— Legal · Privacy

Privacy Statement

How we collect, use and protect your personal data.

The Hair and Beauty College Limited (“HBC”, “we”, “us”) is a beauty and aesthetics training college based at 78 Bridge Street, Warrington WA1 2RF. We’re registered with the Information Commissioner’s Office under registration number C1756707 and we take your privacy seriously.

This statement explains what personal data we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it under the UK GDPR and the Data Protection Act 2018.

Last updated: 2026-09-08 (v2 — reviewed and approved by Paula and our solicitor)


1. Who’s responsible for your data

The data controller is:

The Hair and Beauty College Limited 78 Bridge Street, Warrington WA1 2RF Company number 16387627 · ICO registration C1756707 Email: enrol@thehairandbeautycollege.co.uk Phone: 01925 747371

Where this statement uses “we” or “us”, we mean HBC as data controller.


2. What data we collect, and why

We collect the minimum data needed for each interaction. We don’t collect data “just in case” — every category below has a clear purpose.

2.1 Enquiries — Contact form, email, phone

What we collect Why Lawful basis
Name To address you correctly when we reply Pre-contract (UK GDPR Art. 6(1)(b))
Email To respond to your enquiry Pre-contract
Phone (optional) To respond to your enquiry by phone if you prefer Pre-contract
Course of interest To route your enquiry to the right person Pre-contract
Your message To answer your question Pre-contract
Type of enquiry To route to `info@` or `enrol@` Legitimate interest (efficient inbox routing)

2.2 Enrolment — funded courses (VTCT diplomas via Advanced Learner Loan)

What we collect Why Lawful basis
Full name, date of birth, postcode To produce your Funding Information Letter (a GOV.UK requirement) Legal obligation (UK GDPR Art. 6(1)(c))
Email, phone To stay in touch through your application Contract
Course of interest, preferred start date To match you to a cohort Contract
Anything-we-should-know note To support you appropriately on the course Contract / consent for special-category data (see 2.6)

2.3 Enrolment — paid courses (CPD and non-funded Awards)

Same as 2.2 (minus DOB and postcode), plus:

What we collect Why Lawful basis
Payment preference To send the right payment link Contract
Payment details We don’t store these — Stripe and Payl8r handle them directly N/A — handled by payment processors

2.4 Treatments at our salon floor (public clients)

What we collect Why Lawful basis
Name, contact details To book and confirm your appointment Contract
Treatment history, contraindications, allergies To deliver the treatment safely Contract + explicit consent for special-category data (Art. 9(2)(a))

2.5 Model Group sign-up

See `/model-group` for full detail. We collect contact details, treatment preferences, days available, photo/video consent level, and an optional medical history field.

Lawful basis
Consent (Art. 6(1)(a)) for the contact list itself
Explicit consent (Art. 9(2)(a)) for any medical history you choose to disclose
Consent for any photos or video — opt-in only, re-confirmed per session

2.6 Health and learning-difference disclosures (students)

If you tell us about a medical condition, allergy, medication, or learning difference at enrolment, that’s special-category data under UK GDPR Article 9. We hold it on the basis of:

  • Explicit consent (you’ve chosen to disclose so we can adapt training to support you); or where consent isn’t appropriate,
  • Substantial public interest under the Equality Act 2010 (we’re obliged to make reasonable adjustments).

This data is shared only with your tutor, on a need-to-know basis, and is held for the same retention period as the rest of your learner record.

2.7 Coursework, portfolios, assessments

While you’re enrolled, we collect work-product data: written assessments, practical observation records, portfolio submissions, attendance, and assessment outcomes. We hold this on the basis of contract (delivering the course you’ve enrolled on) and, where awarding-body audit requires, legal obligation.

2.8 Site analytics and marketing pixels

See our Cookie Policy for the full breakdown. In summary:

  • Essential cookies load by default (needed for the site to function and for the Jotform anti-spam check)
  • Analytics and marketing tools load only after you consent via our cookie banner

The tools we use, when consented:

Tool Purpose Vendor
Google Analytics 4 (GA4) Aggregate site usage statistics — pages visited, time on site, conversion paths Google Ireland Limited
Google Tag Manager Container for the analytics + marketing tags so they can be managed without code changes Google Ireland Limited
Google Ads conversion tracking (if used) Measure which ads lead to enrolments so we don’t waste your council-tax-funded loan budget on ads that don’t work Google Ireland Limited
Meta Pixel (possibly — see consent banner) If we run Facebook or Instagram ads, the pixel measures whether those ads convert. Toggleable in the cookie banner. Meta Platforms Ireland Limited

If you decline analytics/marketing cookies, we still serve the site — you just don’t appear in our usage stats and any Meta-driven retargeting doesn’t see you.


3. Who we share your data with

We never sell your data. We share it only with the third parties below, only for the purposes named, and only where the lawful basis above permits.

3.1 Course delivery and assessment

Recipient What we share Why
VTCT (awarding body) Learner registration data, assessment outcomes, certification details Statutory awarding-body audit + certificate issuance
Focus Awards (awarding body) Same — for Focus-awarded qualifications Same
The CPD Group (awarding body) Same — for CPD-accredited courses Same
Tutors and assessors (internal) Your enrolment data + any health disclosures To deliver and assess the course

3.2 Funded course administration

Recipient What we share Why
Funding compliance partner (named at point of enrolment) Your name, contact details, course of interest, start date To guide you through your loan application — we hand off after your enquiry
Student Loans Company (statutory) Course confirmation, fee verification, attendance evidence Statutory funding administration

3.3 Payment processing

Recipient What we share Why
Stripe (payment processor) Card data is collected by Stripe directly — HBC never sees or stores card numbers Card / Apple Pay / Google Pay / Bank transfer / PayPal / Clearpay processing
Social Money Ltd t/a Payl8r (consumer credit) Your name, contact details, course fee, and information needed for credit assessment if you apply Finance application processing — see `/funding/payl8r` for full disclosure

HBC is an Introducer Appointed Representative of Social Money Ltd t/a Payl8r (FCA Reference 675283). Representative APR 65.5%.

3.4 Site infrastructure and tools

Recipient What we share Purpose Data residency
Jotform (form intake) Whatever you enter into our forms Form processing and notification routing EU (Frankfurt)
Google Analytics 4 (consent-gated) Pseudonymous usage events, page views, IP truncated Aggregate site analytics EU + US
Google Tag Manager (loads on consent) Tag-management container; doesn’t itself collect data Tag deployment EU + US
Meta Pixel (consent-gated, possibly deployed) Pseudonymous browsing events on the HBC site Ad-conversion measurement on Facebook/Instagram EU + US
WP Engine (site hosting) Web traffic, IP addresses Site hosting and DDoS protection EU
Google Workspace (mailbox + business apps) Email correspondence, calendar entries, document storage Email infrastructure and internal admin EU + US
Mailchimp (marketing email) Name, email, marketing engagement events Newsletter and course-update sends EU + US

3.5 Statutory and regulatory

We share data with HMRC, Companies House, and the Information Commissioner’s Office where law requires it — this includes tax and accounting records, statutory company filings, and responses to lawful requests from the police, courts, or other regulators where we have a legal duty to disclose.


4. Children and under-18s

Most of our courses are 16+ (and funded courses require you to be 19+ at start under Advanced Learner Loan rules). Where someone under 18 enrols or signs up to the model group:

  • A parent or guardian must be present at sign-up and on premises during attendance
  • We collect parental consent for processing personal data of anyone under 13 (though our minimum age is higher than that)
  • We do not direct any marketing at children

5. How long we keep your data

We keep data only as long as we need it for the purpose collected, and longer where law or awarding-body rules require.

Data category Retention period Reason
Enquiry records (form submission, not enrolled) 12 months from last contact Operational follow-up; deleted thereafter
Learner records (enrolment, attendance, assessments, certification) 6 years from course completion or withdrawal Awarding-body audit + statutory record-keeping (confirmed with VTCT/Focus).
Financial records (invoices, payment receipts) 6 years from end of relevant tax year Companies Act 2006 + HMRC retention rules
Treatment client records (salon floor) 6 years from last treatment Insurance and consumer-protection norms
Model group records Until withdrawn or 24 months of inactivity (no response to slot offers) Contract / consent — see Model Group sign-up
Marketing consents Until withdrawn Consent (Art. 6(1)(a))
Health and learning-difference disclosures Same as the underlying learner / model record Cannot be retained beyond the purpose of collection
Photos and video (with consent) Until consent withdrawn or relevant student’s record reaches end of retention Consent — see consent form per session
Google Analytics 4 data 14 months (default, configurable) Legitimate interest for aggregated site analytics; consent for any user-level data
Meta Pixel data (if deployed) 180 days (Meta’s default custom-audience window) Consent — toggleable in cookie banner

When a retention period ends, we delete or anonymise data through scheduled clean-up — not “as we get round to it”. Anonymised data may be retained for statistical reporting (e.g. cohort outcomes) without time limit, since it can no longer identify any individual.


6. Direct marketing

If you’ve opted in to receive marketing from HBC (course updates, open days, model-group slots that might suit you) we contact you through email — sent via Mailchimp (see Section 3.4).

You can withdraw consent at any time:

  • Click unsubscribe at the bottom of any marketing email (handled by Mailchimp — instant)
  • Email enrol@thehairandbeautycollege.co.uk with “UNSUBSCRIBE” in the subject
  • Tell us by phone or in person

Withdrawing marketing consent doesn’t affect our right to contact you about an active enrolment or appointment — that’s covered by contract, not consent.


7. Your rights as a UK resident

Under UK GDPR you have the following rights over your personal data:

Right What it means
Access We give you a copy of the data we hold about you
Rectification We correct inaccurate data on your request
Erasure (“right to be forgotten”) We delete your data, subject to legal-retention exceptions
Restriction of processing We pause certain uses of your data while a dispute is resolved
Portability We provide your data in a structured, machine-readable format
Objection You can object to processing based on legitimate interest or for direct marketing
Automated decisions You’re not subject to decisions made solely by algorithm — we don’t use automated decisioning
Withdraw consent Where processing is based on consent, you can withdraw at any time
Complain to the ICO If you believe we’ve mishandled your data — see Section 9

Exercising your rights

To make a request, email enrol@thehairandbeautycollege.co.uk with the right you’re exercising in the subject line (e.g. “Subject Access Request”). We respond within 30 calendar days (extendable to 90 days for complex requests, with notice to you). Requests are free unless they are manifestly unfounded or excessive, in which case we’ll explain any fee before charging.

We may need to verify your identity before disclosing personal data — typically by asking for confirmation from the email address on file.


8. Where your data is processed

Our primary data processing happens in the United Kingdom (HBC office at 78 Bridge Street) and the European Union (Jotform Frankfurt data residency).

Some processors (Stripe, Payl8r) may transfer data to the United States for fraud-prevention checks. Where data leaves the UK / EU, we rely on:

  • UK adequacy regulations (EEA, EU-approved adequacy decisions); or
  • Standard Contractual Clauses (UK SCCs / EU SCCs) — the contractual safeguards approved by the ICO; or
  • Specific consent where neither of the above applies.

9. Third-party websites

This site links to third parties (GOV.UK for the loan application, awarding-body sites, Google Maps, social media). Once you click through, you’re on their site and subject to their privacy policies — not ours. We don’t control how they handle your data and aren’t responsible for their practices.


10. How to complain

If you think we’ve mishandled your data, we’d like the chance to put it right first. Email enrol@thehairandbeautycollege.co.uk with “Data complaint” in the subject. We’ll acknowledge within 5 working days and respond fully within 30 calendar days.

If our response doesn’t satisfy you, you have the right to complain to the Information Commissioner’s Office:

  • Online: ico.org.uk/make-a-complaint
  • Phone: 0303 123 1113
  • Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

You can complain to the ICO directly without going through us first — but we’d appreciate the chance to fix it.


11. Security

We use industry-standard technical and organisational measures to protect your data:

  • Encryption in transit (HTTPS / TLS for all web traffic and form submissions)
  • Encryption at rest (passwords hashed; sensitive data fields encrypted in the form provider’s database)
  • Access controls (only authorised tutors and admin staff access learner records)
  • Audit trails (form submissions and access logs retained per the table in Section 5)
  • Secure deletion (scheduled erasure when retention periods end)
  • Staff training on data protection and safeguarding

No system is 100% secure. If we ever experience a personal data breach that puts your rights at high risk, we’ll notify the ICO within 72 hours and you, where required, without undue delay.


12. Changes to this statement

We update this statement when our processing changes — for example, when we add a new tool, add a new processor, or extend a retention period. Material changes are notified to existing students and active enquirers by email.

The current version always lives at this URL with the Last updated date at the top.


13. Questions

If anything here is unclear:

  • Email enrol@thehairandbeautycollege.co.uk
  • Call 01925 747371 (Mon–Fri 9:30am–9:30pm, Sat 9:30am–4:30pm, Sun closed)
  • Write to: The Hair and Beauty College Limited, 78 Bridge Street, Warrington WA1 2RF

The Hair and Beauty College · 78 Bridge Street, Warrington WA1 2RF · 01925 747371 · ICO registration C1756707