Personal information and more specifically the privacy of client data is important to our business as it is the bedrock for building trust and enhancing our working relationship.
In this notice we set out what data is collected, how it is collected, used and stored and for what purpose.
This notice applies to our website, verbal, written and electronic communication before, during and after our business transactions.
We urge you to read our policy carefully and contact us with any questions or concerns about our privacy practices.
Who we are
Insight Learning Consultancy Ltd and associates is a private limited company with registered office in England, UK with the company number 05679865.
For the purpose of the EU General Data Protection Regulation (EU) 2016/679, Insight Learning Consultancy Ltd are a registered Data Controller with the Information Commissioner’s Office (ICO); our registration number is ZA536865.
For all data protection enquiries please contact Kate Craven at firstname.lastname@example.org.
What information do we collect?
The typical categories of personal data we collect includes your full name, business address and email address (often work email).
We collect and process your data when you:
- Enquire about our business services;
- Register for an event, use our training, coaching or facilitation services;
- Complete a questionnaire, feedback or contact form;
- Complete a third-party psychometric assessment;
- Attend an event; and / or,
- Wish to receive marketing from us.
How do we use your personal data?
Our business requires that we hold contact details to send and receive communications with you, before, during and after an event or business series.
We will also use your information for:
- personalisation of content, business information or user experience;
- event administration;
- delivering marketing and events communication;
- carrying out feedback surveys, psychometric tests and profile questionnaires; and,
- providing training or coaching services.
What legal basis do we have for processing your personal data?
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. See below what legal basis we rely on.
|Processing activity||Lawful basis of processing under Art 6 (1) (GDPR)|
|Responding to your enquiries about our business services.||(f) Legitimate interest. We have a legitimate interest to process the data you provide so we can answer your enquiry fully and respond to you.|
|Fulfilling our contract with you.||(b) To fulfil the requirements of a contract. To provide a meaningful and personal service within our coaching and training business, we require information as requested in our communications with each client to deliver results. Our terms of business layout specific details of each contract entered.
Failure to provide accurate information may result in your place on the event being declined.
|Marketing to existing customers||(f) Legitimate interest. We rely on our legitimate interest to send you marketing about other services we offer that we think you might be interested in.|
|Taking photos at events for memorabilia or educational purposes||(f) Legitimate Interest. We have a legitimate interest to take photos of you at events and share them with you for educational purposes. You can object to this processing at any time.|
|Transferring data to associates and/or third-party suppliers of psychometric tests and questionnaires||(b) To fulfil the requirements of a contract. We use associates and third parties to enhance some of our business services. If you choose a service which requires the help of one of our associates or third-party suppliers, their details will be provided to you before we begin. Our associates have their own privacy notices for processing your data and we encourage you to read them.|
|Recruitment||(f) Legitimate interest. We rely on our legitimate interest to collect necessary information to hire coaches and mentors to supply our business services.|
Who we transfer your data to
When you choose a business offering which requires the services of one of our associates or a third-party company, we will always inform you at the start of our service.
We may also share your data with event venues when necessary to provide our services.
Please note, the data will be shared in written form, often by email with safeguards in place to limit who can access your personal data.
Except as provided above, under certain circumstances the force of law may require the provision of information to the legal authorities. In order to maintain the integrity of our business and safeguard the interests of our customers Insight Learning Consultancy Ltd will comply with any such legally binding request.
Third Party websites
Our website may contain links to third party websites. Please note, if you follow a link to any such website, we do not accept any liability or responsibility because these websites have their own Terms & Conditions and Privacy Policies.
Where do we store and process personal data?
Data will be stored and processed in England, UK. Where necessary, we will implement standard contractual clauses in our contracts to safeguard the transfer of data outside of the EEA. You will always be informed if and when this happens prior to the data transfer.
How long do we keep your personal data for?
Data provided to us at the beginning of an event or coaching series will be stored for the length of the contract and no longer than reasonably necessary to process all information in relation to the service being provided.
Calendar monthly inspections and secure destruction methods for disposal of all data records are carried out where the information is no longer necessary outside of contractual obligations, legal business accounting or other local law as may be pertaining at the time.
Use of automated decision-making and profiling
Any psychometric testing, personality profiling or other personal development questionnaires are processed by third parties who employ trained personnel under the relevant body’s code of conduct. Insight Learning Consultancy Ltd does not carry out automated decision making or profiling, but we will send your report from the third-party provider to you or your company.
Your results are utilised only during our time working together and remain your property throughout. All records will be securely destroyed at the end of our contract.
Your rights in relation to personal data
Under the EU General Data Protection Regulation (GDPR), as a Data Subject, you may exercise your right to:
Access the personal data we hold on you
You can access your data processed by us at any time. We will confirm what data is being processed, provide you with a copy of your data in addition to any supplementary information as required.
If you wish to access your data, please submit a Subject Access Request (“SAR”) to Kate Craven by email. We will provide your information in a commonly used electronic format unless you instruct us otherwise. We will need to confirm your identity before providing a response to your SAR.
When making your request, please include:
- Your full name and email address;
- Your company name; and,
- Details of the specific information you require and any relevant dates.
If we are unable or unwilling to agree to the request, we must inform you without undue delay and at the very latest within one month of receipt of your access request, why we have refused the request and that you have the right to complain to the supervisory authority.
Your request will be free of charge, unless “manifestly unfounded or excessive”.
Rectify your personal data
If at any point you believe the information we process on you is incorrect, you may at any time amend or update your data by contacting Kate Craven by email.
Have your data erased
Please send your request for erasure to Kate Craven by email. If you request for your data to be erased, then we will confirm whether this can take place and the next steps that we will take. If we cannot erase your data, we will explain why and confirm any actions required to allow us to do so.
Restrict processing of your data
If you make a restriction request, we will still store a copy of your data but we cannot use this. We will inform you if the restriction needs to be lifted. You can make this request by email. If you request for your data to be restricted, we will confirm whether this can take place and the next steps that we will take. If we cannot restrict your data, we will explain why and confirm any actions required to allow us to do so.
Object to processing of your data
You can object to the processing of your data at any time. You have an absolute right to object to the processing of your data for direct marketing purposes. You may also object to the processing if we are using your data in relation to our legitimate interest. If you object, we will no longer process your data unless we have a compelling and legitimate reason not to do so. In this case, you will be informed why we cannot stop processing your data.
You can request for us to transfer your data to another data controller, where we are processing your data with your consent or in accordance with a contract. This will only apply to information which is processed by automated means (e.g. by a computer). Where feasible, we will send your data directly to another data controller.
In exercising any of your rights, we will endeavour to act without undue delay but no later than one month. We may need to confirm your identity before completing any action on your behalf and reserve the right not to complete any action until we are satisfied that you, or an authorised representative, is making the request. If we cannot complete your request, we will inform you within one month and explain why.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can make a complaint to the UK Supervisory Authority, the Information Commissioner’s Office (ICO). You can contact the ICO through their website: https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.
All of the above should be made in writing to the Kate Craven who will make a written response setting out any contractual obligations that have been entered into and may imply any relevant exemptions.
Data subject rights may be limited, for example; whereby fulfilling the data subject request may expose personal data about another person, or if we are asked to delete data which we are required to keep by law.
How to contact us?
If you have any questions or concerns about our privacy practices, your personal information, or if you wish to file a complaint, please make contact in writing to your event facilitator in the first instance and then Kate Craven:
or postal mail: The Old Dairy The Avenue, Peplow, Market Drayton, Shropshire, England, TF9 3JL