Privacy Notice

1. Introduction

This Privacy Notice explains in detail the types of personal data we collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how APM uses your data.

2. Who we are

When we say “we”, we are referring to Serendipity (WA) Pty Ltd, trading as Advanced Personnel Management (APM) and its related companies in the United Kingdom.

3. What is the legal basis for collecting your data?

The law on data protection sets out a number of different reasons for which businesses may collect and process your personal data:

3.1 To meet contractual obligations

We are required by commissioners, government agencies and other training providers that fund our services to collect your personal data. These include:

  • Education and Skills Funding Agency – apprenticeships, classroom based courses, Nu-futures, Study Programme
  • Ministry of Justice – HMPPS CFO3
  • National Citizenship Service Trust – National Citizen Service
  • Department for Work and Pensions – Employment support programmes


3.2 To meet legal obligations

In certain circumstances we are required to pass on details of people who are involved in certain kinds of illegal or criminal activity to law enforcement. This includes disclosure under the requirements of Prevent and Safeguarding legislation.

3.3 Legitimate interest

We require your data to allow us to run our business effectively and allow us to provide quality services to you. For example:

  • We will use your personal data to stay in contact with you whilst you are participating in our programmes.
  • We will use your personal data to check on your previous qualifications prior to you starting a government funded training course such as an apprenticeship.
  • We will use your personal data to register you with a qualification awarding organisation
  • We will use your personal data to track your progress through your programme.

For employees: we collect your data to ensure you have the appropriate skills and qualifications to do the job. We also have responsibilities to ensure you have right to work in the UK and that you can work with people covered under safeguarding regulations.

4. When do we collect your personal data?

We collect the majority of the personal data we require prior to you commencing a programme with this. This is usually via one of the following:

  • Enrolment form
  • Referral form
  • Interview record
  • Individual learning plan
  • Provider Referral and Payments record (PraP)

We may also collect further personal data to help us to provide effective services to you through the programme.

For employees: we collect your data as part of the recruitment process. We ask you to update this data through the MyView portal.

5. What sort of data do we collect?

We only collect as much data as we need to:

1. Meet the requirements of the commissioner or agency who are funding the programme we are providing to you, and/or

2. Allow us to provide our services effectively.

Data we collect includes your:

  • Name
  • Date of Birth
  • Nationality
  • Gender
  • Ethnicity
  • National Insurance Number
  • Contact details including address; email; telephone number
  • Next of Kin details
  • Employment history
  • Health Status
  • Learning difficulty, disability

For employees: we additionally collect bank account and qualification details.

6. How and why we use data?

We submit your data to commissioners or funding agencies. This submission releases funds to us that allow us to provide services to you. The data is transferred via online systems or portals.

We use your data to help us provide services to you. We use to track and report on your progress with us. We also use it to help us with quality improvement processes such as surveys.

We also share your personal data with third parties that we engage with to provide services to you. For example, to register you with an awarding organisation which allows us to award you with a qualification on successful completion of your programme.

For employees: we collect your data in order to pay your salary and provide employee benefits such as healthcare and pensions. We also use your personal data to undertake pre-employment checks such as disclosure and barring.

7. How we use data for marketing purposes?
We provide a range of services and sometimes we believe these may be of interest to you. We will send your details of these services only if you have opted into receiving marketing emails, letters or phone calls.

For Employees: certain third party providers may use your data to share opportunities or services that maybe of interest.

8. How can you stop marketing communications

There are a number of ways you can stop direct marketing communications from us:

1. Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division

2. Contact our Data Protection Officer, APM, Unit 35 -40 Newtown Shopping Centre, Birmingham B19 2SS, or email

For employees: To unsubscribe directly with third party services, please review the relevant provider’s privacy notice.

9. How we protect your data?

Paper based data is kept in locked rooms/filing cabinets where only authorised people have access.

Electronic data is stored on encrypted systems where appropriate/required. These are password protected and access is restricted.

All staff are trained in data protection principles. This is refreshed annually.

10. Who do we share your data with?

We submit your data to commissioners or funding agencies such as the Education and Skills Funding Agency; National Citizen Service Trust; Department for Work and Pensions; awarding organisations such as City and Guilds, BIIAB, CACHE.

For employees: we share your data with a payroll and pensions providers. We also share your data with other organisations that provide employee benefits.

11. Where will your data be processed?

Data will be processed within the United Kingdom.

Certain tools we use for surveys and marketing are hosted outside the EEA but on sites that are GDPR (General Data Protection Regulation) compliant through Privacy Shield and TRUSTe.

12. What are your rights to access your data?

You have the right to request:

  • Access to the personal data we hold about you, free of charge in most cases.
  • The correction of your personal data when incorrect, out of date or incomplete.
  • That we stop using your personal data for direct marketing (either through specific channels, or all channels).
  • That we stop any consent-based processing of your personal data after you withdraw that consent.
  • To be forgotten, where we delete all data we hold about you (unless we are contractually obliged to retain that data for a specified period of time by the commissioner or funding agency).

To ask for your information, please contact:

Data Protection Officer, APM, Unit 35-40 Newtown Shopping Centre, Birmingham, B19 2SS

or email

or complete the Personal Data Access Request form.

To request deletion of the personal data we hold about you, complete the Personal Data Deletion Request form.

13. How long will we keep your data for?

Commissioner/Funding Body

Programme Type

Retention Period



AEB (non-match funded)

7 years after completion of the programme

ESF 2007–2013 programmes

Work Programme:






Up to 31st December 2022

ESF 2014–2020 programmes



Up to 31st December 2030

Central London Forward

Major and Commonality and citizens of city of London

Working Capital

6 years after termination date of contract



6 years after termination date of contract



6 years after termination date of contract

DWP Contracts

Work and Health Programme




South East

31st December 2026

NCS Trust

National Citizen Service

7 years after the last contracted payment

Ministry of Justice


12 years after the final payment of all sums due under the contract


14. Who can you question about this notice or how we use your data?

You can contact our Data Protection Officer at APM, 5th Floor, 18 Mansell Street, London, E1 8AA or

15. Who can I contact if I feel that my data is being handled incorrectly?

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or go online to


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