1. Who we are and what we do

Who we are

We are Firebrand Training Limited (“Firebrand”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 04097204, and we have our registered office at 27 Old Gloucester Street, London, England, WC1N 3AX. We operate as a wholly separate business but are part of the BPP Professional Education Group. We are registered with the UK supervisory authority, the Information Commission (“IC”), under registration reference Z8811790.

What we do

We are in the business of providing online courses and education programmes to adult learners. In addition to our presence in the UK, we are also the parent of companies in European countries such as Germany, the Netherlands and Denmark. We and our related entities are committed to protecting the privacy and security of the Personal Data we process about you.

Controller

Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

2. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions or you wish to make a complaint, you can contact us using the information provided below under the ‘How to contact us’ section.

3. Who this privacy notice applies to

This privacy notice applies to you if:

1. 1. You visit any Firebrand website, including any subdomains that may be made available by us from time to time, and all Firebrand social media channels (“Website(s)”).

2. 2. You purchase/supply goods or services from/to us

3. 3. You enquire about our products and/or services

4. 4. You receive promotional communications from us

4. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation. 

5. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes and lawful bases’.

6. How we collect your Personal Data

We collect most of the Personal Data directly from you in person, through our website or by corresponding with us by post, phone or email, when you enquire after or purchase goods/services from us, and through the course of your studies. Purposes and lawful bases.

We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our goods or services without the required information (for example, to enrol you onto a relevant course or programme). In this case, we may have to withdraw your application or cancel/restrict a product or service you have with us, but we will notify you if this is the case at the time.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our Retention Notice which you can request by contacting us.

As an education provider Firebrand will hold details of your transcript (i.e. your name, years of study, course or programme name, sponsoring employer, assessment and/or exam marks and final grade or award) indefinitely.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Where a supplier processes your personal data on our behalf, we have put in place contracts with robust data protection provisions.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites or apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

9. Sharing your Personal Data

 We may share your Personal Data with our carefully selected third parties, including:

Internal Third Parties

●      Other companies in the Firebrand Group acting as joint controllers or processors and who are based in and outside the UK and provide administration services and undertake leadership reporting.

External Third Parties 

●      Your employer/prospective employer, where they are sponsoring your place on a course or programme (or where your employer/prospective employer has arranged for a course or programme to be delivered to a group of its employees/prospective employees). We will share information relating to your attendance, performance (including exam/assessment results and mock exam/assessment results and if applicable, recordings of coaching and performance calls) and general behaviour/performance on the course/programme.

●      Any other education provider/employer where Firebrand is the subcontractor for any element of the teaching of your course or programme. We will share information relating to your performance (including mock and actual assessment results), progress and attendance on the course/programme.

●      Any freelance tutor, external presenter or third-party platform engaged by Firebrand to deliver teaching/training to you as part of your course or programme.

●      Any other tuition provider/reseller where Firebrand provides training services to you through your contract with that third-party training provider or reseller. We will share information relating to your performance (including mock and actual assessment results), progress and attendance on the course/programme.

●      Overseas agents, engaged by Firebrand who assist overseas students in submitting applications for courses or programmes to Firebrand.

●      Any third party which Firebrand collaborates with for the purpose of creating, and/or marketing, and/or delivering tailored programmes or courses.

●      Service providers who provide IT and system administration services, including our telephone call recording operations, security services (such as CCTV)

●      Any third-party survey/review organisation or portal provider, such as Metrics that Matter, Microsoft 365, SurveyMonkey, Evasys, Qualtrics, Eventbrite and TrustPilot.

●      Any third-party portals which are used to provide you with student services.

●      Third party platforms providing education and learning materials (including Pluralsight).

●      Third party apprenticeship/traineeship recruiters (including Get My First Job, LinkedIn, Job Train, the Princes Trust, Career Connect and Talent Match)

●      Advertising networks and search information providers (such as Companies House or LinkedIn).

●      Providers of technical, payment and delivery/courier services (e.g., where you order hard copy study materials) such as PayPal.

●      External venues where some elements of a course or programme (including assessments), or an event, are delivered (Firebrand may share Identity Data with the venue for registration and health and safety purposes).

●      Any third party assessment/examination centre, online exam provider (e.g., Pearson VUE, BCS or PSI Testing Solutions), external exam marker or invigilator (for example where you request to sit a Firebrand exam abroad, or your course or programme requires an external assessment organisation to provide your final examination/assessment, including end point assessment organisations for apprenticeships); or any organisations which review assessment submissions for plagiarism such as Turnitin.

●      Any external awarding bodies or professional membership bodies which you may be registered with to enroll onto or complete the course or programme you are studying with Firebrand (including, ICAEW, IAPP etc.)

●      Counselling services, where you make a specific request via the Student Advice Team (Firebrand may share Identity and Contact Data).

●      Recruitment services, where you make a specific request–for example Firebrand passing contact details to getmyfirstjob or another similar job site. They then become the controller of your personal data for the purposes stated in their privacy notice.

●      Future employers or education providers where you specifically request that we provide confirmation of Identity or Student Data to those parties for reference purposes.

●      Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

●      Debt recovery agents with whom we may share your data when you owe a debt to Firebrand.

●      Regulators and other authorities (such as HMRC in the UK) who require reporting of processing activities in certain circumstances.

●      Specific regulators in the field of education. In the UK, it includes the Department of Education ("DfE"), the ESFA and the Education and Skills Funding Agency (for apprenticeships and traineeships), The Federation for Industry Sector Skills and Standards (for apprenticeships), Ofsted, The Office for Students, The Quality Assurance Agency, or any successor organisations who require reporting of certain processing activities.

●      For Apprentices, your information may be shared by the DfE with third parties for education, training, employment and well-being related purposes, including for research. We share your information only if have a legal obligation to do so (e.g. where instructed by the DfE).

●      For Apprentices, The European Social Fund English Managing Authority (the Department for Work and Pensions, also known as DWP), or agents acting on its behalf, may contact you to carry out research and evaluation to inform the effectiveness of training that you receive through your apprenticeship.

●      Firebrand Websites may include links to third-party websites, plug-ins and applications. Clicking on those links, or enabling those connections, may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies.

We may also disclose your personal information in the following circumstances, on the basis that we have a legal obligation or a legitimate interest in doing so:

●      If we are under a duty to disclose or share it in order to comply with any legal obligation (for example, with funding authorities, our auditors, our insurers and HMRC).

●      If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets.

●      If we or substantially all of our assets are acquired by a third party, personal information we hold about you will be one of the transferred assets.

●      The police or governmental body, where the police/ governmental body make a request for personal information (including recordings from audio visual systems and/or CCTV) or as and when we consider necessary for the purpose of crime / fraud prevention.

●      The ambulance service if there is any immediate concern regarding your physical health or mental wellbeing.

●      Your parent, next of kin or emergency contact if there any immediate concerns regarding your physical health/safety or mental wellbeing.

We may use and, where necessary, share your personal data with our group companies and their service to investigate and address reports of fraud, misconduct or other unlawful or unethical behaviour, and to comply with applicable anti-bribery, anti-corruption, anti-money laundering and related laws, ensuring that access is limited, secure and, where reasonably possible, anonymised.

10. International Transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK or the European Economic Area (“EEA”).

We have taken appropriate steps to ensure that the Personal Data processed outside the UK/EEA has an essentially equivalent level of protection to that guaranteed in the UK/EEA. We do this by ensuring that:

●      Your Personal Data is only processed in a country which the Secretary of State or the European Commission has confirmed has an adequate level of protection (an adequacy regulation), or

●      We enter into Standard Contractual Clauses (“SCCs”) or International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary (a copy of the SCCs can be found here Standard Contractual Clauses  and a copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk), or

●      When transferring your Personal Data to America, we may rely on the DPF Framework, where appropriate.

11. Marketing Communications

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

You can opt out of receiving marketing at any time by replying to the sender of the marketing communication with the word “UNSUBSCRIBE” or simply by following the opt out link included in each mail. If you change your mind later, you can contact us and update your marketing preferences. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us when entering a contract with us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Firebrand group of companies for marketing purposes.

12. Automated Decision-Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making, unless we have a lawful basis for doing so and we have notified you.

We do use automated technologies and decision-making when deciding what marketing messages you receive. We do not envisage that any other decisions will be taken about you using automated means, however, we will update this Notice if this position changes.

13. Bots

We also use “bots” to automate some of Firebrand’s administrative services. Bots are computer programmes that attempt to mimic human behaviours and allow them to carry out repetitive tasks without specific instructions. They may be used to collect information for student registration or onboarding (or other administrative tasks).

The personal data collected by these bots is processed in accordance with this privacy notice and is processed in the same way as if it had been collected by a member of Firebrand staff.

14. Online Learning and Assessment

Firebrand conducts online learning across all courses and programmes as well as carrying out online assessments.

Firebrand uses a suite of platforms and software to provide students with online learning and assessment services. The most notable of these is Microsoft Teams.

Students should be aware that, whilst taking part in online learning sessions your tutor and other students in the session will be able to see you (if you enable video), hear you (if you enable your microphone) and see any text that you have typed into the chat box.

Although it is optional to have these features enabled, some tutors may request that these are enabled to improve the experience of all students (to make it more like traditional classroom learning); or to ensure you are able and actively participating in the session (including any group work).

You should also be aware that online sessions may be recorded and shared as a revision aid or used by Firebrand for training and monitoring purposes, including (where applicable) with specific regulators in the field of education as part of their monitoring/audit functions.

Online Assessments

Students should be aware that some online assessment platforms include remote proctoring (you will be made aware in advance where your exam will be proctored remotely and provided with further information and instructions for use).

This means that you will be filmed (video and audio) for the duration of your exam and will be required to provide a video of your surroundings at the start of the exam. Therefore, please ensure you remove anything from view that you would not want recorded (such as personal photographs, documents or other members of your household).

You will be asked to show a form of photographic ID at the start of the online exam (this may also include end point assessments where you are an apprentice). Where you have a Firebrand student ID you must use this as your ID document. If you do not have a Firebrand ID you may use a passport, driver’s licence or other national ID card (which has a photograph).  Please be aware that any information contained in your form of ID will be captured so may include data such as your nationality and if applicable, biometric data.

Recordings of your exam may be used in formal procedures (such as any allegation of academic misconduct, mitigating circumstance applications, academic appeals or formal complaints).

Your exam answers will be processed in the same way as hard copy exam scripts would be.

15. Your rights

Subject to certain exemptions, you have certain rights in relation to the processing of your Personal Data, including to:

·            Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

·            Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

·            Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

·            Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

·            Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

·            Right to restrict processing

You have the right to restrict our use of your Personal Data.

·            Right to portability

You have the right to ask us to transfer your Personal Data to another party.

·            Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making. 

·            Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.  

16. Complaints

If you have a concern about how we collect, use, or store your personal data, you have the right to make a complaint. We take all complaints seriously and are committed to resolving them in a fair, transparent, and timely manner. Our complaints process is designed to meet our obligations under the Data (Use and Access) Act 2025, which strengthens individuals' rights in relation to how their personal data is handled and provides clearer mechanisms for raising concerns.

You can find full details of how to submit a complaint, the steps we will take to investigate it, and the timescales you can expect in our Complaints Policy: https://www.bpp.com/data-protection-complaints.  If you are not satisfied with the outcome of your complaint, you can complain with the relevant supervisory authority. The supervisory authority in the UK is the Information Commission who can be contacted online at:

Contact us | ICO

Or by telephone on 0303 123 1113

For supervisory authorities in other countries within the EU see the link below:

https://edpb.europa.eu/about-edpb/about-edpb/members_en

17. How to contact us and our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

We have also appointed Data protection Officers (“DPO”). Our DPO in the UK can be contacted at:

Firebrand Training Limited

27 Old Gloucester Street London England WC1N 3AX

Email: privacy@firebrand.training

Our Europe DPO is Evalian and can be contacted as follows:

West Lodge, Leylands Business Park, Colden Common, Hampshire, SO21 1TH

dpo@evalian.co.uk

18. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 17^th June 2026