Insights Learning & Development Limited (“Insights”) is registered in Scotland as company number SC107074. Our registered office and global headquarters are located at Terra Nova, 3 Explorer Road, Dundee, DD2 1EG, Scotland, United Kingdom. We offer learning & development products and services either working directly, or through our international partners, with numerous multinational organizations and public-sector bodies globally.
For more information about Insights and other members of The Insights Group of companies, please visit https://www.insights.com/ca/what-we-do/.
This policy sets out the how we collect and process personal data through use of our products and services, use of our website, completion of our Insights Discovery Evaluator questionnaires and other collection of personal data related to our business. Our Insights Distributor Evaluator questionnaires are designed for adults and therefore our questionnaires and websites are not intended for children (under 18 years of age) and we do not knowingly collect data relating to children.
Insights is registered with the UK Information Commissioners Office (ICO) under registration number Z7145849. The ICO is the relevant supervisory authority for Insights Learning & Development Limited.
Data will be collected in order for customers, suppliers and other business contacts to receive or supply products and services, as applicable, to manage contractual relationships on an ongoing basis, for account administration, and to provide updates and news about our products and services, events and other information that we think may be of interest to you.
Data collected may include the following, where provided:
Other than in respect of Insights employees, we do not collect special category data (which includes details about race or ethnicity, religious beliefs, sex life or sexual orientation, trade union membership, health and genetic and biometric data).
Where we need to collect personal data by law or under the terms of a contractual arrangement, and you fail to provide that data when requested as being mandatory, we may not be able to fulfil the terms of the contract or relationship that we have with you.
We may collect your personal data in the following direct ways:
Data will be collected:
Simply visiting Insights websites does not require you to submit personal data (although our cookies may collect certain personal data for statistical and analytical purposes). If however you ask us for information, register with us, sign up to attend any of our events or receive our marketing material or otherwise express an interest in our products or services or report a problem, we collect any personal data submitted to us at that time.
When you visit our websites and access resources on our websites, we may automatically collect Technical Data and Usage Data. We collect this data via cookies including, where available, your IP address, operating system and browser type, for system administration.
We may also collect personal data about you from third parties or publicly available sources including:
Personal data of customers (including Identity, Contact, Technical, Usage and Profile Data) will be used:
You can manage your marketing and other contact preferences through our Marketing Team at firstname.lastname@example.org. You will receive marketing communications from us for a certain period of time if you have requested information from us or purchased products or services from us or if you provided us or one of our service providers (including event organizers) with your details and, in each case, you have not opted out of receiving marketing.
Personal data (including Identity, Contact, Technical and Usage) will be used to form a view on what we think you may want or need, or what products, services or offers may be of interest to you (referred to as marketing) in order to provide you with further information on our products and services. You can manage your marketing and other contact preferences through our Marketing Team at email@example.com. You will receive marketing communications from us for a certain period of time if you have requested information from us with your details and, in each case, you have not opted-out of receiving marketing. Where you opt-out of receiving marketing messages, this will not apply to personal data provided subsequently if you then choose to purchase products or services and in relation to other subsequent associated activities or transactions.
We also use aggregated data, including (i) cookies data and (ii) respondent data taken from the responses to the Insights Discovery Evaluator questionnaire, for the purposes of research and product development. Aggregated data used within our research and product development functions is derived from your personal data but no personal data will be published or disclosed since it is aggregated and anonymised for the purposes of research and product development, and therefore no person is identified or identifiable from such data.
We also perform analytics, such as trends, sales intelligence, marketing effectiveness (such as click and open rates), uptake and progress.
We may use personal data collected by cookies for functional and analytical purposes. Please see our separate Cookies Policy for more information, including relating to those cookies which are strictly necessary for the provision of products and services to you.
We may have to share your personal data with third parties for processing or sub-processing purposes. We undertake a selection process and periodic review in relation to processors and sub-processors. We may also share your personal data with controllers. We enter into data processing agreements with both processors and controllers, as applicable.
We share your personal data with third parties and for the purposes as set out below:
Group Affiliates (acting as processors):
Third parties (acting as processors):
Third parties (acting as controllers):
We require all third party suppliers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our suppliers to use your data for their own purposes, and we require that processing is in accordance with our instructions. We enter into written data processing agreements with suppliers that receive personal data from us.
A list of third party suppliers to whom we transfer personal data can be provided upon request. We do not sell any personal data we collect.
We share your personal data with third parties some of whom may be located outside the EEA as follows:
A list of third parties to whom we transfer personal data outside the EEA, together with the relevant safeguard mechanism can be provided upon request.
We are committed to ensuring the security of processing and the ongoing confidentiality, integrity, availability and resilience of systems and services as such relate to personal data that we hold, in order to prevent accidental or unlawful destruction, loss, alteration or unauthorized disclosure or access.
In our roles as both controller and processor, we implement appropriate technical and organizational measures to ensure a level of information security appropriate to the risk. Our IT infrastructure and software applications are built to provide secure deployment of services, encrypted storage of back-up data with end-user privacy safeguards, encrypted communications between services, and safe operation by customers.
Additionally, our employees, associates and Insights Practitioners are bound to comply with confidentiality provisions and privacy policies and procedures, in addition to completing mandatory privacy & security awareness training. We have various policies that specifically address responsibilities and expected behaviour with respect to the protection of confidential information.
We have procedures for incident and breach investigation and notification. Where our assessment of the likely risk to the individuals involved concludes a breach of personal data may result in risk to the rights and freedoms of individuals, we shall promptly inform individuals (and associated controllers and the relevant supervisory authority where applicable) of any such breach, as required by law and in accordance with any contractual terms.
You should note that where we have given you (or where you have chosen) a username and/or password which enables you to access certain parts of our websites, or use our products and services, you are responsible for keeping the username and password confidential. You should not share these details with anyone.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected the data, including for the purposes of satisfying any legal, accounting or reporting requirements.
The periods that we retain data for are set out in our internal Data Retention and Destruction Policies. This sets out the types of data that Insights collects and the retention periods and destruction methods for such data.
To determine the appropriate retention periods for personal data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the personal data and whether we can achieve those purposes through other means, together with applicable legal requirements, including certain statutory retention periods. For example, by law, we have to keep: (i) certain customer and supplier information for seven years for tax and audit requirements (this period is 10 years in relation to Insights France and Insights Group Deutschland).
We do not store credit/debit card information nor do we share customers details with any 3rd parties.
If you require further information on specific retention periods, please contact us.
You have the right to:
Where we are a processor in respect of your personal data, we will inform the relevant controller of your request and assist and co-operate with the controller for them to fulfil the request.
You normally will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, if a request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, in certain circumstances, we may refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity or verify your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
It is important that the personal data we hold about you is accurate and current. In order for us to ensure this, please keep us informed of any changes at any time to the personal data that we hold about you.
The Data Protection Officer
Insights Learning and Development Limited
3 Explorer Road
Tel: +44 (0)1382 908050
Whilst we hope that you will not need to, if you do wish to complain about how we handle personal data, you may contact our Data Protection Officer as above.
You also have the right to complain to the relevant data protection Supervisory Authority. The UK Information Commissioner’s Office (ICO) is the relevant Supervisory Authority for Insights and its European branch offices. We would appreciate the chance to deal with your concerns before you approach the ICO. You can however contact the ICO as follows:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Telephone: + 44 303 123 1113