Value Partnership LLP (“Value Partnership” or “we” or “us”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tells you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data. This version was last updated on 21st May 2018.
Data Privacy Manager
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Value Partnership LLP (Limited Liability Partnership)
33, St James’s Square, London. SW1Y 4JS
Jane Court, Business Manager – email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The list below is not exhaustive. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, title and your job title.
• Contact Data includes billing address, postal addresses, email addresses, Skype ID, telephone numbers.
• Usage Data includes information about how you use and satisfaction with our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Contracting includes terms and conditions upon which you contract with us.
• Other personal Data Depending on the service we are providing to you or your company, we may also ask for more detailed information about your employment such as your length of employment and professional objectives or goals. This may include outputs from psychometrics and other assessment or feedback tools, interview notes as a result of diagnostic work, or interview notes for recruitment purposes. When receiving coaching from Value Partnership, information considered sensitive may emerge during the course of discussions with your coach. These relationships are bound by strict confidence, and any notes collated by your coach are treated accordingly.
Personal data we obtain is collected in a few key ways including:
• Data disclosed by an authorised third party (e.g. employer) on the individual’s behalf where your data is provided to us by an authorised third party such as your employer (for example, course delegate lists), it is the third party’s responsibility to ensure they have the correct lawful basis in place to share this data with Value Partnership.
• Direct interactions. You may give us your personal data giving us your business card, your Curriculum Vitae, by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you:
o ask us to work with you or talk to you about a particular topic;
o enquire about employment opportunities;
o give it to us as part of the work we are doing with you;
o subscribe to our service, publications or events;
o take part in our research;
o request marketing to be sent to you; OR
o are giving us feedback.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you, or the company you work for.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given your consent to the processing of personal data.
We will not share or sell your data with third parties for marketing purposes.
We will only share your data with third parties when necessary to provide a business service you or your company have requested, or if legally obligated to do so, or where you have given your consent.
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Most web browsers allow some control of most cookies through the browser settings.
Purposes for which we will use your personal data
Your data may be used for a number of purposes including, but not limited to:
• provide all the elements of the services we have been contracted to provide by yourself or your employer.
• assess the quality of our services.
• administrative activities.
• recruitment processes.
• legal obligations of our business.
• statistical and marketing analysis.
• customer surveys.
• customer relations communications.
• offering you services and products we believe may interest you.
You can ask us to stop sending you marketing messages by contacting us at any time.
4. Who has access to your personal data?
The data we collect about you is generally accessed only by authorised Value Partnership employees and consultants where necessary for legitimate business purposes and for providing services as part of our contract with you. However, if we work with partners or contractors, they may have limited access to your personal data but only so much to do their job or for legitimate business reasons.
The following outlines who has access to your personal data, and under what circumstances:
• All Members of Value Partnership LLP, consultants and employees who are involved in arranging and delivering the services you request.
• External Third Parties; for example service providers who provide our IT and administration services and those providers we use in the course of providing legitimate business services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data collected by us will be stored and processed primarily within the UK, but may be stored and processed in another country, including a country that is not in the European Economic Area (EEA). We will ensure that the data protection standards employed within the UK are observed by our partners with whom we need to share information in all of the countries they operate.
6. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
What we may need from you we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If we make substantive changes to this Policy, we will announce it on our website to ensure that you are aware of the information we collect and how we use it at all times.