certified
Your SmartEdge learner ID	To identify your record with us and with CMI
Your username and password	To keep your account secure. Your password is stored in scrambled (hashed) form, so nobody at SmartEdge can read it
A profile picture and anything you add to your profile (optional)	So your tutor and group can recognise you. You choose whether to add these

Your enrolment course

Your first course on the platform is your learner induction. It includes your initial assessment, a skills scan and your Individual Learning Plan (ILP).

What we hold	Why we hold it
Your answers to the initial assessment and skills scan	To check the qualification is right for you and agree your starting point
Your Individual Learning Plan	To plan your learning and track your progress against it
Your answers to “Tell us what you need” (optional)	To plan any support or reasonable adjustments you need for learning and assessment (see “Information about your health or learning needs” below)

Your learning and assessment

What we hold	Why we hold it
Which activities you have completed and when	To show you and your tutor how far through each unit you are, and to unlock your next unit when you finish the induction
Your answers in interactive activities and quizzes	To give you feedback and check your understanding
Your assignments, including any resubmissions	To assess your work against CMI’s requirements
Your tutor’s feedback and your result (Pass or Refer)	To record your assessment decision and support you to resubmit if needed
A history of changes to your results	To show how and when a result was changed, for quality assurance
Notes your tutor records about your progress	To support you and keep an accurate record. You can ask to see these notes
Anything you post in forums, the glossary or comments, and messages you send	To let you learn with your tutor and group, and share ideas with other learners on your course
Entries in your blog (optional)	Your blog is a private space for reflection. Only you can see it. If you want to share an idea with others, use your course forum instead
Digital badges you earn	To recognise your progress. If you choose to send a badge to an external badge backpack, that service holds a copy under its own privacy notice

Workshops

You book your workshops through Microsoft Bookings and join them on Microsoft Teams.

What we hold	Why we hold it
Your name, email address and the workshop you booked	To confirm your place and send you the joining link
Whether you attended	To keep your learning record accurate
A recording of the workshop, including your name, anything you say or type in the chat and your video if your camera is on	So tutors can check what was covered and our quality team can check the quality of delivery. Recordings are stored in our Microsoft 365 SharePoint and only tutors and quality assurance managers can open them. You can keep your camera off if you prefer

How you use the platform

Like most learning platforms, ours keeps a record (a log) each time you view a page or complete an action. Each entry includes the date and time, what you did, and your Internet Protocol (IP) address, which identifies your internet connection. We use these logs to help if something goes wrong, to keep the platform secure and to confirm your progress if there is ever a question about it.

We do not use these logs to build a profile of you or to make automated decisions about you. We never sell your information.

Use of AI in marking

We use Microsoft 365 Copilot for a first-line review of your assignments. It checks your work against CMI’s assessment criteria and highlights points for your tutor to look at. Your tutor uses the licensed version of Copilot, signed in with their SmartEdge work account, which means:

• your work is covered by our contract with Microsoft and Microsoft’s enterprise data protection
• Microsoft does not use your work, or what Copilot produces from it, to train its AI models
• your work stays within our Microsoft 365 environment.

Copilot never marks your work and does not make any decision about you. Your tutor reads your full assignment, checks anything Copilot has highlighted, and decides your result and feedback. Our Internal Quality Assurers check a sample of these decisions in the same way as any other assessment.

Information about your health or learning needs

The “Tell us what you need” form in your induction asks whether you have a learning need, disability or health condition that may affect your learning or assessment. Answering is optional, and you only need to share what you are comfortable sharing.

UK data protection law treats health information as special category data, which needs extra protection. We only use it to:

• plan the support you need while you learn
• arrange reasonable adjustments to your assessments, including requesting them from CMI where CMI needs to approve them.

Only your tutor and the people who arrange your support see it. If we need to request an adjustment from CMI, we will tell you what we plan to share with CMI before we share it, and only share what CMI needs to consider the request.

3. Our lawful basis

What we do	Our lawful basis
Set up your account, deliver your course and workshops, assess your work and register you with CMI	Performance of our contract with you
Keep activity logs, carry out internal and external quality checks, and keep records that show our assessment decisions were fair	Legitimate interests. As a CMI approved centre we must be able to show that assessment is accurate and fair, and you would expect us to keep this record
Record workshops, and use Microsoft 365 Copilot for a first-line review of your work	Legitimate interests. Recordings let us check the quality of teaching, and Copilot’s first-line review helps your tutor give you consistent, timely feedback. Your tutor reviews every assignment and makes every decision
Tell an employer who paid for your place that you have enrolled, and when you achieve your qualification	Legitimate interests. Your employer has paid for your place and needs to know it’s being used and what it has achieved
Keep records we are required to keep by law	Legal obligation
Use information about your health or learning needs to plan support and request reasonable adjustments, including from CMI	Your explicit consent, which you give when you complete the form. You can withdraw it at any time by emailing GDPR@smarttar.co.uk. If you do, we may not be able to put some adjustments in place

4. Cookies on the learning platform

The learning platform only sets cookies it needs to work, so there is no cookie banner.

Cookie	What it does	Can you turn it off?
Session cookie	Keeps you logged in as you move between pages. It is deleted when you close your browser	No, you cannot log in without it
Remember username	Remembers your username on the login page, only if you tick “Remember username”	Yes, leave the box unticked
Page options	Remembers your colour scheme and text size if you change them with the accessibility tools	Yes, it is only set if you use those tools

Our brand font is stored on our own server, so the platform does not send any information about you to a font provider.

5. Who sees it

• Your tutor. Sees your work, progress, notes and anything you share in “Tell us what you need”.
• Your group. You are placed in a group with other learners on your course. They can see your name, profile picture and anything you post in shared spaces, such as forums. They cannot see your blog, assignments, results or support needs.
• Our quality team. Our Internal Quality Assurers (IQAs) check a sample of assessment decisions to make sure they are accurate and fair.
• CMI. We register you with CMI so you can be certified. We share your first name(s) and surname as they should appear on your certificate, your date of birth, your personal email address, your SmartEdge learner ID (if you have one by then) and your results. If you need a reasonable adjustment that CMI must approve, we also share the information CMI needs to consider the request, after telling you what it is. CMI’s external quality assurer may also check your work and our records. CMI’s own privacy notice explains how it uses your information.
• Your employer, if they paid for your place. We email them when you enrol on the place they paid for, and again when you achieve your qualification. We don’t share your progress, individual results, support needs or other personal details with them unless you ask us to.
• Microsoft. Our learning platform runs on Microsoft Azure, and our email, Teams, Bookings, SharePoint (where workshop recordings are stored) and Copilot run on Microsoft 365, under contracts that require Microsoft to protect your information and use it only on our instructions.
• Zoho. We keep your enrolment and booking details in Zoho CRM, our customer records system. When you enrol, it creates your learning account automatically and keeps a note of your learning account number. Your progress and results are not sent to Zoho. When you complete your qualification, your tutor signs off your completion and claims your certificate from CMI. Zoho stores this information in the European Union.

We do not share your details with anyone else unless we are legally required to.

Where it is kept. The learning platform, including its database and the files you upload, is hosted on Microsoft Azure in London (UK South). Backups of the platform are kept in London, with a second copy in Cardiff (UK West) in case of a major outage. None of your learning platform information is stored outside the UK. Our Zoho records are stored in the European Union (EU), which the UK recognises as protecting personal information to the same standard as UK law.

6. How long we keep it

Information	How long
Your learner record: account, enrolment answers, Individual Learning Plan, assignments, feedback and results	5 years, as that is how long CMI gives you to complete your qualification
Your answers to “Tell us what you need”	5 years, so we can show CMI and our quality team what support and adjustments we put in place. Any adjustment request we send to CMI is kept with your assessment record
Workshop recordings	5 years, as that is how long CMI gives you to complete your qualification
Activity logs	12 months, then deleted automatically
Platform notifications	Read notifications are deleted after 1 week, and all notifications after 1 month
Backups	We back up the whole platform every hour, and each course automatically. All backups are kept in the UK and deleted after 30 days. Information deleted from the platform may stay in a backup for up to 30 days, but no longer.
Payment records	6 years from the end of the financial year you paid in, as UK tax law requires

7. Your rights

Under UK data protection law you can ask us to:

• show you what we hold about you
• correct anything that is wrong
• delete it where we have no continuing reason to keep it
• stop or limit how we use it
• object to our use of it where we rely on legitimate interests
• send it elsewhere in a portable format, where that right applies
• withdraw your consent at any time, where we rely on it

You can make a request from your profile on the learning platform using “Contact the privacy officer”, or email GDPR@smarttar.co.uk. We will respond within one month. You can also see a summary of how long we keep information using the “Data retention summary” link at the bottom of every page on the platform.

8. If you need this in another format

Accessibility matters to us. It is built into how we design our courses, and it applies to this page too. If you would like this notice in large print, as plain text, in an easy-read version or read aloud, email askus@smartedgetraining.com and we will sort it out.

9. Complaints

If you are unhappy with how we have handled your information, please tell us first so we can put it right: GDPR@smarttar.co.uk.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113.

10. Changes to this notice

If we change how we use your information, we will update this page and the date at the top, and ask you to read it again when you next log in. We review this notice at least once a year.