FormedPower
Legal

Privacy Policy

Effective — add date Last updated — add date Version 1.0
Summary

FormedPower operates two service lines — safety and isolation consultancy, and leadership assessment and training — and delivers its courses through a LearnDash-based learning platform. This policy explains what personal data we collect when you enquire, book a diagnostic, or enrol on a course, how we use it, and the rights you hold over it.

In short: we collect the data needed to deliver and evidence training, we retain assessment records because certification requires it, we do not sell personal data, and you can contact us at any time to access, correct or erase your information.

01

Who we are

FormedPower ("we", "us") is the trading name of [legal entity name], a company registered in Ireland under company number [number], with its registered office at [registered address]. We are the data controller for the personal data described in this policy.

We provide two related services: Certified Senior Authorised Person (SAP) and safe-isolation consultancy, and leadership assessment and development including the CPD-certified Dynamic Direct Leadership programme. Course delivery, assessment and certification take place on our learning platform, which is built on WordPress with the LearnDash learning management system.

02

Scope of this policy

This policy applies to our public websites, our enquiry and booking forms, our learning platform and learner accounts, and any correspondence connected with the delivery of our services. It covers you whether you are a prospective client making an enquiry, an individual learner enrolled on a course, or a manager or administrator enrolling others on behalf of an organisation.

Where we deliver training under contract to an employer, that employer may be a joint or separate controller in respect of learner records shared with them. Section 08 explains what is shared and on what basis.

03

Personal data we collect

We collect only what is needed to answer your enquiry, take payment, deliver training, and evidence competency. The categories below reflect our actual use of the platform.

Identity and contact data — name, job title, employer, email address, telephone number, and the site or programme your enquiry relates to.
Account data — username, hashed password, profile details and any avatar you upload to your learner account.
Enrolment and progress data — courses and groups you belong to, lessons and topics marked complete, time spent in course content, quiz attempts, answers and scores, assignment uploads, and certificates issued. This is generated by LearnDash as you use the platform.
Assessment data — responses to the leadership diagnostic, resulting behavioural profile, scored dimensions, debrief notes, and the course track recommendation derived from them.
Payment data — billing name and address, purchase records, invoice references and transaction identifiers. Card details are entered directly with our payment processor and are never stored on our systems.
Technical data — IP address, browser and device type, login timestamps and pages viewed, collected through server logs and analytics.
Correspondence — messages you send us through forms, email, or platform messaging, and our replies.
04

How we obtain it

Most of the data above you give us directly — through an enquiry or booking form, when creating a learner account, when completing an assessment, or in correspondence. Some is generated automatically as you use the learning platform, including progress and quiz records created by LearnDash and technical data written to server logs.

Where an employer enrols you on a course, we receive your name, work email address and group assignment from that employer in order to create your account.

05

Why we use it, and our lawful basis

We rely on one of four lawful bases under the GDPR for each purpose: performance of a contract, legitimate interests, consent, or compliance with a legal obligation.

To respond to enquiries — legitimate interests in replying to a request you have made to us.
To deliver courses and assessments — performance of our contract with you or your employer, including account creation, content access, quiz marking and certificate issue.
To evidence competency and certification — performance of contract and our legitimate interest in maintaining defensible training records, including for CPD certification and client audit.
To take and record payment — performance of contract, and legal obligation in respect of accounting records.
To secure and maintain the platform — legitimate interests in preventing unauthorised access, abuse and credential sharing.
To send service messages — performance of contract; these include enrolment confirmations, course reminders, assessment results and certificate notifications, and cannot be opted out of while you hold an active enrolment.
To send marketing — consent, or the soft opt-in for existing clients. You can withdraw at any time using the unsubscribe link in any marketing email.
06

Assessment, profiling and course placement

The leadership diagnostic produces a behavioural profile that determines which course track we recommend to you. This involves evaluating your responses against defined behavioural dimensions, so it constitutes profiling within the meaning of the GDPR.

The placement recommendation is not made by automated means alone. Scoring is assisted by the platform, but every profile is reviewed by Andrew Dowling and confirmed with you in a live debrief before any placement is made. You may disagree with a placement, ask for the reasoning behind it, and request a different track.

Where an employer has commissioned the diagnostic, section 08 governs what they see. We do not represent diagnostic results as a measure of personal worth, suitability for employment, or clinical or psychological assessment, and they should not be used for those purposes.

07

How long we keep it

We keep personal data only as long as we need it for the purpose it was collected, or as long as we are required to keep it by law. Certification and assessment records are kept longer than other data because the value of a competency record lies in being able to produce it later.

Data Purpose Retention
Enquiry correspondence Answering and following up your enquiry 24 months
Learner account Platform access and course delivery Duration of enrolment + 12 months
Progress and quiz records Evidencing completion and competency 6 years
Certificates issued Verification of certification on request 7 years
Diagnostic profiles Placement, re-assessment and progress comparison 6 years
Payment and invoice records Accounting and tax compliance 7 years
Server and access logs Security and abuse prevention 12 months
08

Who we share it with

We do not sell personal data and we do not share it for third-party advertising. We share it only where necessary to run the service or where we are obliged to.

Your employer or sponsor — where an organisation pays for your training, we share attendance, completion status and certification. For the leadership diagnostic we share the recommended track and completion status; we do not release your full behavioural profile or debrief notes to an employer without your specific consent.
Hosting and platform providers — [hosting provider] hosts the website and learning platform within the EEA.
LearnDash and related plugins — the learning management software and any integrated plugins for quizzes, certificates or group management process data on our behalf as part of platform operation.
Payment processor — [Stripe / other] processes card payments and holds the resulting transaction records.
Email and communications providers — [provider] delivers transactional and marketing email.
Professional advisers and certifying bodies — accountants, insurers, legal advisers, and CPD accreditation bodies where verification of a certified course is required.
Authorities — where disclosure is required by law or by a regulator.
09

International transfers

We aim to keep personal data within the European Economic Area. Where a provider processes data outside the EEA, we rely on an adequacy decision or on Standard Contractual Clauses together with any additional safeguards required, and we keep a record of the transfer mechanism used for each provider. Details of current providers and their locations are available on request.

10

Cookies and similar technologies

The learning platform sets cookies that are strictly necessary for it to function: session and login cookies that keep you signed in, and cookies that record your position in a course so progress is not lost between visits. These cannot be disabled without breaking the platform.

We set analytics and preference cookies only with your consent, collected through the cookie banner when you first visit. You can change or withdraw your choices at any time through the cookie settings link in the footer. A full cookie table listing each cookie, its purpose and its lifespan is maintained at [link to cookie notice].

11

Security

Access to the learning platform is over TLS, passwords are stored only as salted hashes, and administrative access is limited to named accounts with multi-factor authentication. Learner accounts are individual and non-transferable; we monitor for shared credentials because they undermine the integrity of a competency record.

No platform is immune to compromise. If a breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Data Protection Commission within 72 hours and inform affected individuals without undue delay.

12

Your rights

Under the GDPR you have the right to be informed, to access a copy of your data, to have inaccurate data corrected, to have data erased, to restrict or object to processing, to data portability, and to withdraw consent where consent is the basis we rely on. You also have the right not to be subject to a decision based solely on automated processing.

Two limits apply in practice. Where we are required to keep certification and assessment records to evidence training we have certified, we may refuse an erasure request in respect of those records and will explain why. And withdrawing consent to service messages is not possible while you hold an active enrolment, because those messages form part of course delivery.

13

Children

Our services are intended for working adults. We do not knowingly create learner accounts for anyone under 18, and we do not market to children. Where a course is delivered to an apprentice or trainee under 18, enrolment is arranged through their employer and we process only the data needed to deliver and certify the training.

14

Changes to this policy

We may update this policy as our services, platform or legal obligations change. The version number and last-updated date at the top of this page always reflect the current version. Where a change materially affects how we use your data, we will notify active learners by email or through a notice on the platform before it takes effect.

15

Contact and complaints

To exercise any of your rights, or to raise a concern about how your data has been handled, contact us in writing. We respond to rights requests within one month. If you are not satisfied with our response, you may lodge a complaint with the Irish Data Protection Commission.

Data protection contact
admin@formedpower.com
Postal address
[registered address]
Company number
[company registration number]
Supervisory authority
Data Protection Commission, Ireland — dataprotection.ie
Drafting note — this policy is a working draft prepared for a LearnDash-hosted platform. Before publication it must be reviewed by a qualified data protection adviser and completed with the bracketed details: legal entity name, company registration number, registered address, hosting and payment processors actually used, and effective date.