This policy relates to our use of any personal information you provide to us when you visit our website, by phone, SMS, email, in letters and other correspondence and in person.
Our context for data privacy is respect. We place a high priority on safeguarding confidential information and processing personal data in an ethical manner, and we take our responsibility for the security of customer and employee data very seriously. In order to carry out other business functions and to deliver our services, we rely on the following lawful conditions for processing personal data:
Consent – the individual has given their Consent to the processing of their Personal Data.
Contractual – processing of Personal Data is necessary for the performance of a contract to which the individual is a party or for AWA to take pre-contractual steps at the request of the individual.
Legal Obligation – processing of Personal Data is necessary for compliance with a legal obligation to which AWA is subject.
Legitimate Interests – processing is necessary under the Legitimate Interests of the AWA or an associated third party, unless these interests are overridden by the individual’s interests or fundamental rights.
We will be clear and transparent with you about which lawful basis is used when processing your personal data.
Collecting personal data
In order to deliver our services and to carry out necessary business functions, we may collect certain personal data from you in a variety of ways, such as, through our website, via email, an online portal, or verbally. These details may include (where applicable), names, contact information and basic employment details. Depending on the service we are delivering to you or your company, we may also ask for more detailed information about your employment such as the department or team you work in, your length of employment and professional performance goals. When receiving coaching/consulting/mentoring from AWA, information considered sensitive may emerge during the course of discussions with your AWA coach/consultant/mentor. These relationships are bound by strict confidence, and any notes collated by your AWA coach/consultant/mentor are treated accordingly.
Personal data we obtain is collected in a few key ways:
Data disclosed by the individual
Data disclosed by an authorised third party (i.e. employer) on the individual’s behalf
Data obtained from linked system or database
Data generated through user interaction with systems/services
Where your data is provided to us by an authorised third party such as your employer (i.e. in the form of course delegate lists), it is the third party’s responsibility to ensure they have the correct lawful basis in place to share this data with AWA.
The purposes of processing personal data
Your data may be used for a number of purposes including, but not limited to: to provide all the elements of the learning and development services we have been contracted to provide by yourself or your employer, contacting you in the event of a workshop time change or cancellation, to assess the quality of our services, administrative activities, crime prevention/detection (i.e. fraud), legal obligations of the business, statistical and marketing analysis, customer surveys, customer relations communications and offering you services and products we believe may interest you.
You will always be told what we intend to do with any personal data we collect from you, however the principal reasons are to:
support the delivery of contracted services and products, or
achieve our marketing and sales strategies.
More specifically, these may take the form of the below likely scenarios:
Individuals engaged with an AWA service as part of a development programme we are contracted to deliver.
When taking part in a service (e.g. diagnostic, survey, workshop) as part of a programme we are contracted to deliver, the information you provide will only be used for the stated purposes and/or those you consented to. This may include product research and development, administrative and legal purposes, statistical analysis, systems testing, or service maintenance and development. In this scenario, we would be relying on contractual necessity as the primary legal basis for processing personal data.
We may need to provide your personal data to an associate or independent practitioner authorised to deliver AWA services or a colleague in your organisation authorised to deliver AWA services if you are enrolled on a programme delivered by either party for learning and development. Either of these scenarios may involve transmitting your data to a different country.
User interactions with online services and resources such as our website, webinar registrations, or downloading white papers.
We may collect information to better understand how visitors use our website and interact with our marketing content, so we can offer timely and relevant information. When using our website to register for a webinar, or download a white paper, your data may be used for the following:
For our own internal records.
To improve the products and services we provide.
To contact you in response to a specific enquiry.
To customise our website for user needs and preferences.
To send you promotional emails about products, services, offers and other things we think might be relevant to you.
To send you promotional mailings or to call you about products, services, offers and other things we think might be relevant to you.
To contact you via email, telephone or mail for market research reasons.
In this scenario, we would be relying on legitimate interests and where required, consent, as the primary legal bases for processing personal data. AWA will only keep data for as long as is necessary to meet these purposes. The personal data you provide to us is only available to relevant employees and contracted service providers. If required by law, AWA may disclose data to government and/or enforcement agencies.
If we intend to use your data for a new purpose outside of those detailed in this Policy, this policy will be updated to keep you informed of the same; should consent be required from affected individuals, then it will be sought. AWA will never supply your data to third parties for marketing purposes.
Cross-border transfers of personal data
Due to the global reach of our business and services we provide, AWA works with Associates in different countries and it is sometimes necessary to transmit your data internationally in delivery of these services to meet our contractual requirements. If it is necessary to do so, we will ensure an adequate level of protection is in place to safeguard your data.
Data collected by AWA will be stored and processed primarily within the UK, but may be stored and processed in another country, including a country that is not in the European Economic Area (EEA). Some countries may not have data privacy laws as strong as those in force in others. We will ensure that the data protection standards employed within the UK are observed by our partners with whom we need to share information in all of the countries they operate.
Storage of your data
AWA takes reasonable steps to protect personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. If you are submitting personal information over the internet that you wish to remain private, please note that while attempts are made to secure information transmitted to this site, there are inherent risks in transmitting information across the internet. If you prefer, you can contact us by phone or mail.
AWA will take reasonable steps to destroy or permanently de-indentify your personal information when it is no longer needed.
We will hold your information on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with us. If you change your registration profile to opt-out of receiving communications from us, your record will stay on the system so we can ensure that we do not contact you in the future
The quality, accuracy and correction of personal information we hold
Protecting personal information is a priority for AWA. We consider security and confidentiality when handling personal information. It is important to us that the information we maintain and use is accurate, complete and up to date. If at any time your personal details change, please let us know so we can update our records.
Access to personal information
AWA respects your right to access personal information we hold about you. We will allow you to access your personal information unless we are entitled to deny access under the GDPR NPPs – for example, where the provision of access would be unlawful or would be likely to prejudice an investigation or possible unlawful activity.
Links from our website
Our website may contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over the other websites and are not responsible for the privacy practices of such other websites.
If you submit personal data and other information to a website to which we link, we are not responsible for its protection and privacy. Always exercise caution when submitting data to websites.
Alan Wick Associates
37 High Street
This document was created using a Contractology template available at www.freenetlaw.com.