HFL Hub

Privacy Policy

HFL Hub is an online CPD resource, managed by HFL Education and hosted by Thinkific Labs Inc. 

This Privacy Policy demonstrates HFL Education’s (HFL’s) firm commitment to data protection. This statement (together with the Terms and Conditions for training courses) sets out the ways that HFL ('the Company, 'we', 'us' or 'our') gathers and disseminates information from the HFL Hub and what you can do if you have questions about Personal Data.

For the purposes of data protection laws, the Company is the controller of personal data collected by us on the HFL Hub.

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.

We are committed to ensuring that the privacy and security of your personal information is protected at all times. Any personal information that you provide to us on the HFL Hub will be handled in accordance with this Privacy Policy.

1. Our details

We are: Herts for Learning Ltd trading as HFL Education

Address: Bank House, Ground Floor – North Wing, Primett Road, Stevenage, Herts, SG1 3EE

Information Commissioner's Office Registration Number: ZA154308

Our Data Protection Officer is: Lynette Dexter, Company Secretary

Email address for the Data Protection Officer: [email protected]

2. Why we collect Personal Data

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 collect from the HFL Hub is provided to us on a voluntary basis when users register on this platform.

Set out below are the reasons we collect and process Personal Data, as well as the legal basis on which we carry out this processing:

• to deliver a CPD service to you
• to manage user accounts / establishment accounts
• to manage course enrolments and event bookings
• to manage course alerts
• to manage our relationship with you
• for research and evaluation purposes

3. Legal basis for processing 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 where we:

• need to pursue our legitimate interests
• need to process the information to carry out a contractual agreement we have with you

4. Categories of Personal Data we collect about you

As a user of the HFL Hub, 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):

• your name;
• your telephone / mobile number;
• your email address;
• your home address for individual users / work address for users joined to an Establishment.

This information will be collected from you at the time that you register on the HFL Hub. Contact information is used to respond to enquiries or get in touch with you when necessary.

Any Personal Data collected by us will be treated as confidential under the principles of the relevant data protection law.

5. Who will have access to your Personal Data

Personal Data will be accessible by:

• members of HFL Education’s event team
• establishment Account Administrators, who can access all user accounts for their Establishment
• Thinkific, the hosts of the HFL Hub

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:

• if we are under a duty to disclose or share your Personal Data to comply with any legal obligation
• to enforce any agreements with you
• to perform contracts whereby we have been commissioned to deliver events on behalf of a third party (i.e. a school, setting or Local Authority)
• to perform contracts with third parties including:
  • webinar Platforms (e.g. Microsoft Teams, Livestorm or Accelevents)
  • external trainers and keynote speakers, for the events that you are attending as a delegate
  • hotels where overnight accommodation is required for the event
  • research partners (e.g. King’s College London, Verian Group, Education Endowment Foundation)
• to protect the rights, property or safety of the Company. 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 written contracts.

6.  Links to other websites

You may encounter a link to an external website page whilst visiting the HFL Hub. 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.

7. How Personal Data will be processed

Personal Data may be processed in a variety of ways; this will include but is not limited to:

• maintaining electronic records
• event administration documents (e.g. delegate attendance lists, evaluations, etc.)
• sending of emails relating to event booking or course enrolment
• general account administration
• research and evaluation purposes
• invoicing purposes

We also use this information for the marketing our training and events, where the necessary consent has been given.

Your Personal Data is stored on a secure cloud-based platform owned by Thinkific Labs Inc, a Canadian company. Your learning account and course activity are hosted within the Thinkific platform, which uses Amazon Web Services (AWS) infrastructure located in the United States. Thinkific acts as our data processor, and AWS acts as a sub‑processor. Both provide secure, industry‑standard cloud hosting services.

8. International Transfers

Your data is stored in the United States, it is transferred outside the UK. These transfers are protected by the safeguards required under the UK GDPR. Thinkific has appropriate transfer mechanisms in place to ensure that your rights and protections travel with your data. Further information is available upon request.

HFL Hub 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 HFL Hub are logged and investigated. Where necessary, HFL Education will inform law enforcement agencies or other relevant organisations regarding misconduct.

For more information please visit: https://www.thinkific.com/privacy-policy/

9. Retention periods

We only retain personal data for as long as necessary for the purposes outlined above and in line with our organisational retention schedule. This includes fulfilling financial and audit obligations and managing course records. Data that is no longer needed will be securely deleted or anonymised.

10. Your Data rights

The General Data Protection Regulation and associated data protection law gives you rights in relation to Personal Data held about you. These are:

Right to be informed: you have the right to be informed about the collection and use of your data. This policy contains information in relation to the collection of your Personal Data, however, if we collect additional data for other purposes, we will inform you about this.

Right of Access: if your Personal Data is held by us, you are entitled to access your Personal Data (unless an exception applies) by submitting a written request. We will aim to respond to that request within one month. If responding to your request will take longer than a month, or we consider that an exception applies, then we will let you know. You are entitled to access the Personal Data described in Section 4.

Right of Rectification: you have the right to require us to rectify any inaccurate Personal Data we hold about you. You also have the right to have incomplete Personal Data we hold about you completed. If you have any concerns about the accuracy of Personal Data that we hold then please contact us.

Right to Restriction: you have the right to restrict the manner in which we can process Personal Data where:

• the accuracy of the Personal Data is being contested by you;
• the processing of your Personal Data is unlawful, but you do not want the relevant Personal Data to be erased; or
• we no longer need to process your Personal Data for the agreed purposes, but you want to preserve your Personal Data for the establishment, exercise or defence of legal claims.

Where any exercise by you of your right to restriction determines that our processing of particular Personal Data are 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.

Right to Erasure: you have the right to require we erase your Personal Data which we are processing where one of the following grounds applies:

• the processing is no longer necessary in relation to the purposes for which your Personal Data were collected or otherwise processed;
• our processing of your Personal Data is based on your consent, you have subsequently withdrawn that consent and there is no other legal ground we can use to process your Personal Data;
• the Personal Data have been unlawfully processed; and
• the erasure is required for compliance with a law to which we are subject.

Right to Data Portability: you have the right to receive your Personal Data in a format that can be transferred. We will normally supply Personal Data in the form of e-mails or other mainstream software files. If you want to receive your Personal Data which you have provided to us in a structured, commonly used and machine-readable format, please contact us via the details in this Notice.

Right to Object: you have the right to object to the processing of your Personal Data where one of the following grounds apply:

• the processing is based on legitimate interests or the performance of a task in the public interest;
• the processing is for direct marketing; or
• the processing is for the purposes of scientific/ historical research and statistics.

You can find out more about the way these rights work from the Information Commissioner's Office (ICO) website.

11. Controlling your personal information

If at any time you wish to close your HFL Hub account and/or stop receiving information/course alerts from us, you can:

• send an email to [email protected] identifying yourself and asking that we close your account
• you can turn off course alerts from your own user account

12. Subject access request (requesting your Personal Data)

You are entitled to 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 protected]. 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.

13. Making a complaint

Under the Data Use and Access Act 2025 (DUAA), you have the right to raise a complaint if you believe your personal data has been mishandled or your data protection rights have been infringed.

If you wish to raise a concern about how HFL Education has handled your personal data, please contact us directly in the first instance. You can submit a complaint using our online Complaints Form or by contacting us via email at [email protected]. Your complaint will be managed in line with the HFL Complaints Policy and we will aim to resolve the complaint within 20 working days of receipt.

 We will:

•              Review the details of your complaint.

•              Keep you informed of progress.

•              Provide a clear outcome once the investigation is complete.

If you are not satisfied with our response, you may escalate your complaint to the Information Commission’s Office, the UK’s independent regulator for data protection:

ICO website:       www.ico.org.uk/make-a-complaint/

ICO Helpline:     0303 123 1113 

14. Changes to this Privacy Policy

Any changes we make to this notice in the future will be posted on the HFL Hub and, where appropriate, notified to you by e-mail. Please check back to see any updates or changes.

This Privacy Policy was last updated March 2026.

Cookies

How cookies are used by HFL Education.

When we provide services, we want to make them easy, useful and reliable.

Where services are delivered on the internet, this sometimes involves placing small amounts of information on your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

This information is used to improve services. For example:

• recognising your computer so you don't have to give the same information several times
• recognising that you may already have given a username and password so you don't need to do it for every web page requested
• measuring how many people are using our website, so they can be made easier to use

You can learn more about cookies on the aboutcookies.co.uk website, including how to manage them in your browser privacy settings.

We use cookies to control the site’s functions, to keep statistics and for session management. We do not store any personal information in cookies.

If you do not want to accept cookies, your browser can be set to automatically reject cookies or to inform you every time a website asks to store a cookie.

Through the browser you can also delete previously stored cookies. Our site will not function satisfactorily without the acceptance of cookies.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Details of Cookies used on HFL Hub can be found here:  https://www.hfleducation.org/privacy-notice-incl-cookies

Herts for Learning Ltd trading as HFL Education,
Bank House
Ground Floor – North Wing
Primett Road
Stevenage
Hertfordshire
SG1 3EE

Tel: 01438 544464

Registered in England and Wales
Company number 8419581
VAT number GB164460021