Who is responsible for your personal data?
Lisa Westbury, Co-Founder at Generate, is registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 1998 or any subsequent UK legislation resulting from EU General Data Protection Regulations (GDPR).
Where is your personal data stored?
All the personal data we have is stored on our database in the UK. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to and processed by third parties outside of the EEA for the purpose of assessment services such as psychometric or self perception tools.
It may also be processed by one of our suppliers. This includes web hosting services and the provision of marketing services (such as ‘Mailchimp’). By submitting your personal data, you agree to this transfer, storing or processing. Generate will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
The information we collect and how we use it
We collect information that you give us when filling in forms on our website (www.generatepartnership.co.uk), subscribe to our services or mailing list, attend our events, participate in a survey or complete a feedback form or by corresponding with us by phone, e-mail or by giving us your business card.
If you engage us to provide coaching/ organisational development services, we may also with your permission, hold notes taken during coaching sessions/research interviews/events on paper and electronically.
As a client, your personal details may include your name, address, private and business e-mail address and phone number; financial information; curriculum vitae and photograph; assessment or exercise responses, and links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
This information may be held and used by us for some or all of the following purposes:
- To assist us in providing you with our services
- For purposes of Continuing Professional Development : name, e-mail, address and number of coaching hours for continued professional coach accreditation
- Anonymised issues may be discussed with your coach’s supervisor
- To improve our customer service and make our services more valuable to you;
- To notify you about upcoming events, news and offers when you have granted us permission to do so;
Information we obtain from other sources
This is information we obtain about you from other sources such as LinkedIn, your business card or personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data, of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
Disclosure of your information
We will share your information responsibly with selected third parties including:
- Marketing and technology platforms and suppliers Mailchimp and SurveyMonkey
- Providers of assessments, psychometrics and other relevant tests that you decide you wish to take as part of a training or development programme.
These suppliers have their own privacy policies on their websites which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
We may disclose your personal information to third parties where we are legally required to do so
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- The nature of the personal data;
- Its perceived accuracy;
- Our legal obligations;
Depending upon the criteria used as to whether we should retain your information we may:-
- Retain your personal data (first name, last name, email address, start and end date of the coaching programme, number of coaching hours received) on a coaching log
- Retain your personal data (name and address) on copies of the invoices we have sent to you for as long as required by HMRC.
- Retain your personal data (first name, last name, email address) on a Mailchimp mailing list if you have opted-in to receiving marketing information from us.
All other client information and data collected during a coaching programme whether held on paper or electronically, will be destroyed on completion of your coaching programme.
What are your rights?
You have the right to ask us not to process your personal data for marketing purposes. From May 25th 2018 we will always obtain your consent before we use your data for such purposes. You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data.
You have the right to request information about the personal data we hold on you at any time. If you would like to make a request for information please email firstname.lastname@example.org
You have the right to request modifications, updates or removal of your data. We may ask you to verify your identify and for more information about your request.
How do we protect your personal data?
We endeavour to take all reasonable steps to protect your personal data but cannot guarantee the security of any data you disclose online. You accept the inherent security implications of sending information over the Internet and will not hold us responsible for any breach of security unless we have been negligent.
All information you provide to us is stored on our secure password protected systems; with a robust firewall. We take all reasonable care to avoid clicking on potentially malicious links or attachments to ensure risk from phishing and other malware is minimal.