your privacy and GDPR
‘ND’ is a private limited company registered in England and Wales (company registration 07458928. ‘ND’ is committed to protecting and respecting the privacy of all our ‘Clients’ we interact with and how we collect, store and use data. In doing so, ‘ND’ is compliant with the current UK Data Protection Act 1998 and applicable regulations, including European General Data Protection Regulations. In this Policy we will set out our information gathering and dissemination practises for any personal information gathered, by ‘ND’, its ‘Partners’, ‘Partner Vendors’ and ‘Associates’.
Nature of our work
‘ND’ by definition carries out and provides to its ‘Client’ services in Leadership Development, Consultation, Facilitator and Mentoring. These services are delivered within the United Kingdom, Europe and North America.
‘ND’ will engage with the ‘Client’ and agree to conduct works on behalf of the ‘Client’ in the form of bespoke or tailored-made programmes or will engage with the ‘Client’ in line with their agreed Statement of Work.
Through our engagement ‘ND’ will directly work with ‘Client’ employees, in various guises through classroom workshops with multiple employees, on a 1:1 basis, or with small groups of management teams and with the ‘Client’s’.
Information gathered on ‘Client’ or ‘Client Partners’
In order to engage with our ‘Client’ and to fulfil our contractual obligations ‘ND’ will be required to obtain for processing the full family name and email address of cohorts, or for the ‘Client’ to share Confidential papers.
The processing of personal data is necessary for the performance of a Contract to which the data subject ‘Client’ is party, or in order to take steps at the request of the data subject ‘Client’ or prior to entering into a Contract.
‘ND’ may be required to share your information with a ‘Partner’ who will themselves use a ‘Partner Vendor’, to meet a specific element of the Contract through engagement of ‘Client’ surveys or assessments in delivering the agreed ‘Client’ programme.
Where is my data stored?
In sharing our ‘Client’ information with a ‘Partner’, your data may be stored on servers which fall outside of the EU. ‘ND’ is confident about the security of your personal data with its business ‘Partners’ having validated and obtained written confirmation of their Privacy Policies, indicating they are wholly committed and take seriously the data storage of any personal data including their security measures, and that of their ‘Partner Vendors’.
Within ‘ND’ any assessment or survey may be stored on our internal drive but not within any ‘ND’ CRM system.
What does Natural Direction do with your information?
The general extent of the personal information gathered by ‘ND’ includes the full family name and work email address of the ‘Client’. On occasion the ‘Client’ will provide a non-work-related email address. ‘ND’ requires this information to communicate important details regarding a forthcoming ‘Client’ programme or to instruct the ‘Client’ to conduct a survey or assessment.
‘ND’ may share your information with our ‘Associates’ who are leading and delivering on an agreed date the ‘Client’ programme.
In collecting the ‘Client’ information it will not automatically be added to our CRM system; shared or sold to any third party. Some ‘Client’ information if deemed appropriate will be used to market ‘ND’ services with the ‘Clients’ express permission or through previous agreement, but ‘ND’ will not automatically add a ‘Client’ to any mailing list.
‘Client’ survey or assessment related reports either individually or by team, will be kept on by ‘ND’, its ‘Partners’ or ‘Partner Vendors’ for future reference or as dictated by their Data Retention Policy.
‘ND’ will delete any ‘Client’ information it deems no longer relevant for example cohort attendee lists, names and email addresses on any spread sheets.
‘ND’ will undertake periodic audits of our ‘Associates’ to request they delete from their records any ‘Client’ information and for our ‘Associates’ to confirm they are not storing any personal data once a specific programme has expired.
Data access and deleting personal data
All requests to see or delete any personal data should be sent to firstname.lastname@example.org You should receive an acknowledgment within 24 hours and whilst ‘ND’ accepts your request to share or delete your personal data held, but if it is held with a ‘Partner’ may take longer to obtain.
In requesting data to be deleted the ‘Client’ accepts they may be deleting important information, specifically if it relates to a survey or assessment, which may be required again in the future. ‘ND’ will accept no responsibility in the deletion of this data upon final confirmation from the ‘Client’.
‘ND’ will at this point provide instructions to its ‘Associates’ any specific ‘Partner’ and in turn – the ‘Partner Vendors’ to delete any personal data, surveys or assessment, which will be confirmed with the ‘Client’ when undertaken.
If you wish to make a complaint
If you wish for to make a complaint on any personal data being held, or that your Data Subject Request has not been carried out to your satisfaction, you should email email@example.com and copy in firstname.lastname@example.org
Upon receipt a thorough investigation will be made into the process and lines of communication in undertaking your complaint and about the personal data being held.