The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Directive (Directive 95/46/EC).
The General Data Protection Regulation builds on previous legislation but enhances privacy rights for individuals. The GDPR will apply in the UK from 25th May 2018.
Despite the UK’s intention to leave the European Union in March 2019 the GDPR will still apply in accordance with the Information Commissioner’s Office (ICO) guidance to continue a similar level of regulation post March 2019 together with a new Data Protection Act.
This policy will outline:
- The details of the Data Controller and how to contact the Data Protection Officer(DPO)
- The types of personal data we collect and how we use it
- Our purpose and legal basis for processing your data
- How and when we share data with Personal Career Management suppliers and partners
- How and when we use your data for marketing purposes
- Your rights to request your personal data and how to do so
- How you can raise a complaint with the ICO
Who controls my personal data?
- The Data Controller is Personal Career Management Limited
- Personal Career Management is a UK registered company 4776125
- The registered address is Chalfont Hall, Gravel Hill, Chalfont St. Peter, Gerrards Cross, Buckinghamshire, SL9 0NP
- The Data Controller’s representative is the Data Protection Officer (DPO)
- You can contact the DPO by email firstname.lastname@example.org or call them on 01753 888 995
- Personal Career Management Limited is registered as a Data Controller with the Information Commissioner’s Office. Certificate number Z1270562
Our purpose and legal basis for processing your data
We provide career coaching and outplacement services to individuals, corporate clients and ancillary services.
We collect the personal data of the following types of people:
Clients and prospective clients for our career coaching, career workshops, outplacement and on-line career services;
Individual contacts of our corporate clients and our suppliers;
Our employees, career coaches, licensees and franchisees and business connections.
What data will you give to us or will we collect from you?
- You provide us with your personal data by filling in forms on www.personalcareermanagement.com, by corresponding with us by phone, e-mail or otherwise, by subscribing to our services, sharing your details at meetings with us, attending our events, participating in discussion boards or other social media functions on our website or online, by entering a competition, promotion, or survey or by reporting a problem with our site or by voluntarily providing your personal information directly to Personal Career Management at any other time e.g. giving us your business card
- The types of personal data we collect may vary according to its purpose, we typically collect information such as: your full name, telephone number, email address, postal address, and Curriculum Vitae. We will also record any other relevant professional or personal information which is relevant to your career situation and how we might help you e.g. salary details
- Personal Data may also include links to professional sites such as LinkedIn, Twitter, or a corporate website
- We will also produce summary notes from career coaching sessions which will be sent to the coachee for their reference
What Information do we obtain from other sources?
- We may obtain information about you from other sources such as our franchisees, our licensees and suppliers, your employer, your business card, personal recommendations, or our partners such as the Guardian, The Telegraph, and CV Library
What are the purposes and legal bases for our processing?
We use information held about you in the following ways:
- To carry out our obligations arising from any contracts we intend to enter or have entered between you and us and to provide you with the information, products, and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation
- To provide you with information about other goods and services we offer that are like those that you have already purchased, been provided with, or enquired about
- Our main legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation, and consent for specific uses of data
- We will rely on contract if we are negotiating or have entered into an agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation
- We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligation, for example, our statutory obligation as an employer
- We will in some circumstances rely on consent for uses of your data and you will be asked for your express consent e.g. before sharing your details with a recruiter or as part of a media request
Our Legitimate Business Interests
- To provide career coaching, career workshops, outplacement and online career services to individuals and corporate clients
- To manage employee and contractor relationships
- To manage our corporate rights and obligations
- Should we want or need to rely on consent to lawfully process your data we will request your consent, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this processing at any time
Other uses we will make of your data:
- To notify you about changes to our services;
- To ensure that content from our site is presented in the most effective manner for you and for your computer
- To administer our site and for internal operations, including troubleshooting, security, data analysis, testing, research, statistical and survey purposes
- To allow you to participate in interactive features of our service, when you choose to do so
- To measure or understand the effectiveness of our advertising that we serve to you and others, and to deliver relevant advertising to you
- We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process
Who will have access to your data inside and outside of European Economic Area (EEA)?
We will share your personal information with selected third parties including:
- Our data processors, licencees, franchisees, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you
- We will not disclose your personal information to third parties except if we sell or buy any business or assets, in which case we may disclose some of your personal data to the prospective seller or buyer of such business or assets for due diligence or substantially all our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets
The lawful basis for the third-party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their contractual obligations to us
- To fulfil their legal obligations
Will your data be used for marketing?
- We will only send you information about our products and services that are relevant to you
- We may send the communication in several ways including email, telephone, and post
- When you register your details with us we will ask your preferences on receiving marketing communications, you also have the right to change your preferences at any time by phone or email
What are cookies and how do they affect your personal data?
- Our cookies track site visitor’s basic information to better tailor the site to our visitor’s needs and improve their customer experience
- Most web browsers automatically accept cookies; however, you can disable cookies in your web browser if you wish. Please be aware disabling cookies will affect the functionality of our website and you may disable other features on the website. We recommend you do not disable cookies, in case they are used to provide a service that you use
Where will we store and process your personal data?
- All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone
- Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access
How long will we retain your data?
- We understand our legal duty to retain accurate data that you are happy for us to retain and only retain personal data for as long as we need it for our legitimate business interests or to satisfy legal, accounting or reporting requirements. Accordingly, we have a data retention policy and run regular data routines to remove data that we no longer have a legitimate business interest in maintaining
We do the following to try to ensure our data is accurate:
- We keep in touch with you, so you can let us know of changes to your personal data
- We may archive part or all your personal data or retain it on our financial systems. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so
- For your information, pseudonymisedData is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms
- Our current retention policy is available upon request
How safe is your data?
- Appropriate technical and organisational measures are taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data
- We use electronic safeguards including firewalls, anti-virus and anti-malware software to protect your data
- Only authorised staff have access to personal data and are appropriately trained and supported by policies and procedures for handling personal data
- For payments, we do not retain your full card details and always require you to provide the last three digits of the security code to process a payment
- We do not recommend or guarantee the safety of your payment details sent to us electronically via email
What are your rights to your personal data?
- You have the right to request copies of any personal data held by us.
- To receive a copy of your personal data please send your written request to the Data Controller, Personal Career Management, Chalfont Hall, Gravel Hill, Chalfont St. Peter, Gerrards Cross, Buckinghamshire, SL9 0NP
- We will provide you with a hard copy of your personal data held
- You will not be charged for your personal data request
- Your data will be returned within 40 days of receiving the request
- We will require proof of identity
- You also have the right to the following:
- The right to prevent data being processed for direct marketing
- The right to have inaccurate personal data rectified, erased, or destroyed
- You have the right to make a complaint to a supervisory body, which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
When the GDPR comes into force you will have the following additional rights, subject to the GDPR:
- The right to object to processing that is likely to cause, or is causing damage or distress.
- The right to object to decisions being taken by automatic means.
- The right to have inaccurate personal data suppressed, rectified, blocked, erased, or destroyed.
- You can enforce these rights by contacting the Data Controller.
Last Reviewed: 07/11/2018
Next Review: 07/11/2019
Reviewed by: Racquel Perry