Modern Governor is an online training and support resource provided by HFL Education (HFL), under which it operates as an owned brand. Modern Governor is comprised of several component elements:
For the purposes of data protection laws, the Company is the controller of personal data collected on the Modern Governor service, including the LMS, app and public-facing web site at moderngovernor.com.
This document sets out the types of Personal Data (meaning information about an individual from which that individual can be personally identified) we handle, the purposes of handling those Personal Data and any recipients of it.
For the purposes of data protection laws, the Company is the data controller.
Please read this Policy carefully. By using moderngovernor.com and any services offered via this website, as well as all related websites and online services provided by HFL Education, you are agreeing to be bound by this Policy in respect of the information collected about you via this website and through other means.
We are Herts for Learning Limited trading as HFL Education
Address: Robertson House, Six Hills Way, Stevenage, SG1 2FQ
Information Commissioner’s Office Registration Number: ZA154308
Our Data Protection Officer is Lynette Dexter, Company Secretary
Email address for the Data Protection Officer: email@example.com
We collect and hold personal information relating to our users/customers, and in relation to any individuals included in data sets that are being processed by the Company under contractual agreements.
We may share Personal Data with other agencies, but only as necessary under our legal duties or otherwise in accordance with our duties/obligations as a Company.
The Personal Data we are provided with or collect is provided to us on a voluntary basis when users:
Set out below are the reasons we collect and process Personal Data:
We will only process your Personal Data information where we have consent, or we have another lawful reason for using it. These reasons include:
As a user of Modern Governor service, we may collect the following Personal Data about you (please note this list does not include every type of Personal Data and may be updated from time to time):
Information stored on the Modern Governor LMS will have been provided by either:
Any Personal Data collected by us will be treated as confidential under the principles of the relevant data protection law.
Personal Data will be accessible by:
We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will not share personal information with third parties without consent unless we are required to do so by law or our policies. We will disclose Personal Data to third parties:
This may include sharing data with the Police and other organisations where necessary.
The above listed third-party suppliers will process data on our behalf. Therefore, we audit these third-party suppliers to ensure their compliance with relevant data protection laws and specify their obligations in appropriate contracts and service level agreements.
Personal Data may be processed in a variety of ways; this will include but is not limited to:
Cookies are small files saved to the user’s device that track, save and store information about the user’s interactions and usage of the website. This allows the website to provide the users with a tailored experience within this website.
You may encounter a link to an external website page whilst viewing e-learning content on the Modern Governor LMS, within the glossary content of the Modern Governor app, or the public-facing site at moderngovernor.com. If the link is to a website that is operated by a third-party you should know that we have no control over that website, or its content, and as such cannot be responsible for the protection and privacy of your data or information you provide whilst visiting the site. You are advised to check the privacy policies of those other sites for their terms and conditions.
Our website – and the services it details and offers – is designed as general audience site not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without parental consent. If you are under 16 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Service from a child under 16 years of age without parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has obtained an account on the Service, then you may alert us at firstname.lastname@example.org and request that we delete that child’s Personal Information from our systems.
Your Personal Data is stored on systems based in the United Kingdom and all data backups are fully encrypted.
The Modern Governor LMS – provided by Learning Pool – has security measures in place to protect the loss, misuse and alteration of the information under our control. All instances of unauthorised attempted access to the Modern Governor LMS are logged and investigated. Where necessary, HFL Education will inform law enforcement agencies or other relevant organisations regarding misconduct. Learning Pool’s platform security statement – including its ISO 27001 certification – and list of sub processors are available.
We will only retain Personal Data for as long as is considered necessary to achieve the purposes for which it was originally collected.
Accounts on the Modern Governor LMS which have not been accessed in 12 months will be suspended by Learning Pool on behalf of HFL Education. In line with HFL Education’s data retention policy.
Any data collected via HubSpot will be deleted by HFL Education after 12 months in line with HFL Education’s Data Retention and Disposal Policy.
The General Data Protection Regulation and associated data protection law gives you rights in relation to Personal Data held about you. These are:
Where any exercise by you of your right to restriction determines that our processing of particular Personal Data is to be restricted, we will then only process the relevant Personal Data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
You can find out more about the way these rights work from the Information Commissioner’s Office (ICO) website.
If at any time you wish to close your Modern Governor LMS account and/or stop receiving information from us, you can:
You are entitled request details of Personal Data that we hold about you and you can access that Personal Data by making a Subject Access Request (SAR).
A SAR is a written or verbal request for personal information (known as personal data) held about you by an organisation. Data protection legislation gives individuals the right to know what information is held about them. However, this right is subject to certain exemptions as set out in the Data Protection Act 2018.
To submit a SAR to HFL Education we recommend that you email a written request to our Data Protection Officer at email@example.com. To help us respond quickly and effectively to your request, please include information regarding your relationship with us, along with a comprehensive list of what personal data you want to access and any details, relevant dates, or search criteria that will help us identify the information that you want.
If you are unhappy with the way we have dealt with any of your data protection concerns, you can make a complaint to the Information Commissioners Office (ICO), the supervisory authority for data protection issues in England and Wales. We would recommend that you complain to us in the first instance, but if you wish to contact the ICO you can do so using the details below. The ICO is a wholly independent regulator established in order to enforce data protection law.
ICO Concerns website: www.ico.org.uk/concerns
ICO Helpline: 0303 123 1113
ICO Postal Address:
Information Commissioner’s Office Wycliffe House
Water Lane Wilmslow Cheshire SK9 5AF