Introduction
This learning management system (LMS) is provided by Torbay Council to support employee, partner and external training delivery. This page explains how personal data is collected, used and protected when you use iLearn.
Data Controller
Torbay Council is the Data Controller for personal data processed within iLearn.
The system is hosted and supported by our contracted LMS provider (Totara platform supplier), who acts as a Data Processor on our behalf under a formal data processing agreement.
What Personal Data We Collect
Depending on your role and use of the system, we may process:
• Name
• Work email address
• Job title and service area
• Line manager details
• Employment status
• Training enrolments and completion records
• Assessment results and certifications
• Appraisal and performance workflow data (where applicable)
• System usage data (e.g. login history, activity logs)
We do not collect special category data through the LMS unless explicitly provided by you when setting up your profile.
Purpose of Processing
We process your data in order to:
• Provide access to mandatory and optional training
• Monitor compliance with statutory and organisational learning requirements
• Record qualifications and certifications
• Support workforce development and performance processes
• Provide management reporting on training compliance and completion
• Maintain system security and integrity
Therefore, the lawful basis of processing is Legal Obligation where the training is legally required to be completed and Legitimate Interests for general training, development and for performance management.
Data Sharing
We do not trade personal data for any commercial purpose nor do we sell or use your data for marketing purposes.
Your data may however be shared with:
• Your line manager and authorised managers for compliance monitoring
• HR and organisational development teams
• System administrators
• Our LMS hosting and support provider (as Data Processor)
Outside of the above, we will only disclose your personal data if we have a lawful basis to do so.
Data Retention
Training records are retained in line with the Council’s retention schedule.
At launch of the current system, only the most recent five years of training history have been migrated. Historic data may be retained separately in secure archive systems.
Retention periods vary depending on the type of training (e.g. statutory safeguarding training may have longer retention requirements).
Security
The LMS is a secure, login-restricted system. Access is role-based and limited to authorised users.
Technical and organisational measures are in place to protect data against:
• Unauthorised access
• Accidental loss
• Alteration or disclosure
User accounts are managed in line with Council IT security policies.
Cookies
iLearn uses essential cookies only. These cookies are required to:
• Maintain secure login sessions
• Remember user preferences
• Ensure the system functions correctly
Because the system requires login and only uses essential cookies, a cookie consent banner is not presented. Further information on essential cookies is available on the Council’s main website.
Your Rights
Under UK GDPR, you have the right to:
• Access your personal data
• Request correction of inaccurate data
• Request restriction of processing (where applicable)
• Raise concerns about how your data is handled
Requests should be directed to the Council’s Information Governance team.
Contact
For system support queries:
Torbay Council - ilearn@torbay.gov.uk
Torbay Council Children’s Services - Learning&DevelopmentHub@torbay.gov.uk
Torbay Safeguarding Children Partnership (TSCP) - TSCPtraining@torbay.gov.uk
SWISCo - hrswisco@torbay.gov.uk
For data protection queries:
Information Governance Team – infocompliance@torbay.gov.uk