This notice is governed by the EU General Data Protection Regulation (GDPR) from 25 May 2018.
We aim to be as clear as possible about how and why we use personal information about you
The contact name for all matters relating to privacy and GDPR is: Maggie Mosley, Director
- Personal data we collect
PMSL collects any details provided to us through our website or collected through other means such as in person, by an online form, email, or telephone communication.
PMSL may collect and process the following personal data about you:
- For individuals associated with our customers, we may hold contact information such as names, email addresses, phone numbers, addresses and job titles and/or specific roles within your organisation (Customer Contact Information).
- For individuals associated with our suppliers and other third parties that we interact with, we may hold contact information such as names, email addresses, phone numbers, addresses and job titles and/or specific roles within your organisation (Supplier Contact Information).
- A record of any correspondence or communication between you and us and any information we may require from you when communicating with you (Communication Information).
- We will collect information either from you directly or from a third party (e.g. your employer or an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
- You do not have to supply any personal information to us but we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data.
- Other websites
We cannot be responsible for the privacy policies and practices of websites that are not operated by us, even if you access them via our website, or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
- Use of your information
We may use your information to provide and personalise our service. We may also use your contact details to communicate with you. We may use your information to send you offers and news about PMSL products which we think may be of interest to you. We may contact you by post, email or telephone.
- Sharing your information
We will NEVER sell your information and we do not disclose any information you provide, to any third parties other than as follows:
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime)
- In order to enforce any terms and conditions or agreements for our services that may apply
- If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services
- We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected
- To protect our rights, property and safety, or the rights, property and safety of our customers or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
- Legal basis on which we process personal data
Personal data we hold about you will be processed either because:
- Performance of contract: the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision of our services; or
- Legitimate interest: the processing is necessary in pursuit of a ‘legitimate interest’. A legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
- Processing of data
We collect and process data for two main purposes:
- Legitimate interest
- Performance of contract
We use individuals’ names, email addresses, telephone numbers, addresses to maintain contact with people who:
a) we are currently providing a service to
This list can include commissioning HR Managers (usually our key point of contact), delegates on a development programme (those in direct receipt of our services), PAs/ administrative assistants (with whom we organise meetings and schedule events), Facilities Managers/ Receptionists (with whom we make visiting arrangements).
b) we have conducted business with in the past
c) have expressed an interest in us or our services
This can include people who have received our services, who we have met (e.g. at a networking event or conference) and who have asked to be kept informed of our services.
This data is kept for a period of time commensurate with its need (see 7. Data retention).
We believe this data is exactly what people would reasonably expect in order for us to provide them with information and services, maintain communication channels and which has a minimal privacy impact on them.
Performance of contract
We may hold additional data as part of our performance of live contracts. This includes:
a) notes about a client organisation’s history, current challenges, culture, current training budget
b) coaching session notes for the purpose of developing coachees and assisting their coach in providing a professional service
c) homework that delegates have completed as part of their development
d) emails from people that enquire about topics they are learning, administrative issues, or about wider service issues
- Data retention
We will delete or destroy the personal data we hold about you as follows:
|Type of personal data||Length of retention|
|Records relevant for tax and customers authorities||8 years from the end of the year to which the records relate.|
|Personal data processed in relation to a contract between you and us||7 years from either the end of the contract or the date you last used our services, being the length of time following a breach of contract in which you are entitled to make a legal claim.|
|Personal data held on marketing or business development records||3 years from the last date on which a data subject has interacted with us.|
For any category of personal data not specifically defined above, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please refer to clause 8 below, which explains your privacy rights.
- Individual rights
You have a right to access the personal data that is held about you. To obtain a copy of the personal information PMSL holds about you, please email us at firstname.lastname@example.org.
Individuals have certain rights in regard to their personal data:
The right to be informed
You have a right to know about our personal data protection and data processing activities; details of which are contained in this notice.
The right of access
You can make a Subject Access Request (SAR) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below. On receipt of such a request we will endeavour to respond to you as soon as possible, but at least within one calendar month.
The right to correction
Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure (the right to be forgotten)
Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data and we may need to keep your data in some circumstances). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing
You can request that we no longer process your personal data in certain ways, but not require us to delete the same data. However some of our services will not be available if processing is restricted.
The right to data portability
You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object
Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will cease such processing.
Rights with respect to automated decision-making and profiling
You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
The right to withdraw consent
If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).
All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to The Data Protection Officer, PMSL, 12 Cromford Road, London, SW18 1NX, email: email@example.com
We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
- Protecting our servers with software firewalls
- Locating our data processing storage facilities in secure locations
- Encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered
- When necessary, disposing of or deleting your data so it is done so securely
- Regularly backing up and encrypting all data we hold.
- We will ensure that our employees are aware of their privacy and data security obligations.
- We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
- This notice and our procedures for handling personal data will be reviewed as necessary.
- Data breaches
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner within 72 hours of becoming aware of such a breach.
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
- Notification of changes to the contents of this notice
We will post details of any changes to our policy on our website, to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
- Contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following address: The Data Protection Officer, PMSL, 12 Cromford Road, London, SW18 1NX, email: firstname.lastname@example.org
- Right to judicial review
Individuals have a right to complain to the Information Commissioners Office (ICO) if they think there is a problem with the way PMSL is handling their data.
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.