Welcome to Insights Online! 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. 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. 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 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. We only provide them with personal data for the purposes stated herein. As independent controllers, they may determine the purpose, manner and means of their processing activities and where they do so, they are responsible for ensuring that they have a lawful basis for this. They have a duty to tell you when they deviate from the purposes set out within this notice and the main way that they will tell you is through their own privacy notices.
If you are unsure whether you are accessing Insights Online through a partner or distributor, please get in touch and we will assist you.
This privacy notice is designed to cover your use of Insights Online and our collection, retention and use of personal data collected about you through our Insights Online platform.
Our Insights Online Portal is our dedicated platform that facilitates Insights Experience set up and management. It is a business tool that supports the administrative tasks related and required to run Insights Experiences and produce Insights’ products such as Experience invites, Profile purchases and Team Wheel generation.
We generally collect your personal data directly from you when you access, use, or register for Insights Online; however, we sometimes also collect personal data from other sources such as your employer, colleagues, or identified third parties such as distributors or partners. For example: your employer may provide us with your name and contact details so that we can deliver our services in accordance with the agreement we have with them. 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 Insights Online, we collect the following information:
This personal data is required to enable us to provide our products and services to you, your organization 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 our products and services.
We generally collect personal data directly from you when you sign up to access and use Insights Online. However, we may also collect information from third parties such as:
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 Insights Online.
We do use cookies when you access Insights Online. When we use cookies, we do so in line with our cookie policy, which can be found here: https://www.insights.com/cookies/.
Under data protection law, we can only use personal data if we have a proper reason for doing so, e.g.:
The table below explains how we use personal data through Insights Online 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. |
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 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. |
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.
|
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.
|
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 access Insights Online, 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 use or access Insights Online 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.
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.
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.
Under data protection law, we can only use special category personal data where:
There are ten potential grounds for using special category personal data under data protection law. 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.
We routinely share personal data with:
Members of the Insights Group may also share personal data about you with other members of the Insights Group.
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”.
We restrict access to Insights Online only to those who require access. For example:
Where Insights Online Users handle your personal data, Insights ensure that it has appropriate contracts in place 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 we share your personal data with third parties, we do so for the purposes set out in this privacy notice. If any such third-party processes 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. Such third party is solely responsible for telling you about how and why it processes your data and for setting such processing activities out within a privacy notice. Please ensure that you read all privacy notices provided to you by any third party.
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.
Some of these third parties may be based outside the European Economic Area or outside the location where you are based.
To provide you with access to Insights Online it is sometimes necessary for us to share your personal data outside of your geographic location e.g.:
We will only transfer your data internationally where we have a lawful basis to do so in accordance with applicable law.
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.
When we keep a copy of your personal data we do so for one of these reasons:
We will keep personal data which we collected about you for as long as necessary for the purposes listed above. We will not keep any personal information which we hold about you after seven years of inactivity unless we have a legal obligation to keep it for longer.
When it is no longer necessary to retain your personal data for the purposes set out in this privacy notice, we will delete or anonymise it.
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 |
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 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.
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 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.
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 |
