1. Introduction
Oliver McGowan Academy (OMA) is an operating division of MDG Health Consult Ltd and is not a separate legal entity.
This Privacy Policy explains how personal information is collected, used, stored, shared and protected in connection with OMA’s website, training services, learner administration and business activities.
It applies to information collected through:
- https://olivermcgowanacademy.com/
- Training enquiries, bookings and communications.
- Classroom and in-person training administration.
- Learner records and completion certificates.
- Online services or external integrations used in connection with training.
This policy should be read alongside the Cookie Policy, Accessibility Statement and Records Management, Retention and Disposal Policy.
2. Personal information we may collect
2.1 Contact and enquiry information
We may collect your name, email address, telephone number, organisation, job title where provided, and the contents of your enquiry or correspondence.
2.2 Booking and training information
We may collect learner names, course dates, booking references, attendance information, relevant communications and course completion status.
2.3 ELFH completion certificates
For relevant Oliver McGowan Mandatory Training, learners must complete the applicable official e-learning prerequisite through the NHS England e-Learning for Healthcare (ELFH) service.
Where required by OMA’s booking process, learners upload their ELFH completion certificates to OMA. We retain the certificates received and maintain a log recording their receipt and relevant administrative details.
We use this information to administer training, check required prerequisite documentation and maintain appropriate training records.
ELFH is an external service. Its own privacy notice applies to information it collects directly through its website and systems. OMA does not claim direct access to ELFH learner accounts or internal records unless a separate authorised arrangement has been established.
2.4 Assessment and completion information
Where applicable, we may hold assessment outcomes, attendance records, course completion details and information needed to administer or verify certificates issued by OMA.
2.5 Payment and transaction information
We may process information needed to manage invoices, payment status, refunds and accounting records.
Online card payments are processed through Stripe where used. Bank transfers are also accepted. Other payment providers will be identified in the relevant information if introduced.
2.6 Technical and website information
Our websites or service providers may process technical information such as IP address, device and browser details, website activity, security logs and cookie preferences, depending on the configuration of the relevant website and services.
The use of optional analytics or tracking technologies depends on the actual configuration and consent arrangements in place.
2.7 Special-category information
We do not routinely require learners to provide detailed medical information merely to book or attend training.
If you voluntarily provide information about a disability, health condition or adjustment requirement, we will use it only where necessary to consider reasonable adjustments, support participation, respond to your request or meet an applicable legal obligation.
Please avoid including unnecessary sensitive information in general enquiries.
3. How we collect information
We may collect personal information:
- Directly from you through our website, forms, emails, telephone calls or other communications.
- When you or your organisation books training.
- When you upload an ELFH completion certificate.
- Through attendance, assessment and course-administration processes.
- From an employer, commissioner or booking contact arranging training on your behalf, where they have an appropriate basis to provide the information.
- Through website hosting, security, payment or other service providers, where applicable.
Where information is provided by an organisation on your behalf, you may wish to ask that organisation how it obtained and uses your information.
4. Why we use personal information
We may use personal information to:
- Respond to enquiries and provide quotations.
- Manage bookings, registrations and communications.
- Administer classroom, in-person and other training services.
- Record attendance and course completion.
- Receive, log and check ELFH completion certificates where required.
- Issue, administer or verify training certificates where applicable.
- Process payments, invoices and refunds.
- Respond to complaints, queries and requests.
- Support accessibility adjustments and learner participation.
- Maintain quality assurance, audit trails and appropriate business records.
- Protect our websites, systems, personnel and services.
- Comply with legal, regulatory and contractual obligations.
- Establish, exercise or defend legal claims where necessary.
We will not use personal information for purposes incompatible with the reason it was collected without an appropriate lawful basis or other required steps.
4a. Training Completion and Certificate Records
OMA may process learner names, contact details, course bookings, attendance, completion status and certificate-related information for training administration, verification, certificate handling and record-keeping.
For The Oliver McGowan Mandatory Training, a partner may issue the certificate under the applicable partnership arrangements. OMA may record relevant completion or certificate information where necessary for its role in the partnership. OMA may also issue and record Certificates of Completion for its own Neurodiversity Awareness training.
Learner information may be shared with the relevant training partner where necessary for course delivery, completion verification or certificate issuance, subject to applicable data protection requirements and the arrangements governing the partnership.
OMA retains the records it is responsible for in accordance with its Records Management Policy and Learner Records Procedure.
5. Our lawful bases for processing
Under applicable data protection law, we rely on one or more of the following lawful bases, as appropriate:
- Contract: where processing is necessary to enter into or perform an agreement with you or the organisation arranging your training.
- Legitimate interests: where processing is necessary for our legitimate business and operational interests, provided those interests are not overridden by your rights and interests.
- Legal obligation: where we must process information to comply with the law.
- Consent: where consent is the appropriate basis, including for certain optional cookies or communications where required.
- Other applicable lawful bases: where permitted by law and relevant to the circumstances.
Where we process special-category personal data, such as health information provided for an adjustment, we will identify and rely on an applicable additional condition under data protection law.
Where processing relies on consent, you may withdraw that consent. Withdrawal does not make earlier processing unlawful, and another lawful basis may apply to information we must continue to retain.
6. Who may receive personal information
We may share relevant information with:
- Authorised office personnel who need it to perform their duties.
- Trainers and training-delivery personnel where necessary to deliver or administer training.
- Website hosting, IT, email, security and other technical service providers.
- Online learning or course-service providers where applicable.
- Stripe and other payment providers where used.
- Employers, commissioners or booking organisations where necessary and lawful.
- Accreditation, regulatory or quality-assurance bodies where applicable.
- Professional advisers, insurers or auditors where appropriate.
- Courts, regulators, law-enforcement bodies or other public authorities where required or permitted by law.
We aim to share only the information reasonably necessary for the relevant purpose. We do not sell personal information to third parties.
Access to uploaded ELFH certificates and the related certificate log is restricted to authorised office personnel who need access for their duties.
7. Storage, security and access controls
We take reasonable and appropriate steps to protect personal information from unauthorised access, loss, alteration, disclosure or destruction.
Measures may include access restrictions, account security, secure storage, staff instructions, appropriate technical safeguards and secure disposal procedures.
No method of internet transmission or electronic storage can be guaranteed to be completely secure. We nevertheless take reasonable steps to protect the information entrusted to us.
8. How long we retain information
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, taking account of legal, contractual, accounting, training, quality-assurance and dispute-resolution requirements.
Our standard retention period for ELFH completion certificates and associated learner-training records is seven years. The period will normally run from the relevant course completion date or another appropriate starting point specified in our retention schedule.
Some records may require a different period. Financial, contractual, staff, complaint or incident records may be subject to separate retention requirements.
When information is no longer required, we take reasonable steps to delete it securely or otherwise dispose of it appropriately, unless we must retain it for a legal or other valid reason.
Further information is set out in our Records Management, Retention and Disposal Policy.
9. External services and international transfers
Our OMA website uses WordPress, and our hosting arrangements use Namecheap. Other providers may support email, payments, security, online learning or website functionality.
The specific providers involved depend on the configuration of the services in use. External providers may process information on our behalf or under their own privacy arrangements.
Where personal information is transferred outside the United Kingdom in circumstances requiring safeguards under data protection law, we will take the steps required by law, which may include an adequacy decision or an appropriate transfer mechanism.
ELFH is an external NHS England e-learning service. Information provided directly to ELFH through its website is governed by ELFH’s own arrangements.
10. Cookies and similar technologies
Our website may use cookies or similar technologies for essential functions, security, preferences and, where configured, optional analytics or other purposes.
Where consent is legally required, non-essential cookies or similar technologies should not be activated before valid consent is obtained. Users should be able to reject optional cookies and change their preferences.
Please refer to our separate Cookie Policy for further details. The actual technologies used depend on the website’s configuration.
11. Your data protection rights
Depending on the circumstances and applicable law, you may have the right to:
- Request access to your personal information.
- Request correction of inaccurate or incomplete information.
- Request erasure where the legal conditions are met.
- Request restriction of processing in certain circumstances.
- Object to processing based on legitimate interests or to certain other processing.
- Request data portability where the relevant legal conditions apply.
- Withdraw consent where processing relies on consent.
- Complain to the Information Commissioner’s Office (ICO).
These rights are not absolute and may be subject to legal conditions and exemptions.
To make a request, contact us using the details in Section 13. We may need to verify your identity before responding.
12. Changes to this policy
We may update this policy to reflect changes in our services, systems, legal requirements or data-handling practices. The current version will be published on the relevant website, with its effective date and review date.
13. Contact us
For privacy questions, data protection requests or concerns about how your information is handled, contact:
Oliver McGowan Academy
An operating division of MDG Health Consult Ltd
124 City Road, London, EC1V 2NX
Email: support@mdghealthconsult.co.uk
Telephone: 020 3488 1172
Website: https://olivermcgowanacademy.com/
You may also contact the UK Information Commissioner’s Office (ICO) for independent information or to raise a complaint.
Website: https://ico.org.uk/
Telephone: 0303 123 1113
Operating division: Oliver McGowan Academy (OMA)
Legal entity: MDG Health Consult Ltd
Company number: 13421370
Registered office: 124 City Road, London, EC1V 2NX
Effective date: 11 October 2026
Next review date: 11 October 2027
