Protecting your privacy

This Privacy Notice explains the types of personal data that Markovits Consulting Ltd may collect about you during our interactions. It also explains how we will keep your data safe and private. We are committed to protecting your privacy and we comply with the UK Data Protection laws.

From time to time we will need to update this Privacy Notice. You will always be able to access the latest version of our Privacy Notice on our website.

Who we are and important information Markovits Consulting Ltd is an independent leadership, coaching and people development consultancy. You can find out more about us at www.markovitsconsulting.co.uk

This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide through this website when you use our contact form. This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Data controller(s)

Markovits Consulting Ltd is the controller and responsible for your personal data (collectively referred to as “Markovits Consulting”, “we”, “us” or “our” in this privacy notice). Our contact details are 156 Hatfield Road, St Albans, Hertfordshire, AL1 4JD. For all data matters contact Anna Markovits on anna@markovitsconsulting.co.uk

Third-party links outside of our control

This 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.

What information do we collect about you? Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including First Name/Last Name/Title/Gender.
• Contact Data including Email Address, Job Title, Company/Organisation, Location, Phone Number and Billing Address.

This is so we are able to contact you about work that we are doing for you. If we are facilitating a programme for you, we may also collect additional data, such as individual information and results for personality profiling exercises. Where we have agreed with you, we may also take photos during events, which may include photos of the people attending.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How do we collect your personal data? We may collect personal information about you, or your company, when you contact us through:

• Emails or letters you send to us;
• Meetings we have with you;
• Telephone calls we have with you;
• When you use our website;
• When you use third party websites for work we are doing with you (see further information about this in the ‘Who do we share your personal data with?’ section below).

Why do we collect information about you? 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:

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. For example, when you complete an online personality profiling questionnaire for a team development exercise. Or, when we take photos during a training event. We will only ever collect the personal data which is needed for the exercise, and won’t collect any additional information unnecessarily.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). An example of a legitimate interest we might use would be processing your feedback about an event you attended with us.
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

How do we use information about you?

• To contact you about training, events, or coaching that we are providing for you. We do this on the basis of the performance of the contract.
• To respond to your queries. We do this on the basis of the performance of the contract.
• To contact you with additional information relating to content from events that we have already run for you or have discussed with you. We do this on the basis of the performance of the contract.
• To provide you with individual personality profiling reports such as the Myers-Briggs Type Indicator, the Strength Deployment Inventory or the Fundamental Interpersonal Relationship Orientation – Behaviour reports. We do this on the basis of the performance of the contract.
• To send you feedback / survey requests to help improve our services. We do this on the basis of our legitimate business interests.
• To help improve the training, events and coaching that we provide for you, by using any evaluation information you share with us. We do this on the basis of our legitimate business interests.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests.
• To promote the services that we can provide to customers, on our website or on social media. For example, we may use photos from events we have run. If our photos include identifiable people, we will only ever use these with your permission. We do this on the basis of our legitimate business interests.
• To comply with our contractual obligations to share data with law enforcement.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who do we share your personal data with? We sometimes share your personal data with trusted third parties. We have ensured that the third parties we work with are GDPR compliant, have their own privacy notices, and that they dispose of your personal data appropriately following the service they have provided to ensure that your privacy is respected and protected at all times. We only provide them with information they need to perform their specific services.

Third parties we work with include:

• Business psychology and training providers, who provide online personality profiling questionnaires and reports, such as the Myers-Briggs Type Indicator, which we may use with you in your training or coaching.
• Professional advisers including lawyers, bankers, auditors and insurers.
• IT companies who support our IT software and hardware.
• Printing companies who print reports and resources we provide you with during training, events or coaching.
• Accounting companies who provide our electronic accounting system and services.
• HM Revenue & Customs, regulators and other authorities as required by law.

We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Where do we transfer your data? Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. If we do transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA;
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA;
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.

You can find out more on the European Commission Justice website.

How do we keep your data secure? 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 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.

Please be aware that no internet or email transmission is ever fully secure or error free, and we ask you to take special care in deciding what personal data you send to us via email or disclose via the internet.

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.

How long will we keep your personal data? 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. At the end of that retention period, we will either delete your data completely or anonymise it, for example by combining it with other data so that it can be used in a way that can no longer be associated with you for statistical purposes or business planning. For the majority of the data we hold, we will retain the data for two years following the end of the relationship with you, at which point we will minimise the data and keep basic information (including contact, identity, financial and transaction data) for a six years after you cease being a customer, for tax purposes and so we can comply with our legal and contractual obligations.

Your rights over your personal data Unless subject to an exemption under the data protection laws, 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 your 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 our processing is based on consent or is necessary for the performance of our contract with you or where we process your 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 our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

You can contact us to request to exercise any of your rights in relation to personal data at any time by emailing anna@markovitsconsulting.co.uk.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

Further Information This version was last updated on 23rd May 2018. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact anna@markovitsconsulting.co.uk

If you feel that your data has not been handled correctly, you have the right to lodge a complaint with the Information Commissioner’s Office: www.ico.org.uk/concerns