WHO WE ARE
We provide consultancy and advisory services to clients for their businesses.
WHAT THE POLICY COVERS
We at Per Ardua Associates take your personal data seriously. This policy:
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data
- sets out the legal basis we have for using your personal data
- explains the effect of refusing to provide the personal data requested
- explains the different rights and choices you have when it comes to your personal data
- explains how we may contact you and how you can contact us
WHAT PERSONAL DATA DO WE COLLECT?
We collect the information necessary to be able to effectively coach and assess individuals and or teams. This information includes assessment data and psychometrics.
We may also collect sensitive personal data about you, in the form of health and dependents. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
WHERE DO WE COLLECT PERSONAL DATA ABOUT YOU FROM?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide while taking part in the assessment or coaching process
- By Reference or word of mouth. For example, an employer or a colleague for a 360 assessment or input to a coaching engagement
HOW & WHY WE USE YOUR PERSONAL DATA?
We use your personal data to in order to understand more about you and assist you with understanding your skils and areas for improvement or future opportunities and options.
HOW LONG DO WE KEEP YOUR DATA FOR?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
(a) our contractual obligations and rights in relation to the information involved;
(b) legal obligation(s) under applicable law to retain data for a certain period of time;
(c) our legitimate interest where we have carried out a balancing test (see legal basis below);
(d) statute of limitations under applicable law(s);
(e) (potential) disputes;
(f) if you have made a request to have your information deleted; and
(g) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Your personal data is shared with the client who initiates the program, but coaching notes remain confidential unless there is a legal obligation to share them externally. Given we are part of a Financial Services Executive Search firm, we work with a broad range of clients within this sector.
WHAT LEGAL BASIS DO WE HAVE FOR USING YOUR INFORMATION?
For individuals our processing is necessary for our legitimate interests in that we need the information in order to be able to effectively coach or assess individuals. We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
This process may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?
If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to provide the same standard of service.
DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
No, we do not carry out automated profiling.
DO WE TRANSFER YOUR DATA OUTSIDE THE EEA?
To deliver the program we may transfer your personal data to your employer in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data.
To find out more about how we safeguard your information as related to transfers contact us on firstname.lastname@example.org.
WHAT RIGHTS DO YOU HAVE IN RELATION TO THE DATA WE HOLD ON YOU?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
|Rights||What does this mean?|
|1. The right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.|
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
|3. The right to rectification||You are entitled to have your information corrected if it’s inaccurate or incomplete.|
|4. The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.|
|5. The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|6. The right to data portability||You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|7. The right to object to processing||You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).|
|8. The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.|
|9. The right to withdraw consent||If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
HOW WILL WE CONTACT YOU?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
HOW CAN YOU CONTACT US?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here:
Per Ardua Associates Ltd
Level 14, Tower 42
25 Old Broad Street