Employees and our Contractors
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
How we use your information
When someone visits www.circl.org we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
When we receive an enquiry from you about our courses, we record your contact details including name, job title, business telephone number, email and postal address. We record this personal information in an electronic database and / or manual files in order to provide you with the information which you are seeking and also to follow up with you to enquire as to whether you have any questions or if you require any further information from us. Each time we contact you, we record a brief note on the file of the status of you enquiry. We will make contact with you at monthly intervals unless we are asked not to make contact again. In such a case, we will record this information on our system and ensure that your wishes are respected. Occasionally, we may send you newsletters unless you request us not to send you such communications.
Once a potential client becomes a client, we will use your personal information on the client record for the purposes of managing the business relationship with you. This may also include us contacting you on a monthly basis and making a record of such contact on our systems. Occasionally, we may send you newsletters unless you request us not to send you such communications.
Once a course has been booked, we collect personal information on the participants(s) from the client representative making the booking or from the participants directly. This includes name, business contact details and any other relevant information required for the purposes of administering the booking and delivering the training course.
In some circumstances, depending on agreements made between us and our clients and / or participants, feedback (written or oral) may be provided to the participant directly and / or to the client.
Under no circumstances, unless required by law or regulatory body, will we pass your personal information to any third parties, with the exception of our contractors who need such personal information to assist us in performing our contracts with our clients. We have contractual protections in place to protect any of your personal information which we need to disclose to our contractors.
Employees and Contractors
We collect personal information from both prospective employees / contractors and employees / contractors including name, address, qualifications, employment history and bank account information. In the case of prospective employees / contractors, we use this personal information to assess suitability for the position applied. In the case of employees, we use this personal information for the purposes of administering the employment contract and in the case of contractors, for the performance of the contract into which we have entered. This includes identifying training needs, carrying out performance appraisals, making payments and scheduling work assignments.
We do not disclose employee / contractor personal information to third parties unless we are required by law or regulatory body or if we are using a third party to provide services to us for which they need such personal information. In such a case, we will ensure that we have appropriate contractual measures in place with such third parties for the protection of your personal information.
We take our obligations to protect your personal information seriously. Should you have any questions about privacy at Circl, please contact us.
Why does Circl need to collect and store personal data?
In order for us to provide you with information about our services, we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Circl would contact you for additional consent.
Will Circl share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Circl in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Circl’ procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Circl use the personal data it collects about me?
Circl will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Circl is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Circl contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Circl at your request, can confirm what information we hold about you and how it is processed. If Circl does hold personal data about you, you can request the following information:
Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Circl or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Circl will need two of the following forms of ID when information on your personal data is requested:
Passport, driving licence, birth certificate, utility bill or bank statement from the last 3 months, rent book.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Circl’ collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Contact details of the Data Protection Officer:
Data Protection Officer contact details
Contact Name: Charlie Stainforth
Address line 1: 321 Market Place
Address line 2: Cirencester
Address line 3: GL7 2NX