EQUAL TALENT PRIVACY POLICY & GDPR DATA COMPLIANCE
Equal Talent Ltd is committed to preserving the privacy of all of our clients and contacts, and visitors to our website www.equaltalent.com. Please read the following Privacy Policy carefully to understand how we use and protect the information that you provide to us. By working with us at Equal Talent and visiting our website www.equaltalent.com you consent to the collection, use and transfer of your information under the terms of this policy.

INFORMATION THAT WE COLLECT FROM YOU
At Equal Talent we only collect the personal information that we need from you to allow us to provide the best possible service to you. When you engage with us about our services (either via the website, e-mail, phone call or face to face) you may be asked to provide certain personal information about yourself including:

• Your name and job title
• Contact information including telephone number, address and email address
• Other information relevant to the service provided e.g. developmental and coaching goals, progress against goals.

We may also ask for examples, feedback and testimonials regarding the services we have provided to you. When you connect with us via our website we may automatically collect details such as your Internet protocol (IP) address used and information about your visit such as products you viewed or searched for, page response times and error messages. Our website may also use cookies to distinguish you from other users of our site.

USE OF YOUR INFORMATION
At Equal Talent we only use your information to ensure that we can provide the best possible service to you. The information that you provide to us allows us to:

• Communicate and engage with you, as necessary, regarding our services
• Effectively deliver the products and services to you
• Monitor and track progress against the goals of services provided to you

We will also use and analyse the information we collect so that we can administer, support, improve and develop our business. We may use the technical and website information collated from the website to administer and improve our website. Further, where you have consented, we might also use your information to let you know by email about other products and services which we offer which may be of interest to you. If at any point you change your mind about being contacted in the future, please let us know. Any data collected from our website (e.g. IP address and cookies) helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

INFORMATION WE RECEIVE FROM OTHER SOURCES
In some instances, if you work for a company who we are working with, we may receive personal data about you from the Programme Sponsor, your leaders/ managers at your company to allow us to scope the services, and to get in touch with you when the coaching programme or workshop commences. We may also receive feedback or input about your developmental opportunities and/or progress against your developmental goals from your leaders, managers, colleagues and/or team members as part of a 360 process, as part of a mid or end of programme review/close out, or as part of a diagnostic process. Collection of this data will be agreed with you in advance. This data will may be received via email, report or document.

WHERE WE STORE YOUR PERSONAL DATA
At Equal Talent, we ensure that all personal data stored is kept to a minimum and stored securely. We use a cloud based CRM system called Capsule to capture and store you’re the majority of your personal data. The data entered is stored securely in a database and is only accessible to the approved users at Equal Talent. Access to the system is restricted to approved users and password protected. The Capsule privacy Policy can be found here https://capsulecrm.com/privacy.

Whilst all users laptops/ computers are all password protected we do not store your data in emails in our hard-drives. On Capsule we capture and store:

• Your name and job title
• Contact information including telephone number, address and email address
• Copies of documents provided/agreed, or email correspondence, in relation to the programme which may include; your name, contact details, developmental goals (at a programme or individual level) and/or progress against goals
• Brief coaching notes to keep a record of progress against the development goals.

We may take brief notes during a coaching programme to help facilitate the session, to record progress against the development goals or the coach may capture reflective notes to allow for coaching supervision and development of our practice. Any notes captured at the time about will be coded to ensure that they are not attributed back to the client and they will be either handed back to the client or destroyed. A summary of the progress against the development goals will be recorded on Capsule against the client. These are fact based and do not include any subjective or sensitive data. A paper trail is not retained. We also use Xero, a cloud based accounting system, to capture and store any billing information provided and invoice data.

DISCLOSURE OF YOUR INFORMATION
At Equal Talent we work with a number of trusted partners, who support us to deliver a great service to our clients. We will only provide information to them which is necessary for them to do their job and ensure that they take the security of your personal data as seriously as we do. We have processor agreements in place where necessary and ensure that all third parties are GDPR complaint. The third parties that we may use from time to time are:

• Our Associated Coaches – All Equal Talent coaches are provided with a Statement of Work to brief them before a programme commences. This includes details of your / the delegates contacts details (name, address, email and telephone number) to allow them to make contact with you, and the programme purpose and development goals to allow them to deliver the programme. All associates are responsible for their own GDPR.
• Our Accountant / Bookkeeper – We provide details of your name, address and email for invoicing purposes only.
• Our Virtual Assistants – We may provide our support team with your contact information required to help us keep in touch with with you.
• MHS Systems – We use MHS systems to generate client EQi reports. Your email address and name is supplied to MHS to allow the questionnaire to be issued. Their privacy policy can be found here: https://tap.mhs.com/privacy.aspx
• Clarity4D – We use Claity4D to generate client Clarity4D reports. Your email address and name is supplied to Clarity4D to allow the questionnaire to be issued. Their privacy policy can be found here: http://www.clarity4d.com/privacy-equality-statement Unless required to do so by law, we do not share customer details with any additional third party.

SECURITY AND DATA RETENTION
At Equal Talent we do not hold your data for longer than necessary and employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction, and damage. We retain your details on Capsule for the following length of time:

• Company contact information will be stored for up to 7 years to allow us to develop and maintain the relationship with you. We will check on an on going basis that your information is still correct, and amend as required. For leads and prospects we will store company contact information for up to 3 years to allow us to develop the relationship with you. If you do not invest in our services and become a client, we will delete the information after 3 years.
• Delegate contact information will be stored for up to 6 months after the end of the end of a programme and then deleted.
• Coaching notes and any documents including developmental goals (such as Statement of Work or Contracting Document) will be stored for up to 5 years after originated.
• Clarity4D and EQi Reports – these will be saved in Dropbox and held for no more than 4 weeks after the completion of the development programme. With all contact information, we will check at least once a year that your information is still correct, and amend as required. Information stored on Xero is retained for 7 years in line with accountancy rules and regulations

BREACHES OF SECURITY
We have taken every measure to ensure that we only collect personal data that is essential to allows us to deliver a great client experience to our clients, and that it is stored securely. However, in the unlikely event that a breach in security were to occur and we became aware of a risk to your personal data, we will take this matter very seriously and will notify you immediately by email and take prompt steps to mitigate any impact.

SOCIAL MEDIA SITES
If you engage with us on social media platforms such as Linked in, Twitter or Instagram please note that this is a voluntary contribution and at Equal Talent we hold no responsibility for the safety of your content or data on these sites.

LINKS TO OTHER WEBSITES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should therefore exercise caution and please check these policies before you submit any personal data to these websites.

ACCESSING AND UPDATING
At Equal Talent we ensure total transparency for our clients. You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at marie.h@equaltalent.com

CHANGES TO OUR PRIVACY POLICY
Any future changes made to our privacy policy will be posted on our website, and where appropriate notified to you via email.

ROLES & RESPONSIBILITIES
Data Controller: Marie Haycocks Data Processors: Marie Haycocks, Catherine Smith, Polly Downes and Amanda Davie.

POINT OF CONTACT
Questions, comments and requests regarding this Privacy Policy are welcomed. Please contact Marie Haycocks, Executive Coach and Director of Equal Talent Ltd at marie.h@equaltalent.com

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