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APT Online
Privacy Policy and Terms of Use

Privacy Policy

APT regards the lawful and correct treatment of personal information as important to our successful operations and to the maintenance of confidence of those with whom we deal. As such this statement will apply equally to all of our operations irrespective of where they are based.

This policy aligns with the provisions of The Data Protection Act and The General Data Protection Regulations 2018 (GDPR) and any related legislation in so far as the same relates to the provisions of these terms and conditions. We shall apply the GDPR globally, except where part or all of any local law is stronger.

This policy relates to relates to all personal data you provide to APT Ltd and all personal data that APT
Ltd holds in relation to your use of (the “Site”).


Your Privacy

APT Ltd is committed to protecting your privacy when you use our services. The privacy statement below explains how we use information about you and APT candidates and how we protect people’s right to privacy.

In line with applicable Data Protection Laws we are only able to process personal data where we have a valid reason to do so, including where you have provided your consent for us to do so, or where we are required to do so either to fulfil our contractual obligations to you, or comply with our legal obligations.

Your personal information is processed, held and/or controlled in accordance with the EU General Data Protection Regulations 2018 (GDPR). Our team makes sure we respect your rights and follow the law. You may contact Spotlight at any time to: 


  • Request access to information which APT has about you

  • Correct any information which APT has about you

  • Ask for any information which APT has about you to be deleted

  • Discuss any concerns or ask any questions about how we look after your personal information

You can contact us at any time at

We may need to use some information about you to: 

  • deliver services and support to you

  • manage those services we provide to you

  • train and manage the employment of our consultants or team members who deliver those services 

  • help investigate any worries or complaints you have about our services and to answer your questions and enquiries 

  • allow you to participate in online training and interactive features of our services if you choose to 

  • check and improve the quality of our services 

  • help with research and planning of new services 

  • send you information which we think might be of interest to you if you have agreed to this 

  • send to third parties where we have retained them to provide services that you have requested 

  • monitor compliance with our policies

  • carry out our obligations arising from any contracts entered into between you and us 

  • market our related products and services to you, where you have given your consent for us to do so

We reserve the right to transfer your data if APT Ltd is sold, goes into a merger, liquidation or receivership or transfers all, or substantially all, of its assets to a new owner. This will only take place if the third party agrees to adhere to the terms of this privacy statement. We will let you know of any such transfer and you will be able to opt-out if you wish.

We only use what we need

We’ll only collect and use personal information if we need it to deliver a service or meet a requirement. If we use your personal information for research and analysis, we’ll always keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.

We don’t sell your personal information to anyone else

You can ask for access to the information we hold about you. We would normally expect to share what we record about you with you, whenever we assess your needs or provide you with services.  However, you also have the right to ask for all the information we have about you and the services you receive from us. When we receive a request from you in, we must give you access to everything we’ve recorded about you.

However, we can’t let you see any parts of your record which contain:

Confidential information about other people; or Data a professional advisor thinks will cause serious harm to your or someone else’s physical or mental wellbeing; or

If we think that giving you the information may stop us from preventing or detecting a crime.

This applies to personal information that is in both paper and electronic records.  

If you ask us for access to your information, then we’ll ask you to provide evidence so that we can verify your identity.

You can ask to change information you think is inaccurate.

You should let us know if you disagree with something contained within your data.  We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

You can ask us to delete information (the right to be forgotten)

In some circumstances you can ask for your personal information to be deleted, for example:

  • Where your personal information is no longer needed for the reason it was collected in the first place.

  • Where you have removed your consent for us to use your information (where there is no other legal reason for us to use it).

  • Where there is no legal reason for the use of your information.

  • Where deleting the information is a legal requirement.

Where your personal information has been shared with others, we’ll do what we can to make sure those
using your personal information comply with your request for erasure.

Please note that we can’t delete your information where:

  • We’re required to have it by law.

  • It is used for freedom of expression.

  • It is for scientific or historical research or statistical purposes where it would make information unusable.

  • It is necessary for legal claims.

You can ask to limit how we use your personal data.

You have the right to ask us to restrict what we use your personal information for where:

  • You have identified inaccurate information and have told us of it.

  • We have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether.

When information is restricted, it can’t be used other than to store securely the data and with your consent; or, to handle legal claims and protect others, or where it’s for important public interests of the UK.  Where restriction of use has been granted, we’ll inform you before we carry on using your personal information.


You have the right to ask us to stop using your personal information for any service we provide.


You also have the right to unsubscribe from any materials we may send you. However, if you make a request this may cause delays or prevent us delivering services to you.  Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or by contract.

Who might we share your information with?

We will share the registration data we have collected from you with your Feedback Consultant, so that the Feedback Consultant can prepare and deliver a high-quality service to you and your child.


We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements, there is always an agreement in place to make sure that the organisation complies with data protection law.  Any personal data that may be processed by or through such third party providers is only as is reasonably necessary in accordance with this Policy.


We may have links to a other websites on our site (Third Party Sites) We are not responsible in any way for the privacy policies of these sites, nor for the way in which they may use the information they collect about you.

We will complete a data protection impact assessment (DPIA) before we share personal information to make sure we protect your privacy and comply with the law. Sometimes we have a legal duty to provide personal information to other organisations. This may be because we need to give that data to the courts. We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:

  • To find and stop crime and fraud

  • If there are serious risks to the public, our staff or to other professionals

  • To protect a child

  • To protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them.


For all of these reasons the risk must be serious before we can override your right to privacy.  We may still share your information if we believe the risk to others is serious enough to do so.  There may also be rare occasions when the risk to others is so great that we need to share information straight away.  If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so.

How do we protect your information?

We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:  

  • Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’.

  • Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.

  • Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong.

  • Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches).

Where in the world is your information?

The majority of personal information is stored on systems in the UK. But there are some occasions
where your information may leave the UK either in order to get to another organisation or if it’s stored
in a system within the EU. We have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party. We’ll take all practical steps to make sure your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments. We will only keep your information for as long as we need it. We will retain your personal information only for as long as we need it in order to fulfil the purposes for which we have initially collected it, unless otherwise required by law or contractual requirements. 

Changes to our Privacy Statement

From time to time we may make changes to this Privacy Policy. Any changes will be posted on this website, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personal data in a manner significantly different from that stated in this privacy statement, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner. 
Reviewed August 2022

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