gdpr: data privacy notice
for clients and suppliers
Summary of Data Privacy Notice
People Create Limited is committed to protecting and respecting your privacy. We take the security of our clients’ personal information seriously and our policies and operations comply with all relevant privacy and data protection laws.
We will not use any personal information for any unauthorised purpose and will keep all personal information secure. We will not share your personal information with third parties unless this is required to allow us to provide the services that are a necessary element of our contract and only where all parties comply with the relevant data protection and privacy laws.
We, People Create Limited, are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand who we are and how and why we collect, store, use and share your personal data. It also explains how we will treat it, your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”). This applies across the European Union (including the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
People Create Limited is the data processor. This means People Create Limited is responsible for processing personal data on behalf of a data controller.
People Create Limited registered address and contact details are:
For all data matters contact People Create using the contact details listed above.
3. The purpose(s) of processing your personal data
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We use your personal data for the following purposes:
- To facilitate communication with you when entering into and carrying out a contract
- To inform, but not limited to, coaching sessions, team meetings and workshops
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Contact details (details can include, name, job title, work email address, work address, mobile phone number and work phone number)
- Psychometric reports
- Notes on coaching sessions (typed or handwritten)
- Information to enable us to check and verify your identity, eg your date of birth;
- your billing information, transaction and payment card information
- information to enable us to undertake credit or other financial checks on you
We will either obtain contact details directly from you, a data subject or from a line manager, head of department or another person managing the contract within your organisation (see point 8). This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
☐ Consent of the data subject
|√ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract (See 3i & 3ii)||
|☐ Processing necessary for compliance with a legal obligation||N/A|
|☐ Processing necessary to protect the vital interests of a data subject or another person||N/A|
|☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller||N/A|
|√ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||
b) Special categories of personal data (article 9 of GDPR)
WE DO NOT PROCESS SPECIAL CATEGORIES OF DATA
6. Sharing your personal data
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
sanctions screening providers;
credit reference agencies;
- customer due diligence providers;
- from a third party with your consent
- via our IT systems, eg automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
7. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with People Create Limited unless apart from the companies we use to provide Automated Decision Making (please see section 11) consent has been obtained to share with other parties.
8. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary, see list below for the period of time and reason for retaining personal data.
|Purpose||Period of time|
|• Contact information to facilitate communication with you||This will be kept for as long as the working relationship exists. Contact details for invoicing purposes will be held for 7 years in accordance with HMRC requirements.|
|• Psychometric reports to inform coaching sessions and team meetings||These are not kept for 18 months after the completion of a contract in case you return for further coaching|
|• Notes to inform coaching sessions||All notes (handwritten or typed) are kept for 18 months after the completion of a contract in case you return for further coaching|
9. Where your information is held
Information may be held at our offices.
10. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing the data
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
- All requests have a month in which to be carried out.
11. Transfer of Data Abroad
We do not transfer any personal data.
12. Automated Decision Making
We use Firo-B, Myers Briggs Type Indicator and Hogan psychometric tools to inform coaching sessions and team meetings. You will complete the questionnaire independently and voluntarily. The psychometric testing company will use this data to generate a report. This report will only be shared with you, in complete confidence. People Create Limited will keep psychometric reports for 18 months, so that you may request a copy.
Firo-B, Myers Briggs Foundation and Hogan may store your data on their secure servers unless you request the deletion of your records, please refer to their Privacy Statements for further guidance.
https://www.opp.com/en/About-OPP/Privacy-Policy (Firo-B and Myers Briggs Foundation)
https://www.hoganassessments.com/privacy-policy/ (Hogan Assessments)
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
16. How to make a complaint
We hope that we can resolve any query or concern you may raise about our use of your information. To exercise all relevant rights, queries or complaints please in the first instance contact People Create Limited on [email protected].
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.