PRIVACY POLICY
Introduction
Inoji Limited (Inoji) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).
About us
Inoji is a business consultancy providing leadership development, talent management, and coaching services.
In providing these services Inoji acts as a "data controller" for the purposes of GDPR. This means that we are responsible for deciding how we hold and use the personal information we hold about you.
We are required under data protection legislation to notify you of the information contained in this privacy notice.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
How your personal information is collected
We collect the personal information about you in the course of providing services to you or when dealing with enquiries.
Personal information may be collected when you: complete a survey or test; have a coaching session; in the course of a training event ; subscribe to our newsletter; or use the contact page on our website (https://www.inoji.co.uk). In addition, personal information may also be collected from staff at your organisation.
Please refer to our separate Cookie Notice in respect of the use of our website.
The kind of information we hold 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 which has been pseudonymised or anonymised to the extent that the individual can no longer be identified (anonymous data).
In general, we may collect, store, and use the following categories of personal information about you:
· Personal contact details you supply in your enquiry such as name; title; address; telephone number; business and personal email addresses; company/organisation name or workplace; and IP address.
In relation to specific programs Inoji is contracted to run, you may be required to complete a survey questionnaire, or a psychometric test which may include the following categories of personal information:
· Name, Organisation, Role, Date of Birth, Length of Time in Role, Survey or Test Responses, Email address and IP address.
Other categories of personal information include:
· Coaching notes and Personal feedback.
How we will use information about you and the legal basis for processing your data under the GDPR
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. For the performance of a contract to which you, or your organisation, is a party.
2. 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.
3. Where we need to comply with a legal obligation.
Situations in which we will use your personal information
The situations in which we will process your personal information are listed below.
(i) Performance of a contract with you
We process your personal data because it is necessary for the performance of a contract to which you, or your organisation, is a party. In this respect, we use your personal data for the following:
· To ensure we meet any and all legal obligations with regards to the service we provide to you, or your organisation, for the duration of your consultancy contract.
· To administer and fulfil requirements as agreed in the contract and any related terms and conditions.
(ii) Legitimate Interests
We process your personal data because it is necessary for our, or a third party's, legitimate interests. In this respect, we use your personal data for the following:
· To respond to your enquiry.
· To provide you with the information and services that you request from us.
· Assessing a particular consultancy project.
· To request feedback on services provided.
· For the purposes of research and statistical analysis and benchmarking.
· To ensure the information we hold about you is up to date and accurate.
(iii) Legal Obligations
Your personal data will also be processed by Inoji for compliance with the Inoji's legal obligations. For example:
· For the prevention and detection of crime, and in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
Some of the above grounds for processing may overlap and there may be several grounds which justify our use of your personal information.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data sharing
We may share your personal information with third parties where it is: required by law; necessary to administer the relationship with you; with your consent; or where we have another legitimate interest in doing so.
Third parties we may share your personal information with include:
· Providers of IT services, such as for email and cloud backup.
· Online services for surveys and psychometric tests.
· Contractors where there is a legitimate reason for their receiving the information.
· Auditors; professional advisors; or a Court, government body, law enforcement agency or other authority when we are required to do so.
All third parties are required to take appropriate security measures to protect your personal information and comply with GDPR.
Your personal data may be transferred outside the EU, such as to a data centre in the US. If so, you can expect a similar degree of protection in respect of your personal information.
A third party may also be a “data collector” under GDPR and will have their own privacy notice, such as an online psychometric test platform. In these circumstances we encourage you to also read their Privacy Notice.
Data security
We have put in place appropriate security measures to protect your personal information including:
· The use of encryption and password protection
· Regular backups and software patch updates
· Checking third party compliance to GDPR.
· Secure storage of sensitive documents.
· Training, policies, and research.
We have put in place procedures to deal with any suspected data security breach and will notify you, and/or your organisation, and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
We will only retain your personal information for as long as:
· It is likely to be useful to you or your organisation;
· Our relationship has ended with you or your organisation;
· As specified by our contract with you or your organisation; or
· For the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you, i.e. for benchmarking.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
· Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing.
· Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal information to another party.
Contact and complaints
The Information Commissioner’s Office (ICO) recommends you seek to resolve any issues with the data controller initially prior to any referral to it. If you have any queries about this privacy notice or how we process your personal data, or if you wish to exercise any of your rights under applicable law, you may contact us by email at: fiona.moore@inoji.co.uk
Generally, you will not have to pay a fee to access your personal data or to exercise any of your rights, however we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. 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.
You can contact the ICO on 0303 123 1113 or https://ico.org.uk/concerns/.
Document last updated: October 2020