1. Introduction
Watermark Group Ltd (“Watermark”) is committed to protecting the privacy and security of the personal data of our cadets. This policy outlines how we collect, use, store, and protect personal data in compliance with the General Data Protection Regulation (GDPR).

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2. Data Controller
Watermark Group Ltd is the data controller for the personal data of cadets. We determine the purposes and means of processing this data.

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3. Data We Collect
We may collect and process the following personal data about cadets:

Personal identification information (name, date of birth, gender, nationality)

Contact information (address, phone number, email address)

Educational background and qualifications

Medical and health information

Employment history and references

Performance records and assessments

Financial information (bank details, scholarship information)

Emergency contact details ​

 

4. Purposes of Data Processing
Watermark processes cadet personal data for the following purposes:

Recruitment and selection of cadets

Administration of training programs and courses

Monitoring and evaluation of cadet performance

Health and safety management

Compliance with legal and regulatory obligations

Communication with cadets and their emergency contacts

Processing payments and financial support

Providing support and welfare services

 

5. Legal Basis for Processing
Watermark processes personal data based on one or more of the following legal bases:

Consent: Cadets have given clear consent for us to process their personal data for specific purposes.

Contract: Processing is necessary for the performance of a contract with the cadet or to take steps at the request of the cadet before entering a contract.

Legal Obligation: Processing is necessary for compliance with a legal obligation to which Watermark is subject.

Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by Watermark or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the cadet.

 

6. Data Sharing
We may share cadet personal data with the following parties:

Training institutions and course providers

Employers and placement providers

Medical professionals and health services

Legal and regulatory authorities

Financial institutions for processing payments

Emergency contacts in case of an emergency

 

7. Data Security
Watermark takes the security of cadet personal data seriously. We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of sensitive data

Access controls and authentication mechanisms

Regular security assessments and audits

Secure storage and disposal of data

 

8. Data Retention
Watermark retains personal data only for as long as necessary to fulfil the purposes for which it was collected and processed, or as required by law. Retention periods vary depending on the type of data and the purpose of processing.

 

9. Rights of Cadets
Cadets have the following rights regarding their personal data:

Access: The right to request access to their personal data and obtain a copy.

Rectification: The right to request correction of inaccurate or incomplete personal data.

Erasure: The right to request deletion of their personal data, subject to certain conditions.

Restriction: The right to request restriction of processing of their personal data.

Data Portability: The right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

Objection: The right to object to the processing of their personal data in certain circumstances.

Withdraw Consent: The right to withdraw consent at any time, where processing is based on consent.

 

10. Changes to This Policy
Watermark reserves the right to update this policy as necessary. Any changes will be communicated to cadets and will be effective upon posting on our website or other communication channels.