The EU's General Data Protection Regulations (GDPR) entered into force on 25 May 2018. This has provided us with the opportunity to review our practices and ensure that your personal data is safeguarded to meet the Regulations' requirements. The privacy notice below tells you what information we may hold about you, how it is managed and how you can contact us.
Roger Lane Consulting Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and suppliers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Roger Lane Consulting Ltd.
Private Limited Company, registered in England under company number 06076689.
Registered address: Penshurst Cottage, Leigh Road, Havant, Hampshire, PO9 2ET.
VAT number: GB 903 8060 46.
Data Protection Officer: Roger Lane.
Email address: firstname.lastname@example.org.
Telephone number: +44 (0)23 9249 2603.
Postal Address: Penshurst Cottage, Leigh Road, Havant, Hampshire, PO9 2 ET.
2. What Does This Notice Cover?
This Privacy Information Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to profiling. Part 6 explains more about how we use your personal data for profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
· Age and/or Date of birth;
· Race, where applicable;
· Email addresses;
· Telephone number;
· Business organisation name;
· Job title;
· Payment information;
· Next-of-kin name and contact details for emergency contact procedures.
· Links to other personnel in your organisation or other professional connections.
· Facebook, Twitter and Skype contact details.
· Curriculum Vitae, provided by potential suppliers or customers.
Your personal data is obtained from the following third parties:
· From potential suppliers and customers;
· Providers of marketing databases;
· Business partners and our pool of subject matter experts for providing solutions for your business needs.
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
· Providing and managing your account, including payment of services and goods.
· Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
· Personalising and tailoring our products and services for you.
· Communicating with you. This may include responding to emails or calls from you. We may make notes of the records of conversations or teleconferences to provide our services to you.
· Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by replying to an email with “GDPR – UNSUBSCRIBE” in the email subject heading.We may use your personal data on the grounds of legitimate business interest, which is to promote the services Roger Lane Consulting Ltd to those who are reasonably likely to have decision-making and/or budgetary responsibilities related to their professional role. We conduct a "legitimate interest assessment" prior to conducting marketing campaigns which documents the assessment of 3 tests: the Purpose Test; the Necessity Test: and the Balancing Test as a precursor to authorising any campaign.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, phone, or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam and we do not sell our contact lists to third parties. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated systems for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
· The following automated profiling may take place:
o Use of psychometric and neuro-science based profiling tools, such as TMSDI, PRISM or Risk Compass, in which clients complete an online questionnaire which then produces an automated profile. The latter is owned by the client, and we are subject to strict ethical guide-lines as to how the profile may be used. Profiling is offered as part of our coaching services, and may be for individuals or teams. No profile maps or other content will be shared with other members of a team, without the explicit written consent of the individual. Transmission of the profile to the individual will only take place when they have verified their email address and provided their consent.
o SenseMaker is an application used to capture micro-narratives for clients that enables powerful insights into business performance, such as organisational culture or whistle-blowing, for example. Each application is customised for the client, and is likely to contain ethnographic information, such as gender, race or age, but does not contain individual names or contact details. The purpose is to provide services to clients. Individuals retain control of what content they input into the application, and this may include voice recordings, images as well as text. Content is sent to Cognitive Edge’s servers, which provide us the means to downloaded the data for analytical purposes.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The following factors will be used to determine how long it is kept:
· The time since the last communication with the individual for: names, email and postal addresses; phone and business contact details;
· The sales cycle for our different products and services.
· Any indication of subsequent requirement by a client or supplier for data retention in order to provide products or services.
8. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
· Limit access to the Customer Relationship Management software to a single, named user.
· Access to the Customer Relationship Management software is password-protected.
· Where wifi connections permit, we transmit and receive emails and attachments using Wifi Privacy software which provides mobile VPN protection that helps to keep personal data safe from hackers and identity theft on public hotspots.
9. Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply products and/or services to you on our behalf. These may include preparation of tender documents and the design, development and delivery of solutions. In some cases, those third parties may require access to some or all of your personal data that we hold.
· Comprehensive Training Solutions (CTS) International, Postboks 6537, 4087 Gausel, Norway is our leading business partner, and we share information to permit joint proposals to design, develop and deliver solutions for clients.
· Nusura Inc, 4101 E Louisiana Avenue #400, Denver Colorado 80246, USA, to enable bid preparation, design, development and delivery of solutions for clients.
· C4i TrgTech, 2723 37th Ave NE, Unit 119, Calgary, Alberta T1Y 5R8 Canada to enable bid preparation, design, development and delivery of solutions for clients.
· Individual supplier Subject-Matter Experts who support bid preparation, design, development and delivery of solutions for clients.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8. We are currently negotiating EU standard model clauses with these third country partners, in order to provide the appropriate level of safeguards.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. Please send an email with “GDPR- Subject Access Request Form” in the header to be sent the form.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. You will be informed of the administrative cost before processing the request, in case you wish to cancel the request.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, our aim is to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Roger Lane:
Email address: email@example.com.
Telephone number: +44 (0)23 9249 2603.
Postal Address: Penshurst Cottage, Leigh Road, Havant, Hampshire, PO9 2ET, England.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website.