Welcome to Connections! 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 information 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 information on to us. You must not provide any personal information 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 information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We want you to be well-informed about how we and why we collect your personal information 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.
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 does not govern the practices of entities which Insights does not own or control.
We collect, use and are responsible for certain personal information about you. The personal information which we collect and use about you will generally be collected in accordance with the UK GDPR and the European General Data Protection Regulation, and we are responsible as a controller. Where you provide personal information to one of our subsidiaries, we may also be responsible for handling your personal information 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 information 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 are independent controllers. Please make sure that you have also read any privacy notices of our distributors or partners which may apply to you.
This privacy notice is designed to cover your use of Connections and our collection, retention and use of personal information collected about you through our Connections platform.
This privacy policy relates to your use of Connections.
Throughout the Connections site, we may, on occasion, link to other websites owned and operated by certain trusted third parties. Insights has many distributors and partners which may be referenced on the website, where they are, we may provide links to their websites and/or privacy notices which may apply to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. Please make sure that you read all privacy notices which may apply to you.
When you access other systems or platforms operated by insights, different privacy notices may also apply, please make sure that you read all privacy notices provided to you by Insights.
When you attend and complete an Insights Discovery Accreditation, you will be sent an email inviting you to register for and access Connections.
We generally collect your personal information directly from you when you complete an evaluator questionnaire or attend an Insights Discovery Accreditation or experience; however, we sometimes also collect personal information from other sources such as your employer, colleagues, or identified third parties such as our distributors and partners. Whatever the manner of our collecting of your personal data, in relation to Connections, we do so in accordance with this privacy notice.
When you access or use Connections, we may collect the following information:
This personal information is required to enable us to provide you with access to Connections and the various resources it provides to you as an Insights Accredited Practitioner. If you do not provide the personal information requested, you may not be able to access certain materials or resources and it may delay or prevent us from providing you with access to Connections.
Before we provide you with access to Connections, we may also receive your ‘pass’ certificate from the facilitators of the IDA which you attended. We receive this certificate so that we know that you have completed the relevant courses and have enough knowledge to use the materials and resources open to you within Connections.
When you register for Connections you will have your own ‘personal space,’ called a ‘Profile,’ which allows you to add personal touches such as: hobbies, photographs, bookmark your favourite content, add your biography, occupation, links to your LinkedIn profiles, education and location to make the ‘space’ personal to you. You may also join in discussions by making comments and rating posts as helpful or not helpful. Save for your name, all other details on your personal space are optional and you are not obliged to add any information about yourself onto your Profile.
Any content which you upload will be accessible to others on Connections, this includes any personal information about you which you have incorporated into the content. Other users will also be able to see that you have uploaded content, rated materials, given feedback and any posts which you have been mentioned in. Your activity on Connections will also be logged on your Profile which other Connections users will be able to access. Access to Connections is limited to Insights Accredited Practitioners, Insights staff and members of the Insights Community, it is not a public forum. When we say users may see your Profile, it means that other Insights Practitioners and Insights staff members who have access to Connections can see your profile, rather than just anyone.
Please make sure that you do not upload or share any personal information about someone else without their express consent.
In order to ensure that our Acceptable Use Policy is adhered to by users, we may also monitor content which you have uploaded to make sure that our community standards are observed. Our monitors may remove content which they find inappropriate for Connections. For more information about how to use your Profile and Connections, please read our Acceptable Use Policy.
As noted above, we generally collect your personal information directly from you; however, we sometimes also collect personal information from other sources such as your employer, colleagues, or identified third parties such as our distributors and partners. We may receive information about you from a Client Practitioner, Licensed Practitioner or facilitator involved in the facilitation of the IDA, workshop or event which you attended .
The personal information which third parties provide includes: your name and work email address in order to provide access to Insights Connections. Where you attended an IDA, the facilitators may also collect your ‘pass’ certificate from the course. We use your name and email address to send you an invitation to use and access Connections.
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website/s. These help us to recognise you and your device and store some information about your preferences or past actions.
For example, we may monitor how many times you visit the website/s, which pages you go to, traffic data, which language you use, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.
We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to enable basic functions like page navigation or to secure areas of the website which you have requested access to.
You can withdraw any consent to the use of cookies or manage any other cookie preferences by clicking on the Civic cookie icon at the bottom corner of any page on our site. It may be necessary to refresh the page for the updated settings to take effect.
The tables below provides more information about the cookies we use and why we use them:
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Website | Cookie Name | Purpose | Retention |
Insights Connections, hosted by Verint | .CommunityServer | This cookie is an ASP.NET authentication cookie. It is used to support the login system. | Session-based (retained for as long as you’re logged in). |
Insights Connections, hosted by Verint | AuthorizationCookie | A Globally Unique Identifier (GUID, e.g., 80FC959D-E916-4C1D-9054-C058450DB32D), used for security purposes. | |
Insights Connections, hosted by Verint | .te.dpr | Stores the device pixel ratio. Used when providing resized images to the clients to ensure that users get properly resized images on high-resolution displays | |
Insights Connections, hosted by Verint | Impersonator | Used when an administrator is impersonating another user. | |
Insights Connections, hosted by Verint | ThemeConfiguration | Used when a user with theme management permissions is previewing theme changes before making them live. | |
Insights Connections, hosted by Verint | Telligent.Evolution-MediaGallery | Saves a user’s preference for display of a media gallery file list. | |
Insights Connections | enable_theme_staging | Used when staged theme changes are being previewed. | |
Insights Connections | _templates | Client side UI templates used to render content. Does not contain any user data. | |
Insights Connections | _cwpcr | (C)ross (W)indow (P)resent (C)ontent (R)egistrar This is part of the infrastructure supporting content presence. Multiple tabs/windows are all tracking what a user is "present" to in their current scrolled segment of their viewport and storing it in a common location (_cwpcr) for the tab that has the actual socket connection to consolidate and send back the server on regular intervals. NOTE: The information in this value it's not actually stored anywhere. It's ephemeral and just used to deliver targeted updates to things users are looking at. | |
Insights Connections | .te.w | Stores the device width. | |
Insights Connections | .te.js | Set if the client supports JavaScript. Used to optimize how the platform builds out some pages or alternatively degrade gracefully (ex. search bot). | |
Insights Connections | CookieControl | Allows a website visitor to choose their cookie preferences |
Analytical cookies are used to help us understand how visitors interact with the website and to track visitor journeys to our website. This allows us to collect information anonymously and create reports so we can improve the experience for all customers visiting our website.
Website | Cookie Name | Purpose | Retention |
_gid | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day | |
_ga | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 min |
The cookies identified above will not be accessed by any other third party.
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website. For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
Under data protection law, we can only use personal information if we have a proper reason for doing so, eg:
The table below explains how we use personal information through Insights Online and our reasons for doing so:
Use of Personal Data/ Why we use your Personal Data | Our lawful basis |
To provide you with access to resources and materials as an Insights Accredited Practitioner. | For the legitimate interests of Insights and a third party – e.g. to support you to deliver Insights Products and Services internally to your employer in accordance with the agreement we have with them. |
The creation of your “Personal Space/Profile” | For the legitimate interests of Insights and a third party – e.g. to enable Insights Accredited Practitioners to interact with other Insights Accredited Practitioners are learn from each other. We ask for consent in relation to any uploaded content. |
To rate materials , resources and content. | For the legitimate interests of Insights and a third party – we have an interest in making sure that materials, resources and content are useful to our community of practitioners and the rating system allows us to see where we are doing well and where we could do better. This in turn ensures that we can make improvements which benefit our clients. Your ratings are included in the consent which we ask for related to content which you upload. The consent requested enables others to see your ratings. |
To use your uploaded content and allow access to it by others on the platform. | Consent – You are responsible for any content which you upload. The consent we ask for is a general consent which covers all content which you upload unless and until you withdraw your consent. This consent will be asked separate to this privacy notice. |
To give you access to Connections | For the legitimate interests of Insights and 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 materials and resources as required. |
Seeking feedback on the products and services which we have provided to you. | Legitimate interest – to assist us to provide services to a good standard. Where you provide feedback on the platform itself it will be accessible by other community members, for this we ask for your consent. |
To manage our ongoing relationship. | Legitimate interest – 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 keep in touch with our users in relation to the provision of our services. |
Ensuring business policies are adhered to, e.g. policies covering security and acceptable use, through monitoring. | 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.
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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.
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Marketing our services to you (or those of selected third parties such as our Partners). | For our legitimate interests or those of a third party, i.e. to promote our business to existing and former users of our products and services. |
To manage our ongoing business relationship, update details and keep an accurate record of CPs and LPs. | Legitimate interest – making sure that we are keeping in touch with our Client Practitioner’s and can assist them along their journey. |
To bill your employer Practitioner Licence Fees, where applicable. | Legitimate interest – we provide licenses to enable Client Practitioners to deliver our services internally to our clients. We have an interest in getting paid in relation to the licence. |
To make any content which you upload accessible to all other Connections users across the globe, including in areas/countries without adequate protection. | Explicit consent. The explicit consent is requested because the platform is designed to be used by Insights Accredited Practitioners across the globe. This is to encourage practitioner interaction. This consent will be asked for separately to this privacy notice. |
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 have a legitimate interest in using your personal information 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:
We will always treat your personal information with the utmost respect and never disclose it for marketing purposes to other organisations outside the Insights Group.
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 information for a new purpose, we will document that new purpose and ask for consent again.
Where we rely on implied consent, we will only process your personal information in the manner set out in this Privacy Notice, as may be amended from time to time.
If you are a resident in California, we confirm that Insights does not sell your personal information 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 information 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 of personal data.
When we process your personal data, we will do so in accordance with this Privacy Notice and all applicable laws.
Under data protection law, we can only use special category personal information where:
There are ten potential grounds for using special category personal information under data protection law. Generally, we currently 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.
We routinely share personal information with:
Members of the Insights Group also often share personal data with each other.
Information may be held at our offices and those of our group companies, our partners, third party agencies, service providers, processors, representatives and agents as described above. Where you are accessing our products and services through one of our partners, the partner may also hold personal information relating to you. Please make sure you read any privacy notices provided to you by our partners to ensure that you are aware if, how and why they process your personal information and where they store it.
Some of these third parties may be based outside the European Economic Area or the location where you are based. This means that we may transfer your data across borders. When we do, we will do so in accordance with appropriate data protection laws.
We will not retain your data for longer than necessary for the purposes set out in this policy. We retain different types of personal information for different periods of time, depending on the purposes for the processing. We will not keep your personal information for longer than is permissible by applicable law.
We will maintain your contact details, to help us stay in contact with you. At any time before or after the termination of your Connections account, you can contact us at: dpo@insights.com and request to delete your contact details.
When we keep a copy of our personal information will do so for one of these reasons:
When it is no longer necessary to retain your personal data, we will delete or anonymise it (i.e., we may keep aggregated non-identifiable personal information when we no longer need to process the personal information itself).
If you choose to deactivate your Profile, we may keep useful comments, feedback or ratings which you have made in the past but we will remove any personal information from such comments so that they can no longer be traced back to you (i.e. your user name will be changed to “former user”). However, if you wish particular comments, feedback or ratings to be deleted, you may request this at any time.
We will keep your comments and content on Connections which you posted (other than your Profile) for 1 year, thereafter your personal data will be deleted. However, you may request that we remove all personal information about you on Connections at any point by emailing our Data Protection Officer at dpo@insights.com.
To provide you with access to Connections and the materials, content and resources within it, it is sometimes necessary for us to share your personal information outside of your geographic location. We usually do so in the following circumstances:
International transfers of personal information are subject to special rules under European and UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:
These are explained below.
The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from the UK/EEA to that country without any further safeguards being necessary.
Other countries or international organisations we are likely to transfer personal information to do not have the benefit of an adequacy decision. This does not necessarily mean they provide inadequate protection for personal data, but we must look at alternative grounds for transferring the personal data, such as implementing safeguards or relying on an exception.
We may transfer your data to a third country or international organisation on this ground where 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 standard data protection contract clauses approved by the European Commission.
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, e.g.:
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 and when we seek to transfer your personal information on this ground.
We are keeping a close watch on the UK’s negotiations with the European Union. Whilst we hope that there will be an adequacy finding in favour of the UK’s processing of personal data, in the event that there is not, we will ensure that any transfers from the EU to the UK will only take place where there are appropriate measures in place to allow for such transfer.
We may share your Personal information 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 information is properly safeguarded at all times and have contracts in place with the third parties to provide a comparable level of protection while Personal information is being processed by third parties outside of Canada.
As with transfers from the EEA to third-countries we may seek your consent prior to permitting such transfer.
A list of third parties to whom we transfer Personal information outside Canada, together with the relevant safeguard mechanism can be provided by contacting the dpo@insights.com.
If you would like further information about data transferred outside the UK or EEA, please contact our Data Protection Officer at dpo@insights.com.
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: |
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 |
Access | The right to be provided with a copy of your personal information |
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—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 information 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 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:
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.
We confirm that Insights does not sell your personal information to third parties. We may, however, share your personal information with third parties who are business partners, services providers or other third parties (see above), provided that such parties have entered into agreements with us covering the use personal data.
Whilst we are only required to tell you whether we sell your personal information to third parties under the California Consumer Privacy Act, we confirm that we do not sell your personal information to third parties anywhere.
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. Where we rely on implied consent, we will only process your personal information in the manner set out in this privacy policy.
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information 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.
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
This privacy notice was published on 15th April 2021 and was last updated on 30th April 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 information to be sure that you are kept up to date.
Please contact us Data Protection Officer by email if you have any questions about this privacy notice or the information we hold about you.
If you have any questions or would like to exercise any rights, please email dpo@insights.com.
