Effective Date: 20 August 2025
Last Updated: April 2026

1. Introduction

This Privacy Policy explains how Active Training Team collects, uses, and protects personal data and user-generated content within our 360Learning platform account. By accessing or using the platform, you agree to the terms outlined below.

2. Data We Collect

We may collect the following types of data:

  • Personal Information: Name, email address, job title, organisation, and other identifiers provided during registration or profile updates.
  • Usage Data: Course progress, quiz results, time spent on modules, and interaction logs.
  • User-Generated Content: Any text, files, or media you contribute via answers to questions, comments in discussion feeds, or other collaborative features.

3. Purpose of Data Collection

We collect and process your data for the following purposes:

  • To deliver and improve learning experiences
  • To track progress and provide feedback
  • To facilitate collaboration and discussion
  • To analyse participant responses and engagement data for the purposes of programme evaluation and client reporting
  • To comply with legal obligations and internal policies

4. Legal Basis

Data is processed under the following legal bases:

  • Contractual necessity: To provide access to learning services
  • Legitimate interest: To improve platform functionality and engagement, and to analyse programme data for evaluation and reporting purposes
  • Consent: For optional features such as newsletters or behavioural analytics

5. Data Sharing

Your data may be shared with:

  • Platform administrators within Active Training Team
  • 360Learning as a data processor, under GDPR-compliant terms
  • Anthropic PBC, as a data processor, where your data is used in AI-assisted analysis (see section 12). Anthropic processes data under a Data Processing Agreement and does not use data processed under commercial terms to train its AI models.
  • The client organisation that commissioned your programme, in the form of aggregated evaluation outputs and reports
  • Third-party service providers only when necessary for platform functionality

We do not sell or rent your data to external parties.

6. User-Generated Content

Content you contribute (e.g., answers, comments) may be visible to other users within your learning group. Please avoid sharing sensitive personal information in public discussion areas.

Written responses and other user-generated content may also be used in programme evaluation and analysis as described in sections 3 and 12.

7. Data Retention

We retain your data for as long as your account is active or as required by law. You may request deletion of your account and associated data by contacting digital@activetrainingteam.co.uk.

8. Your Rights

You have the right to:

  • Access your personal data
  • Request correction or deletion
  • Withdraw consent (where applicable)
  • Object to processing carried out under legitimate interests
  • Lodge a complaint with the Information Commissioner’s Office – https://ico.org.uk/make-a-complaint/

9. Security

We implement appropriate technical and organisational measures to protect your data, including encryption, access controls, and regular audits.

10. Contact

For questions or concerns about this policy, contact:
Email: digital@activetrainingteam.co.uk
Phone Number: (0)203 872 3644
Address: Studio A, 2nd Floor, 6 Little Thames Walk, London, SE8 3FB

11. Moderation and Content Review

To maintain a respectful and productive learning environment, Active Training Team reserves the right to moderate and review user-generated content, including but not limited to:

  • Discussion feed posts
  • Comments on learning modules
  • Answers to questions or quizzes with open-ended responses
  • Uploaded files or media shared within the platform

Moderation may include:

  • Automated filtering for inappropriate language or flagged terms
  • Manual review by designated administrators or moderators
  • Removal or editing of content that violates community guidelines, legal standards, or organisational policies

Content may be reviewed for:

  • Relevance to the learning objectives
  • Accuracy and clarity
  • Respectful tone and constructive engagement
  • Compliance with data protection and copyright laws

Users will be notified if their content is removed or flagged, and may appeal moderation decisions by contacting digital@activetrainingteam.co.uk.

Please note:

  • Moderators do not pre-approve all content before publication
  • Content shared in private groups may still be subject to review
  • Repeated violations may result in account suspension or restricted access

By contributing content, you grant Active Training Team a non-exclusive right to use, display, and archive your contributions within the scope of the learning platform.

12. Use of AI Tools in Analysis and Reporting

Active Training Team uses AI tools to analyse data from the 360Learning platform for the purposes of programme evaluation and client reporting.

What data is analysed

We may use the following data types in AI-assisted analysis:

  • Written reflection responses submitted in response to module prompts
  • Platform engagement data, such as completion rates and module progress
  • Posts made in public discussion areas

How we protect your data before analysis

Before reflection or engagement data is submitted to an AI tool, we pseudonymise participant data: your name is replaced with a numeric identifier and your email address and other directly identifying information are removed. Analysis is performed at cohort level. Outputs produced from the analysis do not include your name.

Where public discussion posts are used in analysis, names and identifying information are removed before submission to any AI tool.

The AI tool we use

We currently use Claude, a product of Anthropic PBC. Anthropic acts as a data processor on our behalf under a Data Processing Agreement. Anthropic does not use data processed under commercial terms to train its AI models. Data submitted to Claude is deleted from Anthropic’s systems within 30 days of the relevant conversation being closed.

Your rights in relation to this processing

You have the right to object to processing carried out under legitimate interests, and to request access to or deletion of your personal data. To exercise these rights, contact digital@activetrainingteam.co.uk.