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Experience Portal Privacy Notice

Welcome to the Insights Experience Portal (“Experience Portal”)! Before you go any further or provide any personal information about yourself or anyone else, please make sure that you have read and understand this privacy notice. If you are providing personal data about, or on behalf of, another person, you must make sure that you tell them what you are providing to us and make them aware of this privacy notice before passing any such personal data on to us. You must not provide any personal data to us where you do not have the right to do so.  

This privacy notice contains important information on who we are and how and why we collect, store, use and share your personal data through the Experience Portal.  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 want you to be well-informed about how and why we collect your personal data and how it is used throughout the process. So, please feel free to ask us questions, raise concerns or exercise your rights (these are detailed further down) at any time. Our Data Protection Officer can be contacted directly at: dpo@insights.com 

We try to continuously improve our processes, so we may update this privacy notice from time to time.  It is important that you check the website for updates to the privacy notice regularly to make yourself aware of any changes which may affect you.  

Who are we?  

This privacy notice is designed to cover Insights Learning and Development Limited, a company registered in Scotland with company number SC107074 with its registered address at Terra Nova, 3 Explorer Road, Technology Park, Dundee, DD2 1EG and each of its subsidiaries and affiliates (collectively, “Insights”, “we”, “us” or “our”). This Privacy notice does not govern the practices of entities which Insights does not own or control.   

We collect, use and are responsible for certain personal data about you.  The personal data we collect and use about you will be processed in accordance with all relevant laws and we act as a data controller in respect of such personal data. This will, generally, be in accordance with the UK Data Protection Act 2018 and the European General Data Protection Regulation, which applies across the European Union.   Where you provide personal data to one of our subsidiaries, we may also be responsible for handling your personal data in accordance with the local data protection laws of our subsidiary.  

If you are a customer of an Insights distributor or partner, you should also read the privacy notice of that distributor or partner who may use your personal data for its own purposes, provided it has a lawful basis to do so.  Insights is not responsible for the data processing activities of its distributors or partners, who act as independent controllers. As independent controllers, they determine the purpose, manner and means of their processing activities.        

This privacy notice is designed to cover your use of the Experience Portal and our collection, retention and use of personal data collected about you through the Experience Portal.   

What is the Experience Portal? 

Our Experience Portal is our dedicated learner platform that facilitates your self-awareness journey as a learner with Insights.  The platform is designed to be experience focused allowing you to complete our evaluator questionnaires as part of our multiple experience types.  

When you complete our evaluator questionnaire, your answers will be processed by our algorithm to produce a "Profile" which is personal to you. Your Profile consists of graphs and sections of text describing how someone with your expressed preferences can understand more about themselves, how to understand others better as well as recommendations for addressing important or challenging topics for someone with your preferences and/or someone with the opposite preferences. 

Your Profile will be provided to you as part of an experience and accessible through the Experience Portal after the experience. 

However, if you are completing a questionnaire through a third party such as a partner or distributor of Insights, you should check their privacy notices for any additional uses or purposes. If you are unsure whether you are accessing one of our evaluator questionnaires through a partner or distributor, please get in touch and we will assist you.  

Personal data we collect about you 

We generally collect your personal data directly from you when you access, use, or register for the Experience Portal; however, we sometimes also collect personal data from other sources such as your employer, organisation, colleagues, or identified third parties such as distributors or partners. For example: your organisation may provide us with your name and email address so that we can invite you to a learning experience.   Whatever the manner of our collecting of your personal data, we do so as set put in this privacy notice.   

When you access or use the Experience Portal, we may collect the following information:  

  • Your full name 
  • Your work email address 
  • A secondary email address 
  • Your known as name
  • Your demographic data – collected on a per evaluator basis 
  • Preferred Language
  • Pronouns
  • Country of Residence (Optional) 
  • Age Range (Optional) 
  • Job Title (Optional) 
  • Length of Service Range (Optional) 
  • Job Level (Optional) 
  • Sector (Optional) 
  • Sub-Sector (Optional) 
  • Evaluator Responses. 

 This personal data is required to enable us to provide our products and services, such as the Personal Profile and Team Wheel, to you, your organisation or employer, and for the purposes set out within this privacy notice. If you do not provide personal data we ask for, it may delay or prevent us from providing some of our products and services or it may prevent you from receiving the full benefit of them.  

How your personal data is collected 

We generally collect personal data directly from you when you sign up to access and use the Experience Portal.   However, we may also collect information from third parties such as:  

  • Your employer or organisation, (i.e., we may receive your email address from a colleague or employer when they wish to invite you to a learning experience); 
  • An Insights Accredited Practitioner or Client Administrator (i.e., when they wish to invite you to or set up a learning experience); or 
  • Our partners or distributors who use Insights as part of their provision of products and services to you.  

 The only information which your employer, organisation or an Insights Accredited Practitioner should provide is your name and work email address.  We use this information to send you an invitation to use and access the Experience Portal. 

Cookies 

We do use cookies when you access the Experience Portal.  When we use cookies, we do so in line with our cookie policy, which can be found here: [INSERT COOKIE POLICY] 

How and why we use personal data 

Under data protection law, we can only use personal data if we have a proper reason for doing so, e.g.: 

  • to comply with our legal and regulatory obligations; 
  • for the performance of our contract with you or to take steps at your request before entering into a contract; 
  • for our legitimate interests or those of a third party; or 
  • where you have given consent. 

A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests. 

The table below explains how we use personal data through the Experience Portal and our reasons for doing so: 

What we use your personal data for 

Our lawful basis 

To provide you with our products and services under a contract which we have with your employer and/or organisation.  

 For our legitimate interests or those of a third party – e.g., to support your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer.  

To create a ‘Profile’ based on your responses to our Insights Evaluator Questionnaire.  

For our legitimate interests or those of a third party – e.g., to support you and your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer. 

We also keep a copy of your evaluator responses on file to enable you to track your life-long learning journey by comparing various personal profiles which you have filled out and discover more about yourself and to enable Insights Accredited Practitioners to engage with you throughout your learning journey.  This enables us to provide the full benefit of our services to you as an individual.  

To create a ‘Team Wheel’ enabling you to see how you and others sit within your team and to understand and connect team members better.  

 For our legitimate interests or those of a third party – e.g., to support your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer. 

 

We also keep a copy of your Team Wheel position on file to enable you to track your progress and to enable Insights Accredited Practitioners to engage with you and colleagues throughout your learning journeys.  By comparing your various Team Wheel positions, you will be able to tangibly see any changes in your preferences and in various teams throughout your lifelong learning journey.   This processing enables us to provide the full benefit of our services to you as an individual and walk alongside you in your discovery journey.  

To process your personal data through our algorithm to produce a personal profile unique to you. The personal profile is designed to help you to understand yourself better. 

For our legitimate interests or those of a third party – e.g., to support your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer. 

To debrief you on your personal profile either directly or through an Insights Accredited Practitioner.  

 For our legitimate interests or those of a third party – e.g., to support your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer.  The coaching is also designed to enable you to understand yourself better.  

To deliver a workshop or learning event to you and other colleagues and attendees.  

 For our legitimate interests or those of a third party – e.g., to support your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer.  The Experience is also designed to enable you to understand yourself better. 

To fulfil our legal obligations such as keeping a record of attendees for fire safety regulations.  

 

To give you access to the Experience Portal.  

For our legitimate interests or those of a third party – e.g., to support your employer and/or organisation in your professional and learning development and team building skills and to provide our products and services to you in accordance with the contract we have in place with your employer.  

To enable you to access and use our products and services as required. We ask for a secondary email address to allow you to recover your account if you have lost a password or to provide you with access to your profile when you have left the employer of the organisation through which you took the Evaluator Questionnaire.  

Seeking feedback on the products and services which we have provided to you.  

 For our legitimate interests or those of a third party – to assist us to provide products and services to a good standard.  

To manage our ongoing relationship.   

 For our legitimate interests or those of a third party – making sure that we are keeping in touch with our users throughout their learning journey.  

Updating and enhancing our internal records.  

To comply with our legal and regulatory obligations (e.g., making sure that records are accurate and up to date.) 
 

For our legitimate interests or those of a third party, e.g., making sure that we can stay connected with our users in relation to the provision of our services. 

Ensuring business policies are adhered to, e.g., 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. 

Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies. 

To comply with our legal and regulatory obligations. 

Operational reasons, such as improving efficiency, training, and quality. 

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 we can for you.  

Statistical analysis to help us manage our internal practices e.g., in relation to our financial performance, client base, work type 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 we can for you.  

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 us and for you.  

 
To comply with our legal and regulatory obligations. 

External audits and quality checks, e.g., for ISO accreditations and the audit of our accounts. 

For our legitimate interests or those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at high standards. 

 
To comply with our legal and regulatory obligations 

To provide copies of your Profile and Team wheels to Insights Accredited Practitioners within our distributors or partners.  

For the legitimate interests of Insights or those of   a third party – e.g., to allow our distributors and partners to provide their products and services to you which incorporate Insights’ products and services.   

 

Canada PIPEDA 

If you are an individual based in Canada covered by PIPEDA, we will ask for consent to process your data where we are required to do so.  We may also imply your consent if consent may be reasonably inferred from your actions or inactions. When determining the appropriate form of consent, we take into account the sensitivity of the personal information, the reasons we are collecting it, and the reasonable expectations of you, the data subject. When using personal data for a new purpose, we will document that new purpose and ask for consent again.  

In this case, before you complete an Evaluator Questionnaire or attend a workshop or event, we will provide you with a copy of our latest Privacy Notice and will ask you to confirm that you have both read it and understood it.  Please do not complete the Evaluator Questionnaire or attend any events or workshops unless you are satisfied with the purposes and manner in which we will use and process your personal data, as set out in this Privacy Notice.  

Where we rely on implied consent, we will only process your personal data in the manner set out in this Privacy Notice, as may be amended from time to time.  Whenever you fill out an Evaluator Questionnaire or attend a workshop or event you must read the Privacy Notice before providing any information to us. Please note that the personal data which you provide to us may be transferred from Canada to the United Kingdom or the European Union.  This is covered in the “Data Transfers” section below.  

California Consumer Privacy Act – ‘Selling of personal data’ 

If you are a resident in California, we confirm that Insights does not sell your personal data to third parties as defined by the California Consumer Privacy Act.  

However, we may, in accordance with the California Consumer Privacy Act share your personal data with third parties who are business partners, service providers or other third parties (see above), provided that such parties have entered into agreements with us covering the use personal data. 

When we process your personal data, we will do so in accordance with this Privacy Notice and all applicable laws.    

Profiles, Team Wheels, and our Algorithm 

Personal Profiles and Team Wheels 

When you provide personal data to us through one of our evaluator questionnaires, the answers which you give to our questions are processed by our unique algorithm which relies on our decades of experience and development of our intellectual property to produce a personal profile which is unique to you. Our ‘Profiles’ are designed to help you increase your self-awareness and are used in the context of a learning or coaching experience.  

Although we are using your data to create a ‘Profile’ we are not processing the data for ‘profiling’ as defined in the GDPR because we are not using the information for automatic decision-making purposes.   

In addition to the ‘Profile’ Insights may generate a ‘Team Wheel’ which identifies and plots each team member’s colour preferences from the ‘Profile’ on to a wheel shaped chart depicting your preferences and the preferences of others within your team.  Examples of teams include a functional departmental team, a collection of colleagues within your organisation or a collection of individuals at a learning event with you. It is designed to assist you and other members of your team to understand each other better and to communicate more effectively through using and understanding the colour preferences of each individual team member.  It does so by plotting team members colour preferences within the team wheel in a visual way, allowing team members to see where each team member sits in terms of their preferences.  Team wheels may be generated by Insights Accredited Practitioners, Client Administrators and Insights Administrators and may be shared with other members of your team. An example can be found here. 

Profiles and Team Wheels are usually linked to a learning experience organised by your employer or organisation. We have a legitimate interest to process your personal data for the creation of Profiles and Team Wheels, these are set out in the table above. You have the right to opt out of participating in Personal Profiles and/or Team Wheels at any time by contacting us by email: clientservices@insights.com. 

Please note that you may not receive the full benefit of the Learning experiences or Experiences Portal if you choose to opt out.   

The use and creation of Profiles and Team Wheels are governed by our Acceptable Use Policy, which can be found here: https://www.insights.com/insights-online-acceptable-use-policy/.  We ask all Insights Accredited Practitioners to use Profiles and Team Wheels in accordance with our Acceptable Use Policy.  Where a client, distributor or partner seeks to create or use Profiles or Team Wheels in a manner not consistent with the Acceptable Use Policy, they alone will be responsible for having a lawful basis in place for their processing.  This means that they must have their own privacy notice which tells you how and why they will process your data and the lawful basis for such processing.   Please make sure that you read all privacy notices given to you to ensure that you understand how your personal data is being processed.  

How and why we use special category personal data 

Generally, we do not process special category data of our users. However, in the event that we do, we will seek explicit consent to process such special category personal data.  

Who we share your personal data with 

We routinely share personal data with: 

  • Insights Accredited Practitioners who are trained in delivering learning experiences to participants or users; 
  • Administrative staff who assist with the organisation of learning experiences; 
  • Your employer or organisation e.g., an attendance record in respect of an Insights Experience or a Team Wheel to enable them to understand team members better; 
  • Our distributors and partners, where they are providing you with products and services incorporating Insights’ products; 
  • Service providers who carry out processing services on our behalf.  Where we use processors, we ensure that we have appropriate contracts in place with them and that they are under strict obligations to follow our instructions; and 
  • Other third parties where necessary to carry out your instructions.  

Members of the Insights Group also often share personal data with each other. We have intragroup agreements in place to allow for such transfers and to ensure that any personal data shared is adequately protected.  

We may provide your ‘Profile’ to an Insights Accredited Practitioner who may provide you with a copy of it as part of a learning experience, or coaching session.  The Insights Accredited Practitioner may be an employee or consultant of Insights, an employee or consultant of your employer or organisation or an employee or consultant of one of our partners or distributors. Where an Insights Accredited Practitioner is an employee or consultant of your employer or organisation, we call them “Client Practitioners” and where they are a consultant or employee of one of our partners or distributors, we call them “Licenced Practitioners”.   

Client Practitioners – within your organisation 

Where Insights Accredited Practitioners exist within your organisation, the Practitioners are responsible for promoting and delivering learning experiences within your workplace.  In order to assist them to do so and to support you in your Insights journey we allow them access to your colour preferences, Profiles and Team Wheels.  

Licenced Practitioners – employees or contractors of one of our partners or distributors 

Licenced Practitioners are responsible for promoting and delivering learning experiences to your organisation and consequently, to you.  In order to assist them to do so and to support you in your Insights journey we allow them access to your colour preferences, Personal Profiles and Team Wheels.  

We restrict access to your colour preferences, Personal Profiles and Team Wheels to:  

  • Insights Accredited Practitioners and Insights Administrators - to administer and provide learning experiences to you, either directly or at a workshop or event; 
  • Insights staff such as IT or Client Services to assist Insights Accredited Practitioners in their administering and provision of Insights products and services to you and in certain circumstances to follow your instructions where you exercise rights as a data subject; and 
  • Insights staff to assist in the smooth running of our products and services.  

We restrict access to Experience Portal to: 

  • Learners to access their own data; and 
  • Insights staff such as IT or Client Services to provide support.

Insights employees or contractors 

IT or Insights employees may only access your personal data where it is necessary for the due performance of their duties as instructed by us.  

Your employer or organisation 

Where Insights products and/or services are delivered to you by a Client Practitioner, Insights ensures that it has appropriate contracts in place with your employer to ensure that your personal data is protected.  We also have terms and conditions and guidance in place with all Insights Accredited Practitioners and Insights employees to ensure that they handle your data appropriately and safely.   

Where your employer processes any personal data which we provide to it for any purpose other than the purposes set out in this privacy notice, it does so as an independent controller and must have a lawful basis for such processing.  Where your employer is a controller, it is responsible for telling you about how and why it processes your data.    

Where your personal data is held 

Information may be held at our offices and those of our group companies, third party agencies, partners or distributors of Insights, service providers, representatives and agents as described above (see ‘Who we share your personal data with’). 

Some of these third parties may be based outside the European Economic Area or the location where you are based.   

Transferring your personal data out of the location in which you are based (international transfers) 

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, European Economic Area (EEA) or the location in which you are based, e.g.: 

  • with our offices or other companies within our group; 
  • with our service providers; 
  • With our clients; 
  • With our partners and distributors; 
  • if you are based outside the UK/EEA, we will transfer your personal data to our servers within the UK/EEA and back out to your location; and 
  • where there is an international dimension to the services we are providing to you.  

 We will only transfer your data internationally where we have a lawful basis to do so in accordance with applicable law.    

Transfer outside of Canada 

If you are based in Canada, we may share your Personal Data with subsidiaries and third parties outside of Canada (i.e., UK, EU, US).  We have policies and processes in place to ensure that the Personal Data is properly safeguarded at all times and have contracts in place with the third parties to provide a comparable level of protection while Personal Data is being processed by third parties outside of Canada. A list of third parties to whom we transfer Personal Data outside Canada, together with the relevant safeguard mechanism can be provided by contacting: dpo@insights.com.   

Further information 

If you would like further information about data transferred outside the UK or EEA, please contact our Data Protection Officer at dpo@insights.com. 

How long your personal data will be kept 

When we keep a copy of your personal data will do so for one of these reasons: 

  • to respond to any questions, complaints or claims made by you or on your behalf; 
  • to show that we treated you fairly; 
  • to keep records required by law; 
  • given that our products and/or services are intended to be part of a lifelong journey, we may keep your evaluator questionnaire responses and Team Wheels to track your development over the years.  You may request that we delete your personal data from our records at any time. If you want us to delete your personal data, please email clientservices@insights.com; and 
  • to anonymise it in order to do statistical analyses.  

We will keep personal data which we collected about you for as long as necessary for the purposes listed above. We will automatically delete or anonymise personal data collected through the Insights an evaluator questionnaire after 7 years of inactivity from you or upon your request, whichever is the earlier.   Should you wish us to delete any information which we hold about you, you should send an email to clientservices@insights.com. 

When it is no longer necessary to retain your personal data, we will delete or anonymise it so that it can no longer identify you.  When we do we may use such anonymised information for: testing our IT systems, research, data analysis, improving the service and developing new products and features. We may also share such anonymised information with others. 

Your rights 

You have the following rights, which you can exercise free of charge: 

Access 

The right to be provided with a copy of your personal data  

Rectification 

The right to require us to correct any mistakes in your personal data 

To be forgotten 

The right to require us to delete your personal data 

Restriction of processing 

The right to require us to restrict processing of your personal 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 

To object 

The right to object: 
—at any time to your personal data being processed for direct marketing (including profiling) 
— to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests. 

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, or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. 

If you would like to exercise any of those rights, please: 

  • email our Data Protection Officer at dpo@insights.com; and 
  • let us know what right you want to exercise and the information to which your request relates.  

We may ask for information to identify you and ask you for proof of your identity and address prior to providing you with any information.  

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. 

How to complain 

We hope that we can resolve any query or concern you may raise about our use of your information.  

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113. 

If you are not based in the UK and wish to complain to your data protection authority about our collection and use of your personal data, please find contact details for authorities in the EEA, Switzerland, and certain non-European Countries (including the US and Canada) here:  

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm 

Changes to this privacy notice 

This privacy notice was published on 21/12/2020 and last updated on 09/06/2021 

We may change this privacy notice from time to time, when we do, we will inform you via the version control on the website.  Please keep checking the website before providing us with any personal data to be sure that you are kept up to date. 

How to contact us 

Please contact our Data Protection Officer by post, email, or telephone if you have any questions about this privacy notice or the information we hold about you. 

Our contact details are shown below: 

Our contact details 

Insights Learning & Development Ltd 

Terra Nova 

3 Explorer Road 

Dundee 

DD2 1EG 

 

+44 (0)1382 908050 

Data Protection Officer contact details: 

DPO@insights.com 

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