WorkInConfidence

Privacy Policy for all WorkInConfidence services

(v2.0 last updated 25th May 2018)

This Privacy Policy is to make clear your rights on how we use your data, and our obligations to you.

Who We Are

We are WorkInConfidence Limited, a company incorporated in England and Wales with registered address at 1 Wesley Gate, 70/74 Queens Road, Reading, RG1 4AP and registration number 08255296.  We are the owner and operator of:

  • WorkInConfidence
  • SpeakInConfidence
  • PulseInConfidence
  • ReferenceInConfidence
  • 360Now
  • TwoWayVision

(each a “Service” and together the “Services”).

Your Privacy – All Services

Our obligations, and your security and privacy, are key to us and when you use any of the Services we ensure that all personal data we hold is held securely.  We comply with all appropriate data privacy laws, including in the UK, the Data Protection Act 1998 and in the EEA the General Data Protection Regulation (GDPR). We act in the following way:

What Data We Hold – See Section Relevant to the Service You Use

SpeakInConfidence – Data We Hold and Purpose

For SpeakInConfidence users we may hold the following personal information:

User:  Any information you enter into the system.  When you register this is usually only your email.  This may also have been provided by your organisation. We use it to allow you access to the system, provide message notifications and send you passwords. We also process and save messages you send and receive in the system and other data you add and complete (but these do not show your identity to your organisation unless you self-identify) and enable management in your organisation to see messages and data about usage.  We process this information as we have a contractual agreement with your organisation to provide this Service to you and them.  As part of the Service we therefore have a legitimate reason to process the data.

Admin User or Manager on the system: If you are an “Admin User” or “Manager” on the system then we will also hold your name, job role and possibly phone number. This is necessary to ensure that admin and manager privileges and participation are assigned and recognised appropriately. Again, a legitimate thing for us to do. 

Client contact: If you are an individual that we interact with as a client as well as a User, then we may also use your personal data to fulfil our contractual obligations with your organisation, for example, to send bills and also to keep you up to date with information about the Services. You can opt out of hearing about Services at any time.

SpeakInConfidence – Retention Periods For Personal Data

Given the nature of topics which users may raise on SpeakInConfidence, we hold data on users and dialogues for up to seven years after your details have been added to the system, in case you need to return to the topic to review what you raised, and responses, at any stage.

If any organisation ceases to be a client of SpeakInConfidence, we will remove all of its data and that of its staff/users within 3 months of their ceasing to be a client, or within 15 months of their ceasing to be a client if they have asked for a 12 months run off period.

If you leave an organisation, we will remove your data from the system as soon as the organisation notifies us that you have moved on. We will also delete any personal data that is identifiable to you from the system at your request.

PulseInConfidence – Data We hold and Purpose

For PulseInConfidence users we may hold the following personal information:

User:  Any information you put into the system when you register – usually this is only your email, but may include your phone number.  This may also have been provided by your organisation. We use it to allow you access to the system, provide message notifications and send you passwords. We also process and save input you enter into the system and enable management in your organisation to see results, feedback, messages and data about usage.   We process this information as we have a contractual agreement with your organisation to provide this Service to you and them.  As part of the Service we therefore have a legitimate reason to process your data.

Admin User or Manager on the system: If you are an “Admin User” or “Manager” on the system then we will also hold your name, job role and possibly phone number. This is necessary to ensure that admin and manager privileges and participation are assigned and recognised appropriately. Again, a legitimate thing for us to do. 

Client contact: If you are an individual that we interact with as a client as well as a User, then we may also use your personal data to fulfil our contractual obligations with your organisation, for example, to send bills and also to keep you up to date with information about the Services. You can opt out of hearing about Services at any time.

PulseInConfidence – Retention Periods For Personal Data

We hold data on our users and clients for the latter of up to three years after the latter of when they were added to the system or they last used the system, incase they need to return to the system, and to give further input. 

If any organisation ceases to be a client of WorkInConfidence, we will remove all of its data and that of its staff either within 3 months of their ceasing to be a client, or within 15 months of their ceasing to be a client if they have asked for a 12 months run off period. 

If you leave an organisation, we will remove your data from the system as soon as the organisation notifies us that you have moved on. We will also delete any personal data that is identifiable to you from the system at your request.

360Now – Data We hold and Purpose

For 360Now users we may hold the following personal information:

All Users:  Any information included when you are registered on or are added to the system – usually this is name and email.  This will usually have been provided by your organisation or a colleague. We use it to allow you access to the system, provide message notifications and send you passwords. If you are completing an Appraisal we also process and save input you enter into the system and make it available to our client organisation and the subject of the 360 Appraisal.  We process this information as we have a contractual agreement with the organisation for whom we are providing 360Appraisals to provide this Service to you and them. As part of the Service we therefore have a legitimate reason to process this data.

Subject of 360 Appraisal (“Appraisee”): We hold responses completed on 360 Appraisals about you. This is considered personal data because it is considered to be an opinion about you and could allow you to be identified. We hold this because we have a legitimate interest to do so. You can always request this to be removed by contacting [email protected]  If you are adding other people to complete for you, please ensure you have their permission to do so.

Person Completing a 360 Appraisal for others (“Appraiser”): If you are completing a 360 Appraisal for others, then we got your email address from the organisation we are working for or the Appraisee. We hold your name and email address under legitimate interest. You can always request this to be removed by contacting [email protected] 

Client contact: If you are an individual that we interact with as a client as well as a User, then we may also use your personal data to fulfil our contractual obligations with your organisation, for example, to send bills and also to keep you up to date with information about the Services. You can opt out of hearing about Services at any time.

360Now – Retention Periods For Personal Data

We hold data on our users and clients for the latter of up to 7 years after were added to the system or you last used the system, incase you need to return to the system, and to give further input or to access your historic 360 Appraisals.

If any organisation ceases to be a client of WorkInConfidence, we will remove all of its data and that of its staff either within 3 months of their ceasing to be a client, or within 15 months of their ceasing to be a client if they have asked for a 12 months run off period.

If you leave an organisation, we will remove your data from our system as soon as the organisation notifies us that you have moved on. We will also delete your personal data from the system at your request. 

TwoWayVision – Data We hold and Purpose

For TwoWayVision users we may hold the following personal information:

All Users:  Any information when you are registered on or are added to the system – usually this is email and possibly name.  This will usually have been provided by your organisation. We use it to allow you access to the survey system to complete surveys and to send you reminders. If you are completing a survey we also process and save input you enter into the system and make it available to our client organisation and enable management in the organisation to see results, feedback and data about usage.  We process this information as we have a contractual agreement with your organisation to provide this Service to you and them. As part of the Service we therefore have a legitimate reason to process your email address. 

Client contact: If you are an individual that we interact with as a client as well as a User, then we may also use your personal data to fulfil our contractual obligations with your organisation, for example, to send bills and also to keep you up to date with information about the Services. You can opt out of hearing about Services at any time.

TwoWayVision – Retention Periods For Personal Data 

We retain email addresses for the period of the survey, and usually one month thereafter, after which they are deleted.

We retain survey input for up to 3 years to allow time to do benchmarking.

If any organisation ceases to be a client of WorkInConfidence, we will remove all of its data and that of its staff either within 3 months of their ceasing to be a client, or within 15 months of their ceasing to be a client if they have asked for a 12 months run off period. 

If you leave an organisation, we will remove your data from our system as soon as the organisation notifies us that you have moved on. We will also delete your personal data from the system at your request.

ReferenceInConfidence – Data We hold and Purpose

For ReferenceInConfidence users we may hold the following personal information:

All Users:  Any information when you are registered on or are added to the system – usually this is your name, email and possibly phone number.  This will usually have been provided by your organisation or a contact who requires a reference. We use it to allow you access to the system, provide message notifications and send you passwords. If you are completing a reference we also process and save input you enter into the system and make it available to our client organisation and possibly the Applicant.  We process this information as we have a contractual agreement with the organisation for whom we are providing the ReferenceInConfidence service. As part of the Service we therefore have a legitimate reason to process your email address.  

Subject of a ReferenceInConfidence reference (“Applicant”): We hold responses completed on references about you. This is considered personal data because it is considered to be an opinion about you and could allow you to be identified.  You will have been given the opportunity to add those people completing for you, and to opt out of the process if you wished.  We hold this because we have a legitimate interest to do so.  You can always request this to be removed by contacting [email protected]  If you are adding other people to complete a reference for you, please ensure you have their permission to do so, you are responsible for this.

Person Completing a ReferenceInConfidence reference for others (“Referee”): If you are someone completing a reference for others, then we got your email address from the organisation we are working for or the Applicant.  We hold your name, email address and possibly phone number under legitimate interest. If you are completing a Reference we also process and save input you enter into the system make it available to our client organisation and possibly the subject of the reference, but as indicated by the system this is aggregated and partially anonymised. You can always request this to be removed by contacting [email protected] 

Client contact: If you are an individual that we interact with as a client as well as a User, then we may also use your personal data to fulfil our contractual obligations with you, for example, to send you bills and also to keep you up to date with information about the Services. You can opt out of hearing about Services at any time.

ReferenceInConfidence – Retention Periods For Personal Data

We hold data on our users and clients for the latter of up to 2 years after were added to the system or you last used the system, incase you need to return to the system, and to give further input or to access your historic references.

If any organisation ceases to be a client of WorkInConfidence, we will remove all of its data and that of its staff either within 3 months of their ceasing to be a client, or within 15 months of their ceasing to be a client if they have asked for a 12 months run off period.

If you leave an organisation, we will remove your data from our system as soon as the organisation notifies us that you have moved on. We will also delete your personal data from our system at your request.

WorkInConfidence – Data We Hold and Purpose

For WorkInConfidence (our overall platform) users we may hold the following personal information:

User:  Any information you enter into the system.  When you register this is usually only your email.  This may also have been provided by your organisation. We use it to allow you access to the system, provide message notifications and send you passwords. We also process and save messages you send and receive in the system – but these do not show your identity to your organisation.  We process this information as we have a contractual agreement with your organisation to provide this Service to you and then enable management in your organisation to see results, feedback, messages and data about usage.  As part of the Service we therefore have a legitimate reason to process your data.

Admin User or Manager on the system: If you are an “Admin User” or “Manager” on the system then we will also hold your name and job role. This is necessary to ensure that admin and manager privileges and participation are assigned and recognised appropriately. Again, a legitimate thing for us to do. 

Client contact: If you are an individual that we interact with as a client as well as a User, then we may also use your personal data to fulfil our contractual obligations with your organisation, for example, to send bills and also to keep you up to date with information about the Services. You can opt out of hearing about Services at any time.

WorkInConfidence – Retention Periods For Personal Data

Given the nature of topics which users may raise on WorkInConfidence, we hold data on users and dialogues for up to 6 years after your details have been added to the system, in case you need to return to the topic to review what you raised, and responses, at any stage.

If any organisation ceases to be a client of WorkInConfidence, we will remove all of its data and that of its staff either within 3 months of their ceasing to be a client, or within 15 months of their ceasing to be a client if they have asked for a 12 months run off period.

If you leave an organisation, we will remove your data from our system as soon as the organisation notifies us that you have moved on. We will also delete your personal data from our system at your request.

Security of Your Data

WorkInConfidence take the security of your data very seriously and take steps to ensure the safety and security of such data. This includes steps such as encrypting the data from your browser to our servers and, where possible, encrypting the data held in our databases.

Each app is designed with security in mind and include measures such as data anonymisation, encryption and safe storing of passwords, which are salted and hashed.

We have regular security audits undertaken on our SpeakInConfidence application by an independent, third party, security expert. Any improvements highlighted by these audits are implemented promptly.

Google Analytics – All Services

For all of the Services, if you visit our website or use the Services then we use cookies to improve your experience of our website, for example to keep you logged in. 

The Services use Google Analytics and possibly other web analytics tools to collect information about how visitors use our site and Services. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.  Google can provide more details about their cookies.

We also generate log files from various servers: this will include an IP address assigned to you or, more likely, to someone who provides you with Internet access.

Our website and Services use cookies to distinguish you from other users of our website in order to provide increased functionality and service. This not only helps us to provide you with a better experience, but also to help us improve our website and services.

Unless you have adjusted your web browser settings (if and where possible) to refuse cookies, our system will issue cookies as soon as you visit our website or related online services. However in doing so, you may find that certain functionality or Services may be impaired or unavailable to you.

The cookies we use only contain anonymous information to improve the services we offer, and do not contain personal information.

It is also important to point out that not all cookies used by this website are created by us. These cookies (referred to as third party cookies) are covered below.

We also use aggregated anonymised data across the services to give overall usage statistics and benchmarking indicators, but these are never used in a way which would identify any individual or organisation.

Transfers to Third Countries or Third Parties – All Services

If your organisation is within the EU, we do not transfer or process data outside the European Economic Area unless we have your specific consent or where the nature of the processing requires it (for example, where we are emailing a party to your matter who is based outside the EEA, or because you have chosen to use an email or other communications service which routes data outside the EEA). Your data is held within the EEA, in Dublin on our behalf by Amazon Web Services, but we may substitute another provider at any time within the EEA.  If your organisation is outside of the EEA we may hold your data regionally to reduce processing speeds.

It is possible that services that we use such Amazon Web Services and Google transfer personal data outside the EEA but we ensure our partners are GDPR compliant.

Your Rights – All Services

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Because of the protections We build in to the Services, often User Input is not connected to a username so We may not be able to provide you with all user input You have completed.  Subject to this, You have the following rights:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data We hold about You and to check that We are lawfully processing it. You can do this by contacting [email protected]  Legally we must respond within a month.  Normally we will respond within a few days.
  • Request correction of the personal data that We hold about You. This enables You to have any incomplete or inaccurate data We hold about You corrected, though We may need to verify the accuracy of the new data You provide to Us.
  • Request erasure of your personal data. This enables You to ask Us to delete or remove personal data where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove your personal data where You have successfully exercised your right to object to processing (see below), where We may have processed your information unlawfully or where We are required to erase your personal data to comply with local law. Note, however, that We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of your request.
  • Object to processing of your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes You want to object to processing on this ground as You feel it impacts on your fundamental rights and freedoms. In some cases, We may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables You to ask Us to suspend the processing of your personal data in the following scenarios: (a) if You want us to establish the data’s accuracy; (b) where our use of the data is unlawful but You do not want Us to erase it; (c) where You need Us to hold the data even if We no longer require it as You need it to establish, exercise or defend legal claims; or (d) You have objected to our use of your data but We need to verify whether We have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to You or to a third party. We will provide to You, or a third party you have chosen, your personal data where practicable in a structured, commonly used, machine-readable format. 
  • Withdraw consent at any time where We are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If You withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No Fees: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Data Protection Officer and Contact

To exercise any of the above rights contact our Data Protection officer Tim Martin, who is also our Chief Executive by emailing [email protected]  Legally we must respond within a month.  Normally we will respond within a few days.

Complaining  

If you are unhappy with our Data Protection Processes you may complain to the Data Protection Registrar https://ico.org.uk/. We would hope that in the first instance you would give us the opportunity to rectify the matter.