This policy may occasionally be updated by us so we suggest you re-review from time to time.
2. Our approach to privacy
Cirrus places 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. To help us continue to achieve this, we have embedded privacy by design and by default within our operating procedures and service delivery. This means that privacy and data protection is taken into consideration and implemented in the design and delivery of our business services, marketing functions, IT systems and overall business practices so that our clients, employees and service users’ right to data privacy and data protection is our default position when processing data.
This ensures that no additional actions are required by you to ensure your privacy is honoured and protected. It also means we will not share your data with third parties for marketing purposes, and will only do so when necessary to provide a business service you have requested, or if legally obligated to do so.
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 Cirrus 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 Cirrus is subject.
- Legitimate interests – processing is necessary under the Legitimate Interests of Cirrus 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.
3. 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 from Cirrus, information considered sensitive may emerge during the course of discussions with your Cirrus coach. These relationships are bound by strict confidence, and any notes collated by your Cirrus coach 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, for example, our website and Strata our digital learning platform.
Where your data is provided to us by an authorised third party such as your employer (i.e. in the form of course participant lists), it is the third party’s responsibility to ensure they have the correct lawful basis in place to share this data with Cirrus.
4. The purposes of processing personal data
Your data may be used for a number of purposes including, but not limited to:
- Provide all the elements of the learning and development, talent and engagement services we have been contracted to provide by yourself or your employer
- Contacting you in the event of a workshop time change or cancellation
- 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 a Cirrus service as part of a development programme we are contracted to deliver.
When taking part in a service (e.g. diagnostic, survey, workshop, webinar, coaching) 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 & 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. The personal data you provide here will either be anonymised or deleted 6 months after the end of the programme and for assessment activity between 3 months and 3 years depending on the nature of the service (see How long do we keep your data section 10 for further details). We may need to provide your personal data to an Approved Practitioner (an associate or independent practitioner authorised to deliver Cirrus solutions), a Third party processor (providing profiling services to Cirrus on your behalf) or a Client Practitioner (a colleague in your organisation authorised to deliver Cirrus solutions) if you are enrolled on a programme delivered by either party for learning & 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 resources.
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 resource, 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, events, offers and other things we think might be relevant to you
- To send you promotional mailings or to call you about products, services, events, 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. Cirrus will only keep data for as long as is necessary to meet these purposes. We will never share, sell, or rent individual personal information to an external party without your advance permission, or unless ordered by a court of law. The personal data you provide to us is only available to relevant employees and contracted service providers. If required by law, Cirrus 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
5. Cross-border transfers of personal data
Due to the global reach of our business and services we provide, Cirrus works with Approved Practitioners in different countries and it is sometimes necessary to transmit your data internationally in the 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 by using either password protected files (with randomly generated passwords being sent in a separate email) or secure file transfer via our Sharepoint server. If, as our client, you have a specific method of transfer you wish us to use, please inform us in writing.
Data collected by Cirrus 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) including Australia. 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.
We will carry out a Data Protection Impact Assessment (DPIA) prior to the transfer of data to a new territory or international recipient located outside of the EEA to identify risks and adequate safeguards to implement. Such international recipients will be required to demonstrate compliance and adhere to defined protocols via a Data Processor Agreement, Code of Conduct, and/or a relevant recognised data protection or security certification. These safeguards are intended to ensure that, post-transfer, your data is subject to security measures no less rigorous than those required by data protection legislation in force in the UK.
In some instances, we may seek authorisation from the Information Commissioner’s Office (ICO) prior to a cross-border data transfer.
6. Keeping personal data secure
Our website and online services are protected by firewalls and we have implemented security policies, rules and technical measures to protect the data in our control. These security measures are designed to prevent unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
Any information you provide us with when using our services is stored centrally on secure cloud-based systems. Direct access to these databases is restricted to authorised personnel and their appointed agents only. We have taken every reasonable step to ensure that your personal data is held securely at all times, and that access to these are closely monitored. We use security measures to protect against the loss, misuse and alteration of data within our systems.
Please be aware, however, that no internet or email transmission is ever fully secure or error-free. You should take special care in deciding what personal data you send to us via email and keep this in mind when disclosing any personal data to us via the internet.
7. Controlling your personal data
Any personal data we collect from you or we generate as a result of your interaction with our systems and services belongs to you. Under the data protection laws in the UK you, therefore, have the right to know if your data is being processed, why and for how long. This will include details of what categories of data we process (e.g. storing your name and contact details in a CRM system), whether your data has been disclosed to third parties and their identities, and how to raise a complaint with the Information Commissioner’s Office (ICO).
In addition to your right of access to data we process, Cirrus will uphold other rights afforded to you under the applicable data protection laws in the UK, namely:
- the right to request that errors in your personal data processed by (or on behalf of) Cirrus are amended or corrected;
- the right to erasure of your personal data if those data are no longer needed for their original purpose, or where the processing is based on consent and you withdraw that consent (and no other lawful basis for the processing exists);
- the right to restrict processing where the relevant personal data either cannot be deleted (e.g. because the data are required for the purposes of exercising or defending legal claims) or where you do not wish to have the data deleted;
- the right to object to processing carried out for the purposes of direct marketing, where processing is likely to cause or is causing damage or distress, or where you may be evaluated or subject to decisions on the basis of automated processing;
- the right to request a copy of the personal data you have provided to us for yourself, or for it to be transferred to another organisation, if the processing was based on consent, the provision of business services under a contract, or processing carried out by automated means.
We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: firstname.lastname@example.org or telephone on +44 1625 425 460, or write to us at Cirrus, Sandfield House, Water Lane, Wilmslow, Cheshire, SK9 5AR, UK.
The accuracy of your information is important to us. If you believe that any information we are holding about you is incorrect or incomplete or wish to exercise any of your rights in relation to your personal data, please contact us. We aim to respond promptly to any requests. However, please note that depending on the complexity and scope of your request, it may take up to 30 days for us to provide you with an adequate response.
8. Data Breach
We have in place a robust procedure if a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of a public electronic communications service occurs. We will assess the scope and impact of the breach. Based on the assessment of the likely risks to individuals, we will notify the individuals and/or their connected organisations that a data breach has occurred where this may result in a significant risk to the rights and freedoms of individuals, or where we may be in breach of a contractual obligation.
Any such notification to individuals will be carried out as soon as reasonably possible and will include information on the nature of the breach, the name and contact details of our Data Protection Officer, the likely consequences of the breach, measures taken or proposed by Cirrus to address it, and recommendations for affected individuals to mitigate any potential adverse effects. Such individuals will also be provided advice on how to make a complaint to the ICO.
If, due to the nature of the breach that Cirrus is required to inform the ICO, we will do so within 72 hours of becoming aware of the essential facts of the breach. Such notification must include at least: your name and contact details; the date and time of the breach (or an estimate); the date and time we detected it; basic information about the type of breach; and basic information about the personal data concerned.
9. Who has access to your personal data?
The data we collect about you is generally accessed only by authorised Cirrus employees for legitimate business purposes and providing services as part of a contract. However, if we work with partners or contractors, they may have limited access to your personal data but only so much to do their job.
If for example, a participant has completed a talent management or personality diagnostic, the profile produced from this data will only be provided to the participant and will not be shared with anyone else without their prior consent. If the participant attends a Cirrus workshop, we would not share his or her profile with a group of their peers. During a workshop, an individual may be invited by the Cirrus accredited facilitator leading the session to share some information from their profile with the group, however, this is their personal choice and done at their own discretion.
The following outlines who has access to your personal data, and under what circumstances:
- Cirrus employee consultants and other employees who are involved in arranging and delivering the services you request (where privacy is legally covered under their contract of employment);
- An Associate/Approved Practitioner who is contracted by Cirrus to provide services to you on our behalf, and therefore bound under terms within their contract relating to confidentiality and privacy that is to the same standard and level as Cirrus employees; or
- A Client Practitioner. That is a person who is employed by the client company and authorised to deliver Cirrus solutions. Cirrus provides clear guidance on privacy requirements that is to the same standard expected of Cirrus employees in their management of personal data. That employee will also have a contract of employment that will address handling confidential information. Should the Client Practitioner allow any other member of staff employed by the customer to handle any personally identifiable information (e.g. a member of administration staff is allowed to access the Cirrus software and our online systems in order to produce the profiles) then again, that employee is bound by their normal terms of confidentiality in their contract of employment and this is at the customers risk.
Third-partyprocessor such as Envisia (providing 360/180 profiling services to Cirrus) or SHL (providing OPQ) who is contracted by Cirrus to provide services to you on our behalf, and therefore bound under terms within their contract relating to confidentiality and privacy that is to the same standard and level as Cirrus employees.
10. How long we hold data
It is Cirrus’s practice that personal data is retained only for the appropriate period of time – neither too long nor too short. We have in place internal guidelines for employees on how long data should be retained detailed in a Data Retention policy.
This specifies that we will need to keep certain information about employees, clients, suppliers and other individuals or organisations we interact with over the course of business to carry out certain business functions for up to 7 years to monitor and improve the quality of our service, for our records and to meet certain legal and compliance requirements.
- Client personal data:
Participant data including profiling used on programmes – deleted 6 months after the end of the programme (paper copies destroyed 3 months post completion of the profile)
Assessment centre reports, profiles and notes – deleted 3 years after the end of the assessment process (paper copies destroyed 3 months post assessment)
- Where a client makes a specific request for their data to be deleted sooner and it does not conflict with any legal or compliance requirement to hold data for longer, we will honour the request
- Employee personal data will be held for the duration of employment and then for 7 years after the last day of contractual employment. Employee contracts will be held for 7 years after last day of contractual employment
- Associate personal data will be held for the same duration as employees, 7 years from the last day of the contractual agreement.
Where data is held by third parties in support of the services we provide to you, the third parties are contractually bound to either delete data upon our request, delete data at the end of our supplier contract with them, or to anonymise data from 3 months to 3 years of receipt depending on the purpose of the data.
On occasion, we may gather information about your computer to provide statistical information regarding the use of our website to help improve our services.
Such information will not identify you personally, it is statistical data about our visitors and their use of our site. This statistical data does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with the website so that we can continue to develop and improve it.
We may gather information about your general internet use by using a cookie file that is downloaded to your computer. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the service that we provide to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular areas of our website.
Although we do not have any advertising featured on this website if we do in the future, they may also incorporate cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on the advertisements.
12. Links from our website
Our website and learning portals 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. Read the site’s data protection and privacy policies fully.
If we make substantive changes to this Policy, we will announce it on our website to ensure that you are aware of the information we collect and how we use it at all times.
14. Contacting us
Cirrus has a designated Data Protection Officer and designated personnel with data protection responsibilities in all service areas.
If you have any questions, comments or requests regarding this Policy, or wish to contact our Data Protection Officer, please get contact us at email@example.com. If you would prefer to write to us then our contact address is:
The Data Protection Officer, Cirrus, Sandfield House, Water Lane, Wilmslow, Cheshire, SK9 5AR, UK.