Privacy and Data Protection Policy
Trim Training Limited
Company Number: 14192835
VAT Number: 976201416
Website: https://www.trim-training.co.uk
Contact Email: support@trim-training.co.uk
Registered Office: Suite 2A, Blackthorn House, St Paul’s Square, Birmingham, B3 1RL
Last Updated: 13 July 2025
Next Scheduled Review: July 2026
1. Introduction
Trim Training Limited (“Trim Training”, “we”, “us”, “our”) is committed to protecting your privacy and ensuring that personal data is handled lawfully, securely, and transparently.
This Privacy and Data Protection Policy explains how we collect, use, store, share, and protect personal information in accordance with:
UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Privacy and Electronic Communications Regulations (PECR)
UK safeguarding legislation and statutory guidance (where applicable)
By using our website, purchasing our digital products, or accessing our learning services, you acknowledge that your personal data will be processed as described in this policy.
Trim Training provides online courses, eBooks, digital downloads, and assessments designed to support young people aged 11–18 and the professionals working with them.
2. Who We Are
Business Name: Trim Training Limited
Trading Name: Trim Training – “The Reliance in Me Training”
Company Number: 14192835
Incorporation Date: 23 June 2022
Registered Office: Suite 2A, Blackthorn House, St Paul’s Square, Birmingham, B3 1RL
Website: https://www.trim-training.co.uk
Email: support@trim-training.co.uk
Data Controller: Noel Wilson (Director)
Trim Training determines the purposes and means of processing personal data and is therefore the Data Controller under UK GDPR.
3. Data We Collect
3.1 Personal Identification Data
Full name
Email address
Contact number
Billing address
Organisation (where applicable)
3.2 Course and Learning Data
Account login credentials
Course enrolment records
Learning progress and completion data
Quiz and assessment results
Certificates issued
MindShift (CBT-based) exercise responses
Participation metrics (time spent, progress tracking)
3.3 Payment and Transaction Data
Payment confirmations
Order history
VAT receipts
Partial card details (last four digits only)
Full card details are never stored by Trim Training and are processed securely by Stripe or PayPal.
3.4 Technical and Analytics Data
IP address
Device type and operating system
Browser type
Pages visited and navigation behaviour
Referring websites
Collected through cookies and analytics tools such as Google Analytics, subject to consent.
3.5 Marketing Preferences
Email subscription choices
Communication preferences
Engagement data (email opens, link clicks)
Managed through HubSpot CRM.
3.6 Children’s Data (Ages 11–18)
Where learners are under 18:
Only data strictly necessary for learning delivery is collected
No unnecessary health or wellbeing data is requested
Additional safeguarding controls apply
Parental or organisational contact details may be required depending on context
3.7 Safeguarding Disclosures (Special Category Data)
If a safeguarding concern is disclosed, we may process:
Incident notes
Wellbeing or health-related information
Information shared with statutory authorities
This data is processed under UK GDPR Article 9(2)(c) (vital interests) and Article 9(2)(g) (substantial public interest – safeguarding).
4. How We Use Your Data
4.1 Deliver Learning Services
Provide access to courses and materials
Track progress and issue certificates
Provide learner and technical support
4.2 Process Payments and Orders
Process transactions
Issue receipts and VAT invoices
Maintain accounting records
4.3 Improve and Protect Services
Monitor website performance
Improve content and user experience
Prevent misuse, fraud, or security incidents
4.4 Marketing and Communications
Send newsletters and updates (with consent)
Inform users of new courses or service changes
4.5 Safeguarding
Protect children and vulnerable individuals
Respond to safeguarding concerns
Share information with relevant authorities when legally required
5. Lawful Bases for Processing (UK GDPR Article 6)
Trim Training processes personal data under the following lawful bases:
Article 6(1)(b) – Contract
To deliver purchased courses, learning materials, and certificates.Article 6(1)(c) – Legal obligation
For financial records, VAT compliance, safeguarding, and regulatory duties.Article 6(1)(f) – Legitimate interests
To manage operations, improve services, ensure platform security, and prevent misuse.Article 6(1)(a) – Consent
For marketing communications and non-essential cookies, where explicit consent is provided.
6. Special Category Data (UK GDPR Article 9)
We process special category data only where:
A safeguarding concern arises
A learner voluntarily discloses information requiring intervention
Lawful bases:
Article 9(2)(c): Vital interests
Article 9(2)(g): Substantial public interest (safeguarding)
Access to such data is restricted and confidential.
7. Data Sharing and Third Parties
We do not sell or rent personal data.
We may share limited data with trusted processors, including:
7.1 Core Service Providers
Stripe – payment processing
PayPal – payment processing
One.com / WebX – website hosting and email services
HubSpot CRM – contact management, marketing, analytics
Learning Management System (LMS) – course delivery
7.2 Professional and Legal Services
Accountants and auditors
Legal advisers
HMRC and statutory authorities (when required)
All third parties operate under Data Processing Agreements (DPAs) and UK GDPR obligations.
8. International Data Transfers
Some processors store data outside the UK (e.g. EU or USA).
We ensure appropriate safeguards through:
UK International Data Transfer Addendum (IDTA)
Standard Contractual Clauses (SCCs)
Additional contractual and technical safeguards
9. Cookies and Tracking Technologies
Our website uses:
Essential cookies – required for site functionality
Functional cookies – remember preferences
Analytics cookies – website performance analysis
Marketing cookies – communications and engagement tracking
Non-essential cookies and tracking tools (including HubSpot and Google Analytics) are disabled by default and are only activated after explicit user consent via our cookie banner, in accordance with PECR and UK GDPR.
Users can manage or withdraw consent at any time via the cookie banner or browser settings.
A separate Cookie Policy provides full details.
10. Data Security
We apply appropriate Technical and Organisational Measures (TOMs), including:
SSL encryption
Secure, encrypted servers
Access controls and role-based permissions
Multi-Factor Authentication (MFA)
Encrypted backups
Secure password policies
Staff training on safeguarding and data protection
Incident response procedures
11. Data Retention
We retain personal data only for as long as necessary, including:
Course and account data: up to 6 years after last activity
Financial and VAT records: 6 years (HMRC requirement)
Marketing data: until consent is withdrawn
Safeguarding records: retained in line with safeguarding and legal obligations
Data is securely deleted or anonymised when no longer required.
12. Your Rights Under UK GDPR
You have the right to:
Access your personal data
Rectify inaccurate data
Request erasure (where applicable)
Restrict processing
Object to processing
Withdraw consent at any time
Data portability
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
https://www.ico.org.uk
To exercise your rights, contact: support@trim-training.co.uk
13. Automated Decision-Making
Trim Training does not use automated decision-making that produces legal or similarly significant effects.
Learning quizzes and assessments do not constitute automated decision-making.
14. Changes to This Policy
This policy will be:
Reviewed annually
Updated as required
Published on our website
Where significant changes occur, users will be notified where appropriate.
15. Contact Information
For privacy or data protection enquiries:
Trim Training Limited
Email: support@trim-training.co.uk
Website: https://www.trim-training.co.uk
Address: Suite 2A, Blackthorn House, St Paul’s Square, Birmingham, B3 1RL
Signed:
Noel Wilson
Director, Trim Training Limited
Date: 13 July 2025
Privacy and Data Protection Pol…