Privacy Notice 

Privacy Notice

Adaptive Pathways Learning CIC

Last updated: September 2026

Adaptive Pathways Learning CIC respects your privacy and is committed to protecting the personal information we hold about you.

This Privacy Notice explains what personal information we collect, why we collect it, how we use and protect it, when we may share it, how long we keep it and the rights you have in relation to your information.

We aim to explain this in clear and accessible language.

1. Who we are

Adaptive Pathways Learning CIC is a Community Interest Company providing personalised education, coaching, employability, enterprise and progression support.

Our services may include:

• Employability coaching

• Enterprise training and workshops

• Progression coaching

• Education and learning support

• Functional Skills support

• AQA Unit Award Scheme activities

• Support for people experiencing barriers to education, training or employment

• Programmes commissioned by schools, colleges, charities, community organisations and other partners.

For data protection purposes, Adaptive Pathways Learning CIC is responsible for deciding how and why personal information is processed in connection with our services.

2. Contacting us about data protection

If you have a question about how we use your information, want to exercise a data protection right or have a concern about our handling of your information, please contact:

Adaptive Pathways Learning CIC

Data Protection Officer (DPO): Rhiannon Rigby
Adaptive Pathways Learning CIC
Email: rhi@adaptivepathwayslearning.co.uk

3. What personal information do we collect?

The information we collect depends on the services you use and how you interact with us.

This may include:

Identity and contact information

• Name

• Preferred name

• Date of birth or age

• Contact details

• Address or general location where relevant

• Preferred method of communication

Information about education, training and employment

Where relevant to the support being provided, we may collect information such as:

• Current or previous education or training

• Employment status

• Employment goals

• Skills and experience

• Qualifications

• Attendance information where necessary for an agreed programme

• CV or application information

• Progression goals

Information about support needs

Where necessary to provide appropriate and accessible support, we may collect information about:

• Communication preferences

• Accessibility requirements

• Reasonable adjustments

• Learning needs

• Barriers to education, training or employment

• Support strategies that work well for the individual

Where relevant and necessary, this may include information relating to disability, neurodivergence or health.

We only seek information that is relevant to the support we are providing and do not routinely require detailed medical information.

Referral information

If someone is referred to us by another organisation or professional, we may receive information such as:

• Name and contact details

• Reason for referral

• Goals and support needs

• Relevant information about barriers to education, training or employment

• Relevant safeguarding information

• Information about adjustments that may help the individual

Where information is provided by someone other than the individual, we will provide the relevant privacy information in accordance with data protection requirements.

Session and progress information

We may keep records relating to:

• Sessions attended

• Learning activities

• Coaching activities

• Progress towards agreed goals

• AQA Unit Award evidence where applicable

• Reviews and outcomes

• Feedback

• Agreed next steps

Parent, carer and professional information

Where appropriate, we may collect contact details and relevant information from:

• Parents or guardians

• Schools

• Colleges

• Charities

• Social Prescribers

• Community organisations

• Other professionals involved in supporting an individual.

Financial information

Where you purchase services from us, we may collect information necessary to:

• Process payments

• Issue invoices

• Maintain financial records

• Meet accounting and legal requirements.

We do not normally need to hold your full payment-card details.

4. Special category information

Some of the information we may process can fall within the category of special category data, for example information concerning health or disability.

We will only collect or use this type of information where it is necessary and where we have an appropriate legal basis and special category condition under applicable data protection law.

For example, information about an individual's support needs may be necessary so that we can make reasonable adjustments and provide appropriate support.

We ask referrers and individuals to provide only information that is relevant and necessary.

5. How we collect information

We may collect personal information:

• Directly from you

• From a parent or guardian where appropriate

• Through a referral

• From a school or college

• From a charity or community organisation

• From a Social Prescriber or other professional

• Through our website

• Through email or telephone communication

• Through registration or booking forms

• Through feedback or evaluation forms

• During sessions and support activities

• From publicly available information where appropriate and lawful.

If we receive information about you from another organisation, we will provide you with appropriate privacy information.

6. Why do we use your information?

We may use personal information to:

Provide services

• Assess whether our support is appropriate

• Arrange and deliver sessions

• Develop personalised support

• Make reasonable adjustments

• Deliver coaching, education, employability and enterprise programmes

• Support progression towards agreed goals

• Provide AQA Unit Award activities where applicable

• Monitor progress and outcomes.

Manage referrals

• Receive and assess referrals

• Contact individuals

• Communicate with referrers where appropriate

• Coordinate support

• Make appropriate onward referrals where necessary.

Safeguarding

We may use and share information where necessary to:

• Protect children and adults at risk

• Respond to safeguarding concerns

• Prevent or respond to serious harm

• Meet relevant safeguarding responsibilities

• Work with appropriate safeguarding professionals or authorities.

Safeguarding information may sometimes need to be shared without consent where there is a lawful basis to do so.

Administration

We may use information to:

• Arrange appointments

• Communicate with individuals and organisations

• Manage bookings

• Process payments and invoices

• Maintain appropriate records

• Manage complaints

• Manage our business and commissioned programmes.

Legal and regulatory responsibilities

We may process information where necessary to comply with applicable legal, regulatory or reporting requirements.

Monitoring and improving our services

We may use information to:

• Evaluate programmes

• Understand outcomes

• Improve our services

• Obtain feedback

• Demonstrate the impact of our work.

Where possible, information used for reporting or promotional purposes will be anonymised or otherwise appropriately de-identified.

7. Our lawful bases for processing

Data protection law requires us to have a lawful basis for processing personal information.

Depending on the circumstances, we may rely on one or more of the following:

Contract

Where processing is necessary to provide services that you have agreed to receive or to take steps at your request before entering into an agreement.

Legitimate interests

Where processing is necessary for our legitimate interests or those of another organisation, provided those interests are not overridden by your rights and interests.

For example, this may include appropriate business administration, communication and service management.

Legal obligation

Where we need to process information to comply with a legal obligation.

Consent

Where we ask you to provide consent for a particular use of your information.

Where consent is the lawful basis, you can withdraw your consent. Withdrawal of consent does not affect processing that took place before consent was withdrawn.

Vital interests

In exceptional circumstances, information may be processed where necessary to protect someone's vital interests.

The appropriate lawful basis depends on the particular processing activity. We do not rely on consent for every type of processing.

8. Special category data

Where we process special category information, such as information concerning health or disability, we will also identify an appropriate condition for processing under applicable data protection law.

The condition used will depend on the circumstances and purpose of the processing.

We will only process special category information where it is necessary and lawful to do so.

9. Who might we share information with?

We will not sell your personal information.

Where necessary and lawful, information may be shared with:

• Parents or guardians where appropriate

• Schools and colleges

• Charities

• Social Prescribers

• Community organisations

• Professionals involved in providing or coordinating support

• Safeguarding services

• Local authorities or other statutory bodies where appropriate

• AQA or relevant awarding/assessment bodies where necessary for an AQA Unit Award

• Professional advisers

• Accountants or financial service providers

• IT, email, website or other service providers who process information on our behalf

• Regulators or authorities where we are legally required to do so.

We only share information that is relevant and necessary for the particular purpose.

10. Safeguarding information

Safeguarding is an important part of our work.

If we become concerned that a child or adult may be at risk of harm, we may need to share relevant information with appropriate safeguarding professionals or authorities.

This may happen without consent where there is a lawful basis for doing so.

We will aim to explain information sharing wherever it is safe and appropriate to do so.

11. Working with referral partners

If you are referred to Adaptive Pathways Learning CIC by a Social Prescriber, school, college, charity or another organisation, we may receive information from that organisation.

The information may include your contact details, reason for referral, goals and relevant support needs.

We will use this information to assess and provide appropriate support.

Where information has been received from another organisation, we will provide appropriate privacy information about the processing.

12. Children and young people

We may provide services to children and young people.

We recognise that children and young people may require privacy information that is clear and appropriate to their age and understanding.

Where appropriate, we may also communicate with parents, guardians, schools, colleges or other professionals involved in supporting the young person.

We will consider the individual's rights and best interests when handling their information.

Where consent or parental involvement is required for a particular activity, we will follow our relevant procedures.

13. How we keep information secure

We take reasonable and appropriate technical and organisational measures to protect personal information from:

• Unauthorised access

• Loss

• Misuse

• Alteration

• Unauthorised disclosure

• Accidental destruction.

Security measures may include:

• Password protection

• Appropriate access controls

• Secure digital storage

• Secure email and communication systems

• Device security

• Regular review of information-handling arrangements

• Staff or associate confidentiality requirements where applicable.

No method of transmitting or storing information is completely risk-free, but we take appropriate steps to reduce risks.

14. Where we store and process information

We use appropriate digital systems and service providers to manage our work.

Some service providers may process information on our behalf.

Where personal information is transferred outside the UK, we will ensure that the transfer is carried out in accordance with applicable data protection requirements and that appropriate safeguards are in place where required.

15. How long do we keep information?

We do not keep personal information for longer than is necessary for the purposes for which it was collected, unless we are required or permitted to keep it for longer.

Our retention periods depend on the type of information and why we hold it.

For example, different retention arrangements may apply to:

• Referral records

• Participant records

• Safeguarding records

• AQA Unit Award evidence

• Financial records

• Contracts and agreements

• Complaints

• Marketing information.

We maintain a separate retention schedule to determine appropriate retention periods and secure disposal arrangements.

Where a specific retention period applies, we will retain information for that period unless there is a lawful reason to retain it longer.

16. Secure disposal

When personal information is no longer required, we will securely delete, destroy or otherwise dispose of it in accordance with our retention arrangements.

17. Your data protection rights

Depending on the circumstances and the applicable legal requirements, you may have rights including:

• The right to be informed about how your information is used

• The right to access your personal information

• The right to have inaccurate information corrected

• The right to request erasure in certain circumstances

• The right to request restriction of processing in certain circumstances

• The right to object to certain processing

• The right to data portability in certain circumstances

• Rights relating to automated decision-making and profiling, where applicable

• The right to withdraw consent where consent is the lawful basis.

These rights are not absolute and may depend on the lawful basis and circumstances of the processing.

18. Making a data protection request

If you would like to exercise one of your rights, please contact:

Data Protection Officer
Adaptive Pathways Learning CIC
Email: rhi@adaptivepathwayslearning.co.uk

Please provide enough information for us to understand what you are requesting and, where necessary, to verify your identity.

We will respond within the applicable legal timeframe.

19. Marketing communications

We may use contact information for appropriate communications about our services where we have a lawful basis to do so.

Where consent is required for direct marketing, we will seek consent before sending relevant marketing communications.

You can unsubscribe from marketing communications at any time.

We will not sell or rent personal information to third parties for their marketing purposes.

20. Website forms and enquiries

If you contact us through our website, we may collect information such as:

• Your name

• Email address

• Telephone number

• Information contained in your message

• Information you choose to provide about the support you are looking for.

We use this information to respond to your enquiry and, where appropriate, provide information about our services.

Please do not send sensitive personal information through a general website contact form unless it is necessary and the form specifically requests it.

21. Cookies and website analytics

Our website may use cookies or similar technologies.

Cookies may be used to:

• Make the website function correctly

• Understand how visitors use the website

• Improve website performance

• Support website security.

Where non-essential cookies or analytics require consent, we will provide an appropriate mechanism for obtaining that consent.

Our website may also use third-party services that place or access cookies.

Further information about the cookies used on our website should be provided in our Cookie Notice.

22. Social media

Adaptive Pathways Learning CIC may maintain social media pages or profiles.

If you interact with us through social media, the relevant social media platform may process your personal information in accordance with its own privacy notice.

We may receive information about interactions with our social media content, depending on the platform and its settings.

We do not control how independent social media platforms process personal information.

23. AQA Unit Awards

Where an individual participates in an AQA Unit Award, we may need to process and share relevant information with AQA or other appropriate awarding/assessment bodies.

This may include information necessary to register, administer, evidence or certify completion of an award.

Only information necessary for the relevant award process will be shared.

24. Automated decision-making

Adaptive Pathways Learning CIC does not currently make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

If this changes, we will update this Privacy Notice and provide any information required by applicable data protection law.

25. Third-party websites

Our website may contain links to other websites.

Once you leave our website, the privacy practices of the other website will apply.

We recommend checking the privacy notice of any external website before providing personal information.

26. Complaints about how we use your information

If you have concerns about how Adaptive Pathways Learning CIC has handled your personal information, please contact us first so that we can investigate your concern.

Data Protection Officer
Adaptive Pathways Learning CIC
Email: rhi@adaptivepathwayslearning.co.uk

You also have the right to complain to the Information Commissioner's Office (ICO).

Information Commissioner's Office
Website: https://ico.org.uk/make-a-complaint/

The ICO is the UK's independent regulator for data protection and information rights.

27. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect:

• Changes to our services

• Changes to how we process information

• Changes to technology or systems

• Changes to data protection law or regulatory guidance.

The latest version will be published on our website.

Last reviewed: September 2026

Next review: September 2027

Contact us

If you have any questions about this Privacy Notice or how we handle personal information, please contact:

Adaptive Pathways Learning CIC

Data Protection Officer: Rhiannon Rigby
Email: rhi@adaptivepathwayslearning.co.uk
Website: https://www.adaptivepathwayslearning.co.uk/home

Adaptive Pathways Learning CIC
Supporting people to build their next pathway.