Etheo Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.
1. Information About Etheo Limited
Etheo Limited is a company registered in England and Wales under the number 11115064 and whose registered office is at 19 Skipps Meadow, Buntingford, Hertfordshire, SG9 9FP
Data Protection main point of contact: Rebecca Godfrey
Email address: firstname.lastname@example.org
Telephone number: +44 (0) 7974 787 464.
2. What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that I use is set out in Part 5, below.
4. What Are Your Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about my collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact me using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about my use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do We Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with me):
· Email address;
· Telephone number;
· Business name;
· Job title;
· Myers Briggs Type Indicator (MBTI) report.
From time to time we may take photographs or video footage to document our workshops or programmes which will be used online (on our website and/or social media accounts), for the purposes of sharing our work with external audiences. We shall always do our upmost to ensure all participants are informed in advance of the photography/filming taking place and the use of their images. All participants shall be given the option to refuse to be photographed and/or filmed whilst they take part in the event. All such refusals shall be respected and adhered to.
In our workshops using LEGO® SERIOUS PLAY® we may, if requested by the client, take a video clip of the story of the shared model. Such videos shall not contain the faces or names of participants but will include the voice of the person telling the story. Such videos shall only be used in order to provide a transcript of the model and therefore shall only be used for internal use at Etheo Limited. On such occasions only those comfortable with being recorded for this purpose shall be recorded, if none of the participants wish to volunteer for such a recording, Etheo Limited will arrange for alternative solutions to capture the story of the model.
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
· Supplying our services to you. Your personal details are required in order for us to enter into and to fulfil a contract with you or your organisation.
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us using the details provided in Part 11)
As mentioned in Part 5, on occasion photography or filming of workshops may take place in order to document and share our work to external audiences. Such material shall be used online, on our website and social media accounts, to share examples of our work.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Details of our retention periods for data are included in our Data Retention Policy which can be provided upon request.
8. How and Where Do You Store or Transfer My Personal Data?
We will store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that this storage of personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
Through our use of certain systems, we may also store or transfer some or all of your personal data to countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. In all such instances we ensure safeguards are in place to protect your data. Such systems include:
· Our Gmail email system (@etheolimited.com) where data may be stored outside of the EEA. In terms of location Google advise that “data will be stored in Google's network of data centers. Google maintains a number of geographically distributed data centers. Google's computing clusters are designed with resiliency and redundancy in mind, eliminating any single point of failure and minimizing the impact of common equipment failures and environmental risks”. Google assures customers of their compliance with GDPR and that they provide “capabilities and contractual commitments created to meet data protection recommendations provided by the Article 29 Working Party.” The Article 29 Working Party (Art. 29 WP) is an advisory body made up of a representative from the data protection authority of each EU Member State, the European Data Protection Supervisor and the European Commission. Etheo Limited has reviewed and agreed to EU Model Contract clauses for G Suite.
· If you, or your organisation on your behalf, requests Myers Briggs Type Indicator (MBTI) as part of the services we provide, we will request name and email addresses for those involved in the MBTI sessions (respondents). We will enter these details into the Etheo Limited OPP Assessment profile which allows the system to contact respondents with the login details for their questionnaire. Respondents may then complete their questionnaire within the OPP Assessment system and the report will be provided to us via and stored within OPP Assessment. The Myers Briggs Company Limited, owners of the OPP Assessment system, is a UK based company however they advise that they may transfer personal data outside the EEA and to any third party located outside the EEA (including to their parent company, The Myers-Briggs Company, in the US) where they are permitted to do so for that transfer under Articles 44 to 49 of the GDPR. The Myers-Briggs Company advise that they are permitted to transfer personal data outside the EEA and to such third parties located outside the EEA as set forth in the List of Third Parties and Transfers ex-EEA, provided the appropriate safeguard mechanisms remain in place. Etheo Limited has entered into a Data Processing Agreement with The Myers-Briggs Company (previously named OPP Limited)
· Etheo Limited makes use of the Pipedrive platform for Customer Relationship Management. Pipedrive have ensured that any data stored outside of the EEA is adequately protected even after it leaves the EEA. They do this by making sure that their third-party service providers have either certified under the EU-US Privacy Shield framework or signed the EU Commission’s standard contractual clauses for data transfers with Pipedrive. The Data Processing contract is written into the Terms of Service in place between Pipedrive and their clients as Data Controllers, i.e. Etheo Limited.
· Etheo Limited makes use of the Quickbooks accountancy platform (provided by Intuit Inc) for Invoice and payment management. Invoices and receipts may contain personal information of those listed as points of contact in these documents. Intuit’s main data storage locations are in the USA. However, as a global company, data are accessed from various locations by their global teams and partners. Intuit have drawn into their Terms of Services Data Processing provisions with their clients, including Etheo Limited. Intuit certify to the EU-US Privacy Shield scheme for their use of personal data in the USA, and they apply guidelines and practices to protect all personal information, including the E.U.U.S. Privacy Shield Principles. When it comes to their partners, Intuit’s practice is to put contractual terms in place to ensure they follow Intuit’s instructions and have appropriate security in place to protect the personal data entrusted to them.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
· Only encrypted laptops and hard drives are used;
· 2 step verification access is used for email access;
· All passwords used are unique and only know to the specified user;
· Malware protection is employed on all computers used for Etheo Limited business;
· Hardcopy documentation storage is kept to a minimum, and where hard copy documents are used these are stored in locked cabinets.
In addition, to ensure GDPR compliance, we enter into Data Processing Agreements with any company processing data on our behalf.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
i) In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
ii) We may sometimes contract with third parties, such as off-site event venues, virtual assistants or OPP, to supply services to you on our behalf or to professional advisors, such as legal and accountancy firms, to support our business activities, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
Rebecca Godfrey, Managing Director, is the Data Protection main point of contact for Etheo Limited. To contact Rebecca about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com
Telephone number: +44 (0) 7974 787 464
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. When updates to this policy are made, all efforts will be made to provide those impacted with a copy of the updated document.
This Privacy Notice has been approved and authorised by:
Dr Rebecca Godfrey
18 February 2019