Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| Term | Description |
|---|---|
| We, us, our | Mindset Practice Limited, a company incorporated in England and Wales with company number 11110121 and registered address Ashley House, 183 Church Road, Frampton Cotterell, Bristol, United Kingdom, BS36 2JX. |
| Personal data | Any information relating to an identified or identifiable individual. |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs,
philosophical beliefs or trade union membership. Genetic and biometric data (when processed to uniquely identify an individual). Data concerning health, sex life or sexual orientation. Information about criminal convictions and offences. |
| Data subject | The individual who the personal data relates to. |
Personal data we collect about you
We may collect and use the following personal data about you:
- your name and contact information, including email address and telephone number and company details;
- information to check and verify your identity, e.g. your date of birth;
- your gender, nationality and ethnic origin;
- your responses to standardised psychometrics including answers to individual questions, raw score totals, decile scores and related standardised feedback; responses to 360 feedback questionnaire including answers to individual questions, raw score totals and qualitative comments; responses to research questions in place to support and validate the integrity of its psychometrics (e.g., current level of engagement at work, intent to quit etc.);
- financial information such as your billing information;
- information to enable us to undertake credit or other financial checks on you;
- information about how you use our website, IT, communication and other systems; and
- your responses to surveys, competitions and promotions.
We collect and use this personal data to provide products and services to you or your employer. If you do not provide the personal data we ask for, it may delay or prevent us from providing products and services to you or your employer.
We also collect, use and share aggregated data such as statistical, qualitative or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
How your personal data is collected
We collect most of this personal data directly from you in person, by telephone, by email and/or via our website and our Mindset Practice Platform (MPP). This includes personal data you provide when you:
- apply for or use our products and services;
- use our 'MPP' online platform
- subscribe to our publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback or contact us.
However, we may also collect information:
- from publicly accessible sources based inside the UK such as Companies House;
- directly from a third party who could be based inside or outside of the UK or the EEA such
as:
- analytics providers such as Google;
- advertising networks such as Google, Facebook or LinkedIn;
- search information providers such as Google; and
- credit reference agencies.
- from a third party with your consent such as your bank or building society;
- from cookies, server logs and other similar technologies on our website; for more information on our use of cookies, please see our cookie policy https://www.mindsetpractice.com/cookiepolicy
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason such as:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract we are about to enter into or have entered into with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons for using your personal data |
|---|---|
| Providing products and services to you or your employer. | To perform our contract with you or your employer or to take steps at your request before entering into a contract. |
| Preventing and detecting fraud against you or us. | For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for you and/or us. |
| Conducting checks to identify our customers and verify their identity. Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business such as under health and safety law. | To comply with our legal and regulatory obligations. |
| Ensuring business policies are adhered to such as policies covering security and internet use. | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you. |
| Operational reasons, such as improving efficiency, training and quality control. | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service at the best price. |
| Completing research to understand and improve the efficacy of our programmes and products, as well to contribute to thought-leadership in the field of occupational psychology and human performance. | For our legitimate interests or those of a third party, i.e., to make sure we can deliver the best possible evidence-based solutions to you. |
| Ensuring the confidentiality of commercially sensitive information. | For our legitimate interests or those of a third party, i.e., to protect trade secrets
and other commercially valuable information. To comply with our legal and regulatory obligations. |
| Statistical analysis to help us manage our business such as in relation to our financial performance, customer base, product range or other efficiency measures. | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service at the best price. |
| Preventing unauthorised access and modifications to systems. | For our legitimate interests or those of a third party, i.e., to prevent and detect
criminal activity that could be damaging for you and/or us. To comply with our legal and regulatory obligations. |
| Updating and enhancing customer records. | To perform our contract with you or your employer before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party such as making sure that we can keep in touch with our customers about existing orders and new products. |
| Ensuring safe working practices, staff administration and assessments. |
To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party such as to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you. |
Marketing our services to:
|
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers. |
| Credit reference checks via external credit reference agencies. | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services. |
| External audits and quality checks and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our
accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations. |
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws such as:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else's) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above 'How and why we use your personal data'). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by using the 'unsubscribe' link in our marketing emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and will never sell it.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our products and services to you;
- other third parties we use to help us run our business such as marketing agencies, website hosts, lawyers, auditors, insurers and brokers;
- HM Revenue & Customs, regulators and other authorities;
- our bank; and
- credit reference agencies.
We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- share personal data with external auditors in relation to the audit of our accounts;
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
- share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring; usually, information will be anonymised, but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see 'How to contact us' below).
Where your personal data is held
Personal data may be held at our office, third party agencies, service providers, representatives and agents as described above (see above: 'Who we share your personal data with').
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: 'Transferring your personal data out of the UK and EEA'.
How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing products and services to you or your employer. Thereafter, we will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly; and
- to keep records required by law.
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA such as:
- with our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is a European and/or international dimension to the services we are providing to you or your employer.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an 'adequacy decision');
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law.
These are explained below.
Adequacy decision
We may transfer your personal data to certain countries, based on an adequacy decision. These include:
- all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the 'EEA');
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law such as:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims.
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if we seek to transfer your personal data on this ground.
Further information
If you would like further information about data transferred outside the UK/EEA, please contact us (see 'How to contact us' below).
Your rights
You have the following rights, which you can exercise free of charge:
| Rights | Description |
|---|---|
| Access | The right to be provided with a copy of your personal data. |
| Rectification | he right to require us to correct any mistakes in your personal data. |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data in certain situations. |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data. |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations. |
| To object | The right to object:
|
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
For further information on each of those rights, including the circumstances in which they apply, please contact us (see 'How to contact us' below).
If you would like to exercise any of those rights, please
- email or write to us—see below: 'How to contact us';
- provide enough information to identify yourself such as your full name and address and any additional identity information we may reasonably request from you; and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any query or concern about our use of your information (see below 'How to contact us'). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (www.ico.org.uk) or any relevant European data protection supervisory authority.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
- Full name of legal entity: Mindset Practice Limited
- Email address: support@mindsetpractice.com
- Postal address: Ashley House, 183 Church Road, Frampton Cotterell, Bristol, United Kingdom, BS36 2JX.
Changes to this privacy policy
We keep our privacy policy under regular review. This privacy policy was published in January 2022. We may change this privacy notice from time to time, when we do so we will post a new version to this website.
This agreement was last updated 28th January 2022.