Mindflex Leadership Limited is committed to respecting the privacy of all visitors to its website (the ‘website’) and of its clients and contacts.  Please read the following privacy policy to understand how we use and protect the information that you provide to us or that we obtain or hold about you and to understand what your rights are in relation to information that we hold. This policy applies to information about living identifiable individuals only.

WHAT INFORMATION DOES MINDFLEX LEADERSHIP PROCESS?

From our general website

You may choose to provide personal information to us when you register with the website e.g. to register for an event, sign up for a newsletter or ask us to contact you. You may be asked to provide certain information about yourself including your name, title, postal address, telephone number and/or email address. If you are attending an event, you may also be asked to provide information about any dietary or access requirements you may have which may reveal information about your health or religious beliefs.

Automatically

We may also collect information automatically about your usage of our websites using cookies and other technology (for full details of what we use see the section below on “Cookies”). To that effect, we use your IP address (a series of numbers that identifies a computer on the internet) to collect, among other things, internet traffic data and data regarding your browser type and computer. If you do not want to receive cookies, you may reject them by using your browser settings provided they are not necessary for delivery of our website or services to visitors (for help with how to do this see the section below on “Cookies”).

For training, coaching or development programmes

If you seek an estimate of costs for leadership development, are provided with free initial advice or become a client of the company, we will also need information about the companies and your personnel’s needs and circumstances as well as contact information for you, your personnel and other parties to the development work. The information that we need will be explained to you by our trainers/coaches and administrators  and/or set out in our letter of engagement depending on the nature of the development work but may include both personal data and special categories of data. You may also provide us with additional information that you consider relevant as part of your instruction.

From third parties

We may also receive information about you (or your personnel) from third parties such as personality profile test results, and other advisors and specialists related to your programme. Alternatively, you may provide us with information about you directly at our request or otherwise.

HOW DOES MINDFLEX LEADERSHIP USE THIS INFORMATION?

We will use your information for the specific purpose(s) for which it has been provided to or collected by us e.g.:

To provide information that you or your employer may request regarding the services that we offer e.g. whether we can provide training or coaching to assist you with your development

• To contact you to introduce you to our coaches and trainers
• To comply with our statutory and regulatory obligations
• To book you onto a course or event
• To provide you with feedback, information or materials relevant to any development programme you are involved with
• To ask you for feedback on the provision of our services

We also use your information to administer, support, improve and develop our business generally.

We may also use the information that we collect about you for marketing and hospitality purposes e.g.:

• to provide communications about us and other services we provide that may be of interest to you e.g. sending you newsletters
• to provide you with updates on relevant areas of leadership development
• to contact you about other activities and events that we may undertake
• to invite you for a meal or drinks or to a hospitality event

Information gathered through cookies and similar technologies are used to measure and analyse information on visits to our websites, to tailor the websites to make them better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.

Processing grounds

We must have a lawful basis for processing your information; this will vary depending on the circumstances of how and why we have your information but typical examples include:

• the activities are within our legitimate interests as a leadership development company seeking to engage with and provide services to prospective and current clients and personnel e.g. to make our systems and procedures more efficient
• you have given consent for us to process your information e.g. in relation to certain marketing activities
• we are carrying out necessary steps in relation to a contract to which you are party or prior to you entering into a contract e.g. because you wish to instruct us to carry out leadership developmet training or coaching for you
• to protect your vital interests e.g. if you were unfortunate enough to fall ill or suffer an injury on our premises

We will not process any special categories of information i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, processing of biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation, we must have a further lawful basis for the processing. This may include:

We will not process any information relating to your criminal convictions or offences.

MARKETING

If you become a client of the company, we may use your personal information to invite you to hospitality events or other selected events for clients and/or to send you information that we think may be of interest to you or your business. This is within our legitimate interests as a leadership development company to use your information in this way.

We may also use personal information about our contacts to invite them to hospitality events or other selected events and/or to send them information that we think may be of interest to them or their business. This is also within our legitimate interests.

You will be given an opportunity to tell us whether or not you wish to receive direct marketing materials and communications from us either at the time you submit or provide your details to us (primarily if you are a private individual, a sole trader or an unincorporated partnership) and/or within the communication itself.

If you do not wish to receive any direct marketing material or communications after you submit or provide your details, please contact our Marketing team using the details below (stating UNSUBSCRIBE in the heading of any email message) indicating if you do not wish to be contacted for one or more of these marketing purposes and/or via particular forms of communication e.g. email or telephone. Please note that the preferences that you state will override any registrations you or your organisation may have with the relevant preference organisations (such as the telephone preference services).

If you change your mind about being contacted by us in the future, or change address, or if any information that we hold about you is inaccurate or out-of-date, please let us know by: emailing: info@mindflexleadership.com or writing to our Marketing team at: Mindflex Leadership Limited, 21 – 23 Croydon Road, Caterham, Surrey, CR3 6PA or calling us on 01883 330 883

AUTOMATED PROCESSING/PROFILING

We tailor our marketing and hospitality communications to the interests of particular clients and contacts to ensure we provide information and invitations of interest and relevance to them.

DISCLOSURE OF YOUR INFORMATION

Some of the information you provide to Mindflex Leadership will be held on our computers in the UK and will only be accessed by or given to our staff working in the UK. Some of the information you provide to us may be transferred to, stored and processed by third party organisations which process data for us and on our behalf. These third parties may be based (or store or process information) in the UK or elsewhere including outside of the EEA. These third parties may include third party IT platforms (including cloud based platforms), suppliers of administrative and support services and suppliers of other specialist products.

We may also transfer your information to other organisations or professional advisers with whom we are working on client matters or to whom we are referring you for additional or separate advice. If you agree to act as a referee for us in relation to other leadership development work for which we are tendering, we will only do this with your prior permission.

We may also be obliged to disclose data under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.

Finally, if Mindflex Leadership merges with another business entity or divests a part of its business or carries out internal corporate restructuring, your information may be disclosed to Mindflex Leadership’s new business partners or owners or the new corporate entities.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy; please see section “Protection of your information” below.

PROTECTION OF YOUR INFORMATION

We have in place administrative, technical and physical measures on our website and internally designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold.

Where we transfer information to third parties to enable them to process it on our behalf, we ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data to them and keeping it secure.

We will also ensure that where information is transferred to a country or international organisation outside of the UK / EEA, we will comply with the relevant legal rules governing such transfers.

Destruction dates

The following is general guidance, at a summary level only, on the length of time we keep data and documents and how that period will be determined. This guidance is for users of the companies website.

Destruction dates are primarily based upon the likelihood of the company needing to refer to the documents again, as informed by limitation periods or the nature of the transaction covered by the client matter.

Certain items of information about client matters may be retained for longer periods of time for legal and regulatory reasons e.g. as part of our accounting records or for conflict checking purposes etc.

Prospective Clients

If a prospective client contacts the company and is given advice in an initial telephone call or email or meeting but the matter is not taken further and no matter file is opened, the matter is treated as a closed client matter and any written or electronic records of the advice given will be deleted no later than 7 years after initial contact.

Marketing and Business Development (BD)

BD client and contact data that is kept in the firm’s Client Relationship Management (CRM) system for marketing purposes and which has been added to the system because we are entitled to within our legitimate interests e.g. where the individual is employed by a corporate client of the firm, or because data has been added via the soft opt-in consent permission i.e. where an individual has instructed us and clearly chosen not to object to receiving marketing materials when we collected their data, will be retained for 5 years. At that point, we will then review our current relationship with the individual and remove details for any inactive clients or contacts e.g. where an individual has not attended an event or clicked on a link in any email or instructed us for a number of years.

BD client and contact data is kept in the companies CRM system because we have that individual’s express consent for the firm to keep their data for marketing purposes. We will re-confirm consent every 2 years (e.g. asking the individual to confirm which areas of the business they want to continue to receive information or newsletters about) or delete the data.

Client feedback forms or surveys are kept for 12 months and any personal information contained in them is deleted.

Clients or contacts whose details are kept in the companies CRM system can unsubscribe or ask for their details to be removed from the system at any time if they wish.

Event feedback forms are kept for 18 months then deleted.
Event data (e.g. dietary requirements) will be deleted after an event.

For individuals who have asked to unsubscribe from marketing communications, the ‘unsubscribe’ list will be kept indefinitely with minimal information to ensure no marketing is sent to those individuals.

Human Resources

All applications for vacancies or speculative applications (along with related correspondence) sent to the firm are kept for 12 months after receipt of the application or, where the firm has first secured consent to retain, for a longer period. Any such consent will be re-confirmed every 6 months thereafter and, if not received, the record is destroyed. Records relating to individuals taken on by the firm are retained in line with the firm’s employment policies.

Graduate recruitment applications (and related correspondence / other documents) are kept for 2 years after receipt of application or, where the firm has first secured consent to retain, for a longer period. Any such consent will be re-confirmed every 12 months thereafter and, if not received, the record is destroyed. Records relating to individuals taken on by the firm are retained in line with the firm’s training / employment policies.

You have certain rights in relation to your personal information: You have the right to request that we:

• Provide you with a copy of your personal information that we hold
• Update your personal information where it is out-of-date or incorrect
• Delete personal information that we hold
• Restrict the way in which we process your information
• Consider any valid objections to our processing of your personal information
• Provide information you have given to us to a third party provider of services (where our lawful basis for processing is consent or contract and where processing is automated)

We will respond to your request (including providing information on whether the rights apply in the particular circumstances) within the applicable statutory time period. If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are.

CHANGES TO THIS POLICY

We may make changes to this policy from time to time as our business and internal practices and/or applicable laws change.  We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by applicable law.

HOW TO CONTACT US

If you would like to get in touch to discuss this policy, how we use your personal information, to exercise your rights or to provide feedback or make a complaint about use of your information, please contact us as follows:

Brian Edwards, Risk and Compliance Director

dataprotection@mindflexleadership.com   or 01883 330 883

Mindflex Leadership Limited, 21 – 23 Croydon Road, Caterham, Surrey, CR3 6PA

You can also contact the Information Commissioner’s Office via https://ico.org.uk/  for information, advice or to make a complaint.

COOKIES

Cookies, also known as browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions e.g. to know who you are if you log into a restricted part of a website, for shopping carts, and for tracking purposes.

At Mindflex Leadership we use the following cookies:

• Google analytics. We use Google analytics cookies on the website for tracking purposes. The cookies allow us to understand general traffic to our website for example number of visitors and length of time on site. This process does collect data, but in an anonymous form, to help us make improvements, develop the website and enhance the user experience.
• Siteimprove. We use Siteimprove cookies on the website for tracking purposes. The cookies allow us to understand general traffic to our website for example number of visitors and length of time on site. This process does collect data, but in an anonymous form, to help us make improvements, develop the website and enhance the user experience.
• Privacy preferences. We use a tracking cookie, which is added to your computer, to remember your cookie preferences i.e. if you have allowed or disallowed them.
• Register for events. We have the ability for you to register for events on the website. If you do so this information goes directly into our database. In order to register our database adds an essential cookie (reaction server) to your computer.
• Member services. For areas of our website that are password protected then an essential cookie is added to your computer, which is then automatically deleted after your session has ended.

MANAGE COOKIES

Shortly after arriving at our website we will add an ‘opt-in’ tracking cookie to your computer unless you specify otherwise. See above for further information on the types of cookies that we use.

If you would like to opt-in or opt-out of using cookies then you can use the link below. You can review your cookie settings at any time.

If you do opt-out then an opt-out preference cookie will be added to your computer, however if you delete all your cookies or use a different device then you will need to set your cookie preference again.

If this is your first visit and you navigate away from this page without specifying your cookies preference then an ‘opt-in’ tracking cookie with be added to your computer.

Please note that you cannot opt-out of the deployment of cookies that are necessary for delivery of our website or services to visitors.