4.8 Learner data management If you are an independent Instructor Member and handle personal information— such as customer names, addresses, or payment details—you may need to register with the Information Commissioner's Office (ICO) and pay the applicable data protection fee. This is a legal requirement under the Data Protection Act 2018 for individuals or organisations that process personal data, and failure to register when required could result in a fine. It's important to assess the nature of your business activities to determine whether registration is necessary. The ICO provides a self-assessment tool on their website here . If you are an in-house Instructor Member solely delivering within your employer's company, charity, or public sector organisation, you may not need to register personally. In these cases, it is usually the responsibility of your employer to register with the ICO. However, you should always check with your organisation’s data protection officer or relevant department to confirm whether the registration has already been completed and whether any specific responsibilities fall to you. 4.9 Learner outside of England Instructor Members are reminded that Mental Health First Aid courses can only be delivered to learners in England. Where Instructor Members receive requests to deliver to learners based outside of England, they must in the first instance refer the learner to the licenced MHFA provider in the country in which the learner is situated.
In some specific circumstances, it may be possible to consider the request for a learner based outside of England to attend and complete the MHFA course delivery, please contact the Instructor Support team at instructorsupport@mhfaengland.org with details of the request so they can advise
further on the matter. 4.10 Concerns Disruptive learners
Where a learner is being consistently disruptive, is not adhering to the group agreement as outlined at the beginning of the delivery or demonstrating concerning behaviours that do not align with the role of an MHFAider ® , based on the situation and level of concern, Instructor Members are able to request the learner to leave the course delivery before they complete all delivered sessions of the course. Independent Instructor Members should ensure that they include provisions for this situation in their business terms and conditions and follow the relevant process should the situation arise. Instructor Members delivering within their own employer organisation should follow internal process to raise concerns and seek support and process guidance from the Workplace Lead as appropriate. If you have any concerns about communications with a learner or client, please contact MHFA England. We are happy to discuss any concerns and offer guidance on how to resolve the situation. For contact information,see section 6 of this handbook.
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