We’ve tried to keep this policy as user friendly as possible, but it does need to include a lot of things. There are some key terms at the end of the document that I hope are useful. Any questions, please email: firstname.lastname@example.org
This policy explains how we collect, store, use and share Personal Data. It also outlines your rights under the GDPR law, including the rights for access to the data we hold.
The Data Controller for the purposes of the GDPR is:
Mike Roarty, Director, Strengths Focused Leadership Ltd.
Website: www. sfleadership.co.uk
You may, at any time, contact us with any questions or suggestions regarding data protection or this policy, to exercise any of the rights outlined below, or to make a request to access your data. We will provide the details securely, free of charge and within a maximum of one month, unless there is any legal reason why we must not.
If at any time you wish to opt out from receiving any communication from Strengths Focused Leadership, then please contact Mike directly on the details above. Any promotional emails we send you will also have the option to unsubscribe.
We have physical, electronic, administrative and managerial procedures in place to safeguard and secure the information we collect from you to protect your Personal Data against accidental, unlawful or unauthorised disclosure.
LAWFUL BASIS FOR COLLECTING AND PROCESSING PERSONAL DATA
Strengths Focused Leadership has to have a lawful basis for collecting and processing your Personal Data as set out in Article 6 of the GDPR. The reason we believe we have the right to gather and use your data is that we have a legitimate interest in doing so for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
What this means in practice is that we use the data that you share with us so that we can carry out our work with you and provide you with the services that you have asked us to. Without this data it would not be possible to do this, and so we believe our need for the data is legitimate. You are therefore under no contractual or statutory obligation to provide this data, but without it it may not be possible for Strengths Focused Leadership to work with you.
COLLECTION OF PERSONAL DATA
We may collect Personal Data about you in ways that may include the following:
When you provide it to us: e.g. where you select the “contact us” option on our website, send an email or leave a phone message or text asking us to get in touch.
When you access the ‘Downloads and Videos’ section of our website and register your details. You have a choice of whether or not your want us to send you further promotional materials and we don’t assume that you do unless you actively choose to say ‘yes’ to it.
In the ordinary course of our relationship with you, for example when providing coaching or some other development activity.
When you give us your name and date of birth for registering you on an ILM qualification programme.
CATEGORIES OF PERSONAL DATA
The categories of Personal Data about you that we may collect and process include:
Personal details: given name(s); preferred name; gender; date of birth / age
Contact details: telephone number; email address; and any social media profile details
Professional details: professional profile details; association memberships; qualifications
Device details: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our Site and other technical communications information
Payment details: billing address; bank account number: accountholder name
Usage details: records of your use of our website and other services, including: registrations; details of content with which you interact; votes; questions; downloads; ratings; feedback; profile views; search queries; anonymous viewings; page views; player clickstream; chapters; and favourite moments
Analysis data: keywords, communities, trends, content quality and content importance
Views, opinions and interests: any comments, ratings, views or opinions that you choose to send to us, post via our website, via a survey, or publicly post via social media platforms
PURPOSES FOR WHICH WE MAY PROCESS YOUR PERSONAL DATA
To help us deliver the services that you have asked for, the way we may process Personal Data, subject to applicable law, could include:
Provision of services to you: providing our services and website access to you; communicating with you in relation to those services; recommending content that may be of interest to you; and recommending your content to others
Our Website: operating and managing our website; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our website
Marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) about our services and providing other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law
Communications and IT operations: management of our communication systems; operation of IT security; and IT security audits
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations
Financial management: sales; finance; invoicing; and vendor management
Surveys: engaging with you for the purposes of obtaining your views on our services or our website
Improving our website and our services: identifying issues with our services or our website; planning improvements to our services or our website; creating a new service or website
The criteria for determining the duration for which we will keep your Personal data are as follows:
We will retain copies of your Personal Data, in a form that permits identification, only for as long as is necessary in connection with the purposes set out in this Policy
With ILM qualifications your name, date of birth and gender need to be held for 7 years
All training, coaching and supervision notes will be kept for a maximum of 36 months after finishing working with you and then be securely destroyed
This will be the case with this and any other data unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
We will not share your details with anyone who is not directly connected to or providing a service to/for Strengths Focused Leadership. All third parties providing a service to us (for example the organisation who manages and hosts our website) will be required to adhere to the requirements of the GDPR.
INTERNATIONAL TRANSFER OF PERSONAL DATA
We will not transfer your Personal Data to other countries outside the UK.
PROCESSING YOUR SPECIAL CATEGORY DATA (SENSITIVE PERSONAL DATA)
We do not seek to collect or otherwise Process your Special Category Data, except where:
the Processing is required or permitted by applicable law (e.g. to comply with our diversity reporting obligations);
the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
the Processing is necessary for the establishment, exercise or defence of legal rights; or
we have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your Special Category Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Strengths Focused Leadership does not work with people under the age of 18 and they are not eligible to use our website. We therefore ask that minors do not submit any Personal Data to us, or use any of the services provided on, through or via our website.
We take every reasonable step to ensure that:
your Personal Data that we Process is accurate and, where necessary, kept up to date
any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it is Processed) is erased or rectified without delay
From time to time we may ask you to confirm the accuracy of your Personal Data.
We take every reasonable step to ensure that your Personal Data that we Process is limited to that which is reasonably required in connection with the purposes set out in this Policy.
YOUR LEGAL RIGHTS
Subject to applicable law, under GDPR you have rights regarding the Processing of your Personal Data, including:
The right of access to your personal data and supplementary information and for us to be aware of and verify the lawfulness of the processing
The right to rectification if your personal data is inaccurate or incomplete
The right to erasure, also known as ‘the right to be forgotten’, enabling you to request the deletion or removal of personal data where there is no compelling reason for its continued processing
The right to restrict processing of your personal data, enabling us to store the data, but not further process it, ensuring the restriction is respected in future
The right to data portability, allowing you to obtain your data securely and reuse it for your own purposes across different services, without hindrance to usability
The right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
Rights related to automatic decision making and profiling and if applicable give you information about the processing, introduce simple ways for you to request human intervention or challenge a decision and carry out regular checks to make sure that our systems are working as intended.
This does not affect your statutory rights.
You have the right to escalate a complaint to the Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf. The Authority for this is the Information Commissioner’s Office, who can be contacted at, email@example.com
‘Controller’ means the person that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws
‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws. In the UK this is the Information Commissioner’s Office (ICO)
‘Personal Data’ means information that is about any individual, or from which any individual is identifiable
‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying
‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
‘Special Category Data’ means Sensitive Personal Data about race or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life or sexual orientation, genetics or biometrics, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.