There are some changes in data protection law, so we wanted you to know that we have updated our Privacy Notice

Introduction

Full legal name: The Clore Social Leadership Programme.

Your trust is important to us, and we want to make sure you understand what these changes mean for you.

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Clore Social Leadership uses your data; for example we will explain things such as our procedures for collecting and storing the information that you provide as a participant on one of our programmes.

We hope the following sections will answer any questions you have but if not, please do get in touch with us at info@cloresocialleadership.org.uk.

1. Explaining the legal basis we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, when you fill out an application form for one of our programmes, we’ll collect your employer’s details in order to contact them for feedback during the programme. We’ll also collect your email address in order to send you communications throughout the programme.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Clore Social Leadership to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your programme participation history to send you or make available personalised offers.

We also combine the data we collect from various feedback forms throughout the programme to identify trends and ensure we can keep up with demand, or develop new products/services and make improvements to our current programme offerings.

We will also use your email address details to send you direct marketing information via email, telling you about products and services that we think might interest you.

2. When do we collect your personal data?

When you complete an Expression of Interest form or an Application Form for one of our programmes.

When you book to attend an event, for example a Leader’s Now breakfast at the House of St. Barnabas. We keep your name and email address in order to contact you again for future Clore Social events.

When you visit any of our websites, and use your account to buy products and services.

When you create an account with us. (same as above)

When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.(same as above)

When you engage with us on social media.

When you contact us by any means with queries, complaints etc.

When you choose to complete any surveys we send you.

Any individual may access personal data related to them, including opinions. So if your comment or review includes information about one of our partners (such as a professional facilitator at one of the programme residential sessions), who provided that service, it may be passed on to them if requested.

When you’ve given a third party permission to share with us the information they hold about you, such as an outside coach or professional facilitator.

3. What sort of personal data do we collect?

If you have a web account with us we might collect: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password. We collect all the relevant information required for programme participant selection; such as, name, address, telephone number, previous professional experience and history, employer details, and leadership development needs.

Details of your visits to our websites or apps, and which site you came from to ours.

Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies. (Link to cookie policy)

Personal details which help us to recommend items of interest. For example, you might tell us your leadership development needs, which we’ll use to guide our suggested items. Or you might share information on your personal goals which allows us to recommend appropriate further leadership development programmes, products or other services.

To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit and any search terms you entered. Learn more about this. (Link to cookie policy)

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your training experience with us. Of course, it’s always your choice whether you share such details with us.

4. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when a new programme or product is available, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

To process any applications or expressions of interest that you make by using our websites or apps. If we don’t collect your personal data during the application process, we won’t be able to process your order and comply with our legal obligations.

For example, your details may need to be passed to a third party to supply or deliver the programme element that is part of the programme you are taking, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, and so on.

Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications via email  in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

You are free to opt out of hearing from us at any time.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your programme. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To develop, test and improve the programmes, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

For example, we collect, collate, and use programme feedback survey data to compare with previous programme data to inform us about trends and to continually provide improvements to our programme content and delivery.

To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are not required to respond to these requests.

To process your booking/appointment requests (for example at our residential venue). Sometimes, we’ll need to share your details with a third party who is providing a service (such as our trainers or coaches). Without sharing your personal data, we’d be unable to fulfil your request.

Here’s more information on how we share personal data with third parties.

5. How we protect your personal data?

We know how much data security matters to all our clients. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using httpstechnology.

Access to your personal data is password-protected within our various customer relationship management applications (such as Salesforce and Teachable).

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

6. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis, programme evaluations, Â and business planning.

Some examples of customer data retention periods:

Expression of Interest
When you fill out an expression of interest for one of our programmes, we’ll keep the personal data you give us for five years in order to provide further information to you regarding any new programmes. This would come under our Legitimate Interest as the legal basis for data retention.

Programme participants
We’ll keep the personal data you give us during the application process and  the programme feedback progress for ten years after the programme ends, in order to comply with the legal and contractual obligations to our participants.

7. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example, our programme trainers and facilitators, our residential venues for bookings, our programme evaluators.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
  

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Direct marketing companies who help us manage our electronic communications with you.
• Data insight companies to ensure your details are up to date and accurate. Â
• We contract with experts in their fields to provide much of the programme content - coaches, trainers, facilitators.

We will only share your data with third parties for their own purposes in very specific circumstances, for example:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.For example, if the programme coach or trainer would like to contact you for additional opportunities to use their services.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so.

 

These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

To help carry out our programme administration we currently use the following companies, who will process your personal data as part of their contracts with us:

• Your Membership
• Teachable
• Form Assembly
• Typeform
• Mailchimp
• Eventbrite
• Ontraport

 

8. What are your rights over your personal data?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
• A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.

Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.

• That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
  
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.

You can contact us to request to exercise these rights at any time by contacting us directly at info@cloresocialleadership.org.uk.

If we choose not to action your request, we will explain the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as to complete a programme once started.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

9. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.

If you have an account, log in into your Clore Social Leadership account, visit the ‘My Account’ area and change your preferences.

Write to our Operations Director at Clore Social Leadership at our address: Clore Social Leadership, 7 Bell Yard, London WC2A 2JR

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

10. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

11. Refund Policy

By completing your registration for an Online Course and making a payment of full or installment fee, you agree to the following Terms and Conditions:

Under this refund policy and under guidance of the Consumer Contracts Regulations 2013, you have the right to cancel your booking at any time at the following terms:

11.1 Our refund policy is as follows: our cancellation period is 14 days. Any purchase cancelled within 14 days of payment will be eligible for a full refund (unless you have started the course).

11.2 Once you begin the course, you are no longer eligible for a full refund, even if you ask for a refund within 14 days of payment.

11.3 Once a course has been redeemed, we cannot grant a refund.

11.4 All refund requests should be sent to info@cloresocialleadership.org.uk or posted to: Clore Social Leadership, 7 Bell Yard, London WC2A 2JR.

11.5 Any refund will take up to 30 days to process.

11.6 As a UK training provider, The Conditions shall be governed by and construed in accordance with the laws of England and you irrevocably submit to the exclusive jurisdiction of the courts of England.

12. Any Questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

• Email us at info@cloresocialleadership.org.uk
• Or write to us at Data Protection Officer, Clore Social Leadership, 7 Bell Yard, London WC2A 2JR

This notice was last updated on 06/10/2020

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Clore Social Leadership uses your data; for example we will explain things such as our procedures for collecting and storing the information that you provide as a participant on one of our programmes.

We hope the following sections will answer any questions you have but if not, please do get in touch with us at info@cloresocialleadership.org.uk.