Insights General Privacy Notice
Welcome to the Insights Privacy Notice (“Notice”).
If you are providing personal information about, or on behalf of, another person, you must make sure that you tell them what you are providing to us, why you are providing it and make them aware of this Notice. Please do not provide any personal information to us unless you have the right to do so.
There is a glossary at the end of this Notice which is designed to assist you in understanding some of the terms which we have used. Where we have defined terms or words, we have tried to link these throughout this Notice for your ease of reference. If there is anything within this Notice that you do not understand, please contact us.
Who are we?
We are Insights Learning & Development Limited, a company registered in Scotland with its registered address at Terra Nova, 3 Explorer Road, Technology Park, Dundee, DD2 1EG and company number SC107074. Any reference in this Notice to “we” “our”, “us” or “Insights” means Insights Learning & Development Limited and our relevant affiliates. Details of our subsidiaries can be found via our website. Insights is a "controller”, this means that we are responsible for deciding how we hold and use personal information about you.
This Notice governs our practices in relation to the personal data collected and processed by Insights only. It does not govern the practices of third parties which Insights does not own or control such as, but not limited to, our Direct Clients and/or Partners.
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Notice. If you have any questions about this Notice or would like to exercise your legal rights, please contact our DPO.
For more information about Insights and what we do, please visit our website.
Changes to this Notice and your duty to inform us of changes.
We continuously try to improve our processes and keep this Notice under regular review. Historic versions can be obtained by contacting us.
We may need to update this Notice from time to time. When we do, we will endeavour to keep you informed of updates via our website, applications and/or through the email address you provided to us. We also ask that you check our websites for any updates which may affect you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can contact us at any time to update your personal data.
We are constantly seeking to improve and develop new products, this means that when
Third Party links and Customers
Insights often deliver Insights Products directly to you in the context of a debrief, workshop, experience and/or learning event (an “Insights Event”). However, we also enable Customers to deliver Insights Products to you through Insights Accredited Practitioners.
Insights often accredits individuals to deliver and facilitate Insights Events, incorporating Insights Products, to you. Where you undertake the Insights Discovery Evaluator or attend an Insights Event facilitated or delivered by a colleague, it is likely that your employer has paid for them to be accredited to deliver Insights Products internally to your employer/organisation. We call your employer/organisation our “Direct Client” and Insights Accredited Practitioners within your employer or organisation are called “Client Practitioners”.
Insights provides Insights Products to Client Practitioners for the purposes set out in this Notice. Although Client Practitioners are accredited by Insights, as employees of your employer/organisation, they are under the control of our Direct Client and may act upon the Direct Client’s instructions. Where your employer/organisation instructs or permits a Client Practitioner to process your personal data in a manner not set out in this Notice, they must have a lawful basis to do so, and they should provide you with a separate privacy notice or statement covering their processing activities. We encourage you to read all privacy notices and/or privacy statements given to you.
If you are concerned about how your employer/organisation may process the personal data provided to them by Insights, please contact them prior to providing any personal data to us.
Insights is not responsible for any processing activities carried out by Direct Client’s, Insights Accredited Practitioners, Administrators, Partners or otherwise, for any purpose other than those purposes specified in this Notice.
Provision through one of our Partners
Insights sometimes provides Insights Products to third parties who may incorporate such Insights Products (including, but not limited to, Personal Profiles and Team Wheels which contain personal data about you), into their own programmes, products and/or services. Although we share your Personal Profile, Colour Preferences, Team Wheel or other Insights Products with them for the purposes set out within this Notice, these third parties ( known as “Partners”) are not controlled by Insights and may incorporate such data about you), into their own programmes, products and/or services.
As independent controllers, Partners are responsible for their own compliance with data protection laws including information requirements. The Partner should make themselves known to you and tell you how and why they process personal data as well as any lawful basis for their processing activities (should they deviate from the purposes set out in this Notice). We encourage you to read all privacy notices and/or privacy statements given to you. The privacy notices and statements provided to you by a Partner should tell you how Insights Products are incorporated into their programmes, products and/or services, how and why they use your personal data and their lawful basis for their processing.
If you have any concerns with the way in which one of our Partners is handling your personal data you will need to address that directly with them, however, please feel free to let us know. We take such matters seriously and will investigate all complaints and treat your communications with respect.
We generally collect personal data directly from you when you use or access our products and/or services. However, we may also collect information from third parties.
Our products are not intended for children, and we do not knowingly collect personal data relating to children.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Personal data collected about Customers
If you are a Customer we may collect:
Where you are acting on behalf of a Customer, we will collect personal data mentioned above to the extent that you are named by the Customer or are directly involved in a relevant activity. For example: if you are a named user of the company card or account which is to be used to purchase products and/or services, your identity data will be processed, or, if you are involved in the negotiation of a particular contract, we will process contact data and identity data to negotiate with you.
The personal data which we collect is usually collected in the following circumstances:
Participant personal data.
When you are undertaking an Insights Discovery Evaluator, we will collect the following personal data:
We may also collect personal data which you provide directly to us including, without limitation, when you fill in forms, provide feedback on our products and/or services or correspond with us in any manner, whether via post, email, through our website or otherwise.
In order to produce products such as the Personal Profile and Team Wheel, we require to collect personal data from you through a questionnaire which we call the “Insights Discovery Evaluator”. This psychometric tool uses a simple and memorable colour model to help people understand their style, their strengths and the value they bring to their team.
The Insights Discovery Evaluator consists of a series of statements, and you will be asked to rank how well you believe each statement describes you and/or your preferences. Your answers will be processed by our algorithm, which relies on our decades of experience and development of our intellectual property to produce a Personal Profile which is personal to you.
We also keep a copy of your Insights Discovery Evaluator responses on file to:
This enables us to provide and you to obtain the full benefit of Insights Products as an individual through our Insights Accredited Practitioners.
We may provide Insights Products (incorporating your personal data) to Insights Accredited Practitioners more than once and to more than one such practitioner (i.e. we will provide your Personal Profile to an Insights Accredited Practitioner to allow them to provide it to you in connection with an Insights Event which you are to attend. Please note: Insights Events may include attendees from other organisations which are not connected with your employer and/or organisation).
Although we are using your responses to the Insights Discovery Evaluator to create a Personal Profile and Team Wheel, we are not ‘profiling’ as defined in data protection law because we are not using your information for automatic decision-making purposes.
Please be aware that you are not obliged to provide us with your personal data. If you would not like to receive a Personal Profile, please do not complete our Insights Discovery Evaluator because once completed, a Personal Profile will automatically be generated.
Once a Personal Profile is created and printed, your personal data may be shared with an Insights Accredited Practitioner or Administrators and whilst we can delete any copies which we hold, we will not have control over any hard copies or electronic copies stored by your employer, organisation, Insights Accredited Practitioner or Administrator. Therefore, it is important that you also request that your Insights Accredited Practitioner and/or Administrator also deletes any copies which they hold from their own systems. Insights has no control over, and are not responsible for, which are not stored on our own internal systems.
You are entitled to opt out of being included in a Team Wheel. If you chose to opt out of the Team Wheel, you may not receive the full benefit of any Insights Event which you are to attend. If you would like to opt out of the Team Wheel you can do so by contacting us by email: firstname.lastname@example.org or by letting your Insights Accredited Practitioner know.
Once a Team Wheel is created and printed, your personal data may be shared with other members of your Team and/or with your employer or organisation. We can remove your wheel position from future electronic copies of Team Wheels, but we may not be able to remove you from hard copies or electronic copies which are already in existence (i.e. which are stored by your employer, organisation or Insights Accredited Practitioner separately from us). Therefore, it is important that you tell us that you wish to opt out as soon as possible and, where you have already been a part of a Team Wheel, that you request your removal from existing Team Wheels stored by your employer, organisation and/or Insights Accredited Practitioner. Insights has no control over, and is not responsible for, Team Wheels which are not stored on Insights’ internal systems.
If you choose not to provide us with your personal data, or if you choose to opt out, it may delay or prevent us from providing some of our products and/or services to you or it may prevent you from receiving the full benefit of them. Nevertheless, you are under no obligation to provide us with any of the personal data we request, and you are fully entitled to opt out at any time.
If you are an Administrator, we may also collect your contact information, the name of your employer and your login data.
We will receive personal data about you from various third parties.
Where you are a Participant, we may receive personal data from:
Where you are a Customer, we may receive personal data from:
Where you are an Insights Accredited Practitioner, we may receive personal data from:
More generally, we may receive technical data from the following third parties or publicly available sources:
Personal data collected when you visit our website
If you want to sign up to attend events, receive marketing material or otherwise express an interest in purchasing or receiving any of our products and/or services through our website, we will collect any personal data which you submit to us. When you use “Ask Insights” chat and “Contact us” through our website to ask questions or report problems, we will also collect the personal data which you provide through those functions.
Automated technologies or interactions
We also collect, use, and share aggregated data such as statistical 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. For example, we may aggregate your usage data to calculate the percentage of users accessing their Personal Profiles after a certain period or to analyse website use. 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 Notice.
Special Category Personal Data
We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the rare event that we will collect special category personal data, we will let you know before we collect it.
How and why, we use personal data
We will only use your personal data if we have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we may ask for consent, where required, to send marketing communications to you via email or text message. Where we have relied upon your consent for any reason, you have the right to withdraw consent at any time. We will tell you how to withdraw your consent when we ask for it, however, you can also withdraw it by emailing us, if that is easier for you.
If you are an individual based in a jurisdiction requiring consent to process your data, we will ask for your express consent before we collect or use your personal data unless we are able to infer your consent from your actions or inactions. When determining the appropriate form of consent, we consider the sensitivity of the personal information, the reasons we are collecting it, and your reasonable expectations as data subject. When using personal data for a new purpose, we will document that new purpose and ask for your consent to it.
Personal data collected about Customers (including Partners/distributors)
Participant personal data
We also collect more general personal data about you whether you are a Customer, business contact, Participant, Insights Accredited Practitioner or Administrator. This personal data is generally collected in so that:
If you would like a more detailed description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so, please request this from us by emailing email@example.com.
Where you are a Customer or an Insights Accredited Practitioner, we may use your personal information to send you updates (by email, text message, telephone or post) about product or service developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.
We usually have a legitimate interest in using your personal information for marketing purposes which 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:
Selling of personal data
Insights charges your employer or organisation for the Insights Products and/or services provided but does not sell personal data to third parties.
Who we share your personal data with
We may share your personal data with the parties set out below for the purposes set out in the tables above:
Where you are accessing Insights Products through one of our Partners, we may share your personal information with them to assist with administration, facilitation and delivery of Insights Products to you.
Members of the Insights group of companies may share personal data with each other. We have intragroup agreements in place to ensure that any personal data shared in this way is protected.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We limit access to your personal data to those who have a genuine need to access it for the purposes outlined in this Notice.
Where your personal data is held by us
Your personal data is held on our AWS European Data Centres, Azure Office 365 Cloud Services and may be held at our offices and the offices of our group companies, third party agencies, Partners, service providers, representatives and agents as described above.
Some of these third parties may be based outside the European Economic Area or outside of the location where you are based.
Transferring your personal data out of the location in which you are based - international transfers
To deliver our services to you, it is sometimes necessary for us to share your personal data outside the UK, the European Economic Area (EEA) or the location in which you are based, for example:
We will only transfer your data internationally where we have proper safeguards in place and there is a lawful basis for us to do so in accordance with applicable law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. These parties will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long your personal data will be kept
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period of time in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data that we hold, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You may request that we delete your personal data from our records at any time by emailing firstname.lastname@example.org.
We will keep your personal data only for as long as necessary for the purposes listed in the tables above. In respect of Insights Products, including the Personal Profile, Colour Preferences and Team Wheel, we will keep personal data required to generate these products for 3 years from the last date of activity, unless you ask us to keep it for longer or to delete them before the 3 year period has elapsed.
We will automatically delete or anonymise your personal data when the purpose for keeping it no longer applies. Personal data that has been anonymised can no longer identify you and the law regards such data as presenting no risk to individual freedoms. We can use anonymised data for any purpose.
So that you are completely clear about how we use your personal data, even after we have completely anonymised it, we may use anonymised information in various ways including, without limitation: testing our IT systems, research, data analysis, improving our service and developing new products and features.
We may also share anonymised information with others.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
The right to be provided with a copy of your personal data
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
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or for that data to be transmitted to a third party
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
If you would like to exercise any of these rights, please: email our Data Protection Officer at email@example.com and let us know:
No fee usually required
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 can refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
For further information on each of your rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. However, you have the 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 online at https://ico.org.uk/concerns or by telephone: 0303 123 1113. You can contact them, whether or not you are located in the UK.
Contact details for authorities in the EEA, Switzerland and certain non-European Countries (including the US and Canada) can be found here
How to contact us
Please contact our Data Protection Officer by email, post or telephone at:
Insights Learning & Development Ltd
3 Explorer Road
+44 (0)1382 908050
Colour Preferences means the colour preferences outlined in your Personal Profile. They are designed to assist you to understand how you interact and communicate with others. Colour Preferences represent your mix of colour energies. These colour energies are the colourful basis of almost everything that we teach because we believe they are fundamental to understanding ourselves. Whilst you will probably have a natural affinity for one colour energy over the others, we are all a mixture of all of the colour energies and we can all dial up or dial down particular colours when required. The colours represent preferences and are not a measure of skill and whilst they can be an accurate description of you, they do not define you. Your colour energy is not a static thing, but rather it is fluid.- It is designed to assist you tackle any situation you find yourself in through understanding yourself.
Your combination of colour energies is summarised by your Team Wheel position.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Direct Client means a Customer of Insights which purchases Insights Products for its own internal use (i.e. for its employees). Direct Client may also have Client Practitioners who are accredited to deliver Insights Products internally to the Direct Client.
Where an Insights Accredited Practitioner is employed by your employer or organisation, we refer to them as a “Client Practitioner” and they may only deliver Insights Products internally to your employer or organisation.
Insights Connections means the Insights Online community digital platform for Insights Accredited Practitioners which includes a virtual discussion forum and resources designed to support Insights Accredited Practitioners in the delivery of Insights Products. The Insights Connections Privacy notice can be found here.
Insights Discovery Accreditation means a training event run by Insights for individuals who wish to become Insights Accredited Practitioner.
Insights Discovery Evaluator means the Psychometric tool used by Insights to produce Insights Products. The Insights Discovery Evaluator consists of a series of statements which Participants are asked to rank how well they believe each statement describes them and/or their preferences. Answers will be processed by our algorithm, which relies on our decades of experience and development of our intellectual property, to produce Insights Products (such as the Personal Profile and Team Wheels).
Insights Online means an online platform operated by Insights through which (i) individuals may access the Insights Discovery Evaluator; and (ii) persons authorised by Insights can access Insights Products.
Insights Products means products and services which are developed by, owned by or licenced to Insights and which are marketed or used under the brands and trademarks of Insights. These may include, products which incorporate personal data, such as but not limited to: the Personal Profile, Colour Preferences and Team Wheel.
Participant means the person receiving the Insights Products or attending an Insights Event (i.e. the individual undertaking the Insights Discovery Evaluator, attending an Insights Event or whom the relevant Personal Profile is about).
Partner means a Customer of Insights which purchases Insights Products in order to incorporate them into its own products/services and/or programmes with its own Customers. Partners are sometimes also called “Distributors”.
Personal Profile means the profile generated by the Insights Discovery Evaluator which is personal to you. The Personal Profile is designed to help you increase your self-awareness and is usually used in the context of a learning or coaching experience. It consists of graphs, charts and sections of text describing how someone with your preferences can understand more about themselves and others. For example: it may have a chapter on your strengths, weaknesses and value to the team, your communication style, sales effectiveness, how you manage or like to be managed, your ideal working environment etc. Within the Personal Profile, you will see your Colour Preferences and Team Wheel position.
Team Wheel - The Team Wheel identifies and plots each team member’s colour preferences, as set out within their Personal Profile, on to a wheel shaped chart depicting the colour preferences of the team. “Team” in this context can mean departmental teams, collections of colleagues, or other collections of individuals, participating in an Insights Event. If you participate in an Insights Event where individuals from different organisations are in attendance, other individuals attending that Insights Event will form a Team. Team Wheels may be generated by Insights Accredited Practitioners and Administrators and may be shared with other members of your Team, our Partners and Direct Client.
Team Wheels are designed to assist members of a team to understand each other better and to communicate more effectively with each other by using and learning how to identify the colour preferences of each team member.