1.1 Effective date

This Privacy Notice was last updated on 3 September 2026.

We may notify existing registered learners about material changes to this Privacy Notice by email or through the Service.

2. Personal information we collect

Depending on how you use Care Learning, we may collect:

• your name, email address, username and any optional profile information you provide;
• your organisation name and, where relevant, its website or email domain;
• information you provide about your sector, organisation type, role, employment, volunteering, apprenticeship, study or placement relationship;
• information about the purpose for which you intend to use Care Learning;
• answers to eligibility questions and eligibility declarations;
• course enrolments, lesson and quiz activity, scores, completion dates, timestamps and certificates;
• forum posts, comments, support requests and correspondence;
• assignments, photographs, files or other material that you choose to upload;
• transaction and refund records if you purchase paid content;
• your IP address, browser type, device information and security or access logs;
• cookie preferences and information collected through permitted analytics technologies; and
• mailing-list details, including your name where provided and email address.

Where a third-party payment processor handles a transaction, Care Learning does not store your full payment-card details.

We do not ask you to provide protected characteristics or special-category personal information for the purpose of deciding whether you meet our learner eligibility requirements.

2.1 Account-reminder information

To administer inactive learner accounts, we may also process:

• your account registration date;
• the most recent successful sign-in recorded by our systems;
• the most recent relevant LearnDash learning activity;
• a limited factual summary of courses started or completed;
• account-reminder dates and status;
• transactional email delivery or bounce information; and
• administrative holds and manual review decisions.

WordPress does not provide a complete historical record of every sign-in. For older accounts, we may use the registration date, available sign-in information and relevant LearnDash activity.

2.2 Eligibility and account-review information

Where it is necessary to establish or review eligibility, we may process limited information such as:

• organisation name;
• organisation type or sector;
• organisation website or email domain;
• your relationship with the organisation;
• the purpose for which you are using or intend to use Care Learning;
• eligibility declarations or information supplied in response to an eligibility query;
• screening indicators or rules that caused an account to be referred for review;
• whether an organisation or domain has previously been reviewed;
• factual information obtained during a manual eligibility review;
• correspondence concerning eligibility;
• the outcome and reason for an eligibility decision; and
• limited administrative records showing when and by whom a review was completed.

A screening indicator does not necessarily mean that a person or organisation is ineligible or has acted improperly.

We aim to keep eligibility records factual, relevant and limited to what is reasonably necessary to administer the Service.

3. How we obtain personal information

We obtain personal information:

• directly from you when you register, enrol, complete an eligibility declaration, respond to an eligibility enquiry, make a purchase, contact us, join a mailing list or submit material;
• automatically from your use of the Service, including course activity and technical access data;
• from information associated with the email address or domain used to register;
• from authorised providers that support payment, hosting, security, communication or course administration; and
• where reasonably necessary to verify eligibility, from publicly available sources such as an organisation’s own website or an appropriate official public register.

We do not routinely carry out extensive background checks on individual learners.

Where we obtain personal information from a publicly available source, we use it only where this is reasonably necessary for a relevant purpose described in this Notice.

4. Why we use personal information

We may use personal information to:

• create and administer learner accounts;
• assess and administer eligibility for learner accounts;
• identify registrations or accounts that may require an eligibility review;
• verify information supplied in connection with an eligibility review;
• apply and enforce the eligibility requirements and other access rules;
• provide courses and record progress, assessments and completion;
• issue and verify certificates;
• process payments, refunds and transaction records;
• provide support and respond to questions, reviews, complaints or claims;
• send course administration and service messages;
• protect accounts, prevent fraud, enforce access rules and investigate misuse;
• prevent unauthorised commercial, competitive or systematic use of the Service or its content;
• operate, secure, analyse and improve the website and learning platform;
• maintain appropriate legal, financial, security and audit records;
• manage user submissions and course forums; and
• send marketing or content updates where permitted.

4.1 Inactive-account administration

We use the information described in section 2.1 to:

• identify learner accounts with no recorded sign-in or relevant learning activity for 12 calendar months;
• send fair notice before an account becomes eligible for deletion review;
• stop further reminders when the learner returns;
• investigate incorrect or failed email delivery;
• prevent inappropriate or accidental account deletion;
• maintain a limited audit record of reminders and administrative decisions; and
• reduce the amount of personal information held when an account is no longer required.

We do not use the inactive-account process to profile learners for advertising or select learners for marketing.

4.2 Eligibility administration

We use the information described in section 2.2 to administer the eligibility requirements set out in the Terms and Conditions.

This may include:

• assessing whether a registration appears to fall within the intended audience for Care Learning;
• identifying registrations that require an additional eligibility declaration;
• referring an account for manual review where eligibility is unclear;
• distinguishing eligible direct-service organisations from organisations or uses that fall outside the eligibility requirements;
• preventing repeated registration for a restricted purpose;
• investigating a possible misrepresentation of eligibility;
• reviewing an eligibility decision where the account holder provides further information; and
• maintaining a limited record of decisions so that similar registrations can be handled consistently.

Eligibility screening is not used to make decisions based on protected characteristics.

We do not use eligibility information to profile learners for advertising or marketing.

5. Lawful bases

Depending on the purpose, Care Learning may rely on:

• contract, where processing is necessary to create or administer an account, provide an enrolled or purchased service, apply the Terms and Conditions, process a payment or provide requested support;
• legitimate interests, where processing is necessary to operate and secure the Service, administer learner eligibility, prevent misuse or unauthorised commercial use, protect Care Learning content, maintain appropriate records, understand service performance or respond to a complaint or claim, provided those interests are not overridden by your rights;
• consent, where you choose to receive marketing or where consent is required for a cookie or similar technology; and
• legal obligation, where information must be used, disclosed or retained to comply with applicable law.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not make earlier processing unlawful. It also does not require us to delete information that we must or are otherwise lawfully permitted to retain on another basis.

5.1 Lawful basis for inactive-account administration

We rely on legitimate interests when we process personal information for inactive-account administration.

Our legitimate interests are to:

• keep learner and account records accurate;
• avoid retaining personal information that is no longer needed;
• reduce the security risk associated with dormant accounts;
• give learners fair notice and an opportunity to keep or close their account; and
• maintain a limited record of reminders and administrative decisions.

We limit the information used to what is reasonably necessary for these purposes. Your right to object to processing based on legitimate interests is explained in section 14.1.

5.2 Lawful basis for eligibility administration

We generally rely on legitimate interests when we process personal information to assess, verify or review learner eligibility and to prevent the Service from being used for restricted purposes.

Our legitimate interests include:

• operating Care Learning as a targeted free learning service for its intended audience;
• managing the resources and costs involved in providing free learning;
• preventing misuse of learner accounts;
• protecting Care Learning content and intellectual property;
• preventing unauthorised commercial exploitation, systematic analysis, redistribution or competitor use;
• applying our eligibility requirements consistently; and
• maintaining limited records so that eligibility decisions can be reviewed and explained.

Some processing may also be necessary to administer the contractual relationship created when a learner accepts the Terms and Conditions and uses the Service.

We seek to use only information that is reasonably necessary for these purposes. A screening indicator will not necessarily determine eligibility by itself, and manual review is available where eligibility is unclear.

We do not use protected characteristics or special-category personal information to determine learner eligibility.

Your right to object to processing based on legitimate interests is explained in section 14.1.

6.5 Eligibility-review records

Information used in an active eligibility review will be kept while the review is in progress and for a reasonable period afterwards where this is necessary to administer the decision, respond to a challenge or complaint, prevent repeated misuse or establish, exercise or defend legal rights.

Limited identifiable eligibility-review records will normally be kept for no longer than 24 months after the relevant decision or closure of the account, unless there is a documented reason to retain them for longer.

Information relating to an organisation or email domain may be retained for longer where the classification remains relevant to administering eligibility for future registrations. We will minimise such records and review them periodically.

Where an organisation or domain record identifies or relates to an individual, including a sole trader, we will treat that information as personal information where data-protection law requires us to do so.

We may remove eligibility information earlier where it is no longer necessary.

11. Automated course and eligibility administration

The learning platform may automatically carry out routine administrative functions. For example, it may:

• mark a quiz or lesson as complete;
• issue a certificate when stated course requirements are met;
• send a course-progress or administrative message;
• detect a keyword, email-domain indicator or other registration rule;
• display an additional eligibility declaration; or
• refer a registration or account for further review.

Eligibility screening rules are intended to assist administration. A keyword, domain indicator or similar automated flag does not necessarily establish that somebody is ineligible or has breached the Terms.

Where eligibility remains unclear or a decision requires consideration of a person’s individual circumstances, the matter may be reviewed by an authorised administrator.

These routine functions are not intended to make solely automated decisions producing legal or similarly significant effects.

If we introduce solely automated decision-making that is intended to have a legal or similarly significant effect, we will provide the information and safeguards required by applicable data-protection law, including appropriate information about the decision and any applicable ability to make representations, obtain human intervention or contest the decision.

14.1 Objections to processing based on legitimate interests

You have the right to object to processing based on legitimate interests.

This includes processing carried out for inactive-account administration or eligibility administration.

You can object or ask us to review your particular circumstances by contacting info@carelearning.org.uk.

We will consider your circumstances and respond in accordance with data-protection law.

An objection does not necessarily require us to stop processing immediately. We may continue where the law allows us to do so, including where we can demonstrate appropriate grounds for continuing the processing or where information is needed for the establishment, exercise or defence of legal claims.

Where appropriate, we may place an administrative or eligibility process on hold while an objection is considered.

15. Complaints about personal information

Please contact info@carelearning.org.uk if you have a concern or complaint about how we use your personal information.

Please provide enough information for us to understand and investigate the concern. We will acknowledge a data-protection complaint within the period required by law and will respond without undue delay.

You may also complain to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Website: https://ico.org.uk/make-a-complaint/