women ahead and moving ahead privacy policy
What is this policy?
This is our data protection and privacy policy. It explains who we are, and why and how we process personal data. If you are the subject of any of the personal data that we process, this policy explains what rights you have, and how to get in touch with us if you wish to.
WHo are we?
We are Moving Ahead Ltd, trading as Moving Ahead or Women Ahead (Moving Ahead). Our contact and other details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy.
What do we do?
Our aim is to help improve diversity and inclusion in the workplace. We provide mentoring programmes, consultancy services and research services, we run and participate in workshops and we provide speakers for events and other forums.
How do we process personal data?
How we process personal data depends on the purpose for which we obtain it and the individual to whom it relates. We will normally only process personal data relating to you if:
· You are a mentee (you receive mentoring).
· You are a mentor (you provide mentoring).
· You participate (or are asked to participate) in one of our workshops or other events or programmes.
· You organise an event in which we participate.
· You use our digital learning platform.
· You are a client of ours, or you work for a client.
· You are a supplier of ours, or you work for a supplier.
· You receive advertising, marketing or promotional material on our behalf.
· You browse our website(s).
· You apply for a position with us.
We explain our personal data processing in more detail, below, in relation to each of these categories.
If you are a mentee (you receive mentoring managed by us)
Purpose of processing
The purpose of the processing is to provide you with mentoring, and to manage and administer the relevant mentoring programme(s) and ensure that you benefit from them as expected. We will use your personal information to match you with an appropriate mentor and to manage and administer the mentoring while it is taking place.
Once a mentor has been selected for you, we will share relevant information with the mentor in order to enable the mentor to provide mentoring to you effectively. The mentor will be under a duty of confidentiality and will not disclose the information (or anything you discuss with the mentor during the course of the mentoring programme) to anyone else without your consent.
We will share information about relevant matches between mentors and mentees with your employer and your mentor’s employer, together with basic information (e.g. name, title, business area and email address) about the mentors and mentees concerned. Otherwise, we will only disclose the information that you give us (but not anything that is discussed between you and your mentor) to your employer if this has been specifically agreed with you first.
Other than your mentor and your employer (as set out above), no third parties will have access to your personal information other than as set out in this policy (see Other disclosures we may make, below) or unless the law allows them to do so.
Information processed
Your name.
Who you work for.
Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
Information necessary to facilitate the mentoring, such as your:
o job title;
o organisation;
o business unit;
o photo;
o years of experience (general or specific);
o gender;
o location preference (for the mentoring);
o specialism;
o specialism preference (for the mentor);
o gender preference (for the mentor);
o skills;
o motivation to take part in the programme;
o objectives for the programme.
Background information relating to you, such as your achievements and things you are proud of; your hobbies and interests; your core values and behaviour.
Special categories of information (subject to your explicit consent), such as your ethnic group or sexual orientation.
Legal basis
You have given consent to the processing of your personal data for one or more specific purposes – article 6(1)(a) GDPR.
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us (in providing a mentoring service) or by your employer or sponsor (in providing you with access to mentoring) – article 6(1)(f) GDPR.
Where you are asked to provide us with certain special categories of personal data (for example, with regard to gender, ethnic grouping, sexuality and the like), this will in addition to any other ground be subject to your explicit consent – article 9(2)(a) GDPR.
How long we keep it
We keep the personal information that you give to us throughout the period of your mentoring programme and for a reasonable period after the programme ends, after which we will delete it or anonymise it (if we wish to use it for further research purposes).
If you are a mentor (you provide mentoring managed by us)
Purpose of processing
The purpose of the processing is to enable you to participate in a mentoring programme, and to manage and administer the mentoring and ensure that the individuals you mentor benefit from it as expected.
We will use your personal information to match you with an appropriate individual to mentor and to manage and administer the mentoring while it is taking place.
Once an individual has been selected for you to mentor, we will share relevant information with the individual concerned in order to enable the mentee to benefit from the mentoring by you
We will share information about relevant matches between mentors and mentees with your and your mentee's employer, together with basic information (e.g. name, title, business area and email address) about the mentors and mentees concerned. Other than any individual that you mentor and your or your mentee's employer (as set out above), no third parties will have access to your personal information other than as set out in this policy (see Other disclosures we may make, below) or unless the law allows them to do so.
Information processed
· Your name.
· Who you work for.
· Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
· Information necessary to facilitate the mentoring, such as your:
o job title;
o organisation;
o photo;
o years of experience (general or specific);
o gender;
o specialism;
o skills.
· Background information relating to you, such as your achievements and things you are proud of; your hobbies and interests; your core values and behaviour.
· Special categories of information (subject to your explicit consent), such as your ethnic group or sexual orientation.
Legal basis
You have given consent to the processing of your personal data for one or more specific purposes – article 6(1)(a) GDPR.
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interest pursued by us (in providing a mentoring service) or by your employer or sponsor (in providing you with access to mentoring) – article 6(1)(f) GDPR.
Where you are asked to provide us with certain special categories of personal data (for example, with regard to gender, ethnic grouping, sexuality and the like), this will in addition to any other ground be subject to your explicit consent – article 9(2)(a) GDPR.
How long we keep it
We keep the personal information that you give to us throughout the period of your mentoring programme and for a reasonable period after the programme ends, after which we will delete it or anonymise it (if we wish to use it for further research purposes).
If you participate (or are invited to participate) in a workshop or other event organised by us
Purpose of processing
Our purpose in processing your personal data is to enable you and any other relevant individuals to be invited to, and to participate in, the event and to facilitate your attendance (for example, dietary or special access requirements).
We will use your personal information to market the workshop or other event to you, to enable your attendance at the workshop, to provide the workshop and to facilitate your participation in the workshop.
We will share the information with the client for whom we are organising the workshop (if relevant), anyone who assists us with the management and delivery of the workshop and (with the exception of any dietary or other special requirements) with the other attendees at the workshop. Otherwise, no third parties will have access to your personal information other than as set out in this policy (see Other disclosures we may make, below).
Information processed
· Name.
· Contact details (email address, phone number, address).
· The organisation you work for.
· Other personal details relevant to your involvement in the event.
· Details relevant to hospitality being organised or provided (e.g. dietary requirements).
Legal basis
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR.
How long we keep it
As long as reasonably necessary for the purposes of organising the event and then for a reasonable period after the event, after which we will delete it.
If you use our digital learning platform
Purpose of processing
Our purpose in processing your personal data is to enable you to use our digital learning platform; to facilitate your access to relevant materials and your interaction with us and with others via the platform.
We will use your personal information to enable you to register on, and log onto and use the platform; to facilitate your access to relevant materials and your interaction with us and with others via the platform.
Certain of your information (such as your name or username, for example) may be shared with other users of the platform with whom you interact, as appropriate to the nature of the interaction. Otherwise, no third parties will have access to your personal information other than as set out in this policy (see Other disclosures we may make, below).
Information processed
· Name.
· Contact details (email address and phone number).
· Organisation.
Other personal details relevant to your particular use of the platform (such as personal details you upload to your profile on the platform).
Legal basis
You have given consent to the processing of your personal data for one or more specific purposes – article 6(1)(a) GDPR.
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR.
How long we keep it
As long as reasonably necessary for the purposes of organising the event and then for a reasonable period after the event, after which we will delete it.
If you organise a workshop or other event in which we participate
Purpose of processing
Our purpose is to enable us to attend and participate in the event.
We will use your personal information to organise and enable our attendance and participation in the workshop
We will share the information with anyone who assists us with our attendance and participation in the workshop.
Information processed
· Your name.
· Who you work for.
· Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
Legal basis
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if we are contracting with you as an individual) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR.
How long we keep it
We keep the personal information that you give to us until the workshop has been delivered and then for a reasonable period after the programme ends, after which we will delete it.
If you are a client of ours, or you work for a client of ours
Purpose of processing
The purpose of the processing is to enable us to provide, and to manage and administrate the provision of, the relevant services by us to you or the person that you work for, and to communicate with you in relation to the provision of services concerned.
In the course of providing our services, we may share relevant information with third parties to the extent necessary to facilitate the provision of the relevant services to you or the person that you work for. For example, if we are engaging a third party to provide goods or services in relation to our provision of services to you, we may share your contact details with them if that is necessary to facilitate communications between you and them as part of service provision (see also Other disclosures we may make, below).
Information processed
· Your name.
· Who you work for (if applicable).
· Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
· Bank account or other financial details (if you are an individual client).
· Personal description and photograph.
· Any other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the services.
Legal basis
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR.
How long we keep it
We keep the personal information that you give to us throughout the time during which we provide our services to you or the person that you work for, and for a reasonable period after the provision of services ends, after which we will delete it or archive it (if there is an appropriate reason to maintain an archive copy of it for future reference).
If you are a supplier or you work for a supplier (or we are considering you or your employer as a supplier) to us or our clients
Purpose of processing
If:
· You provide goods or services to us or our clients.
· You work for, or are agent for or otherwise represent, someone who provides or is being considered as a provider of such goods or services.
· We are assessing your suitability (or that of the person you work for) to provide such goods or services.
We may process information relating to you to enable us, our clients or other suppliers of ours or our clients to manage and administer the provision of goods or services by you or the person that you work for and to communicate with you and our client in relation to that provision. This may include (where relevant) processing any information necessary to enable us to provide or arrange any facilities, resources, travel, accommodation, insurance or anything else necessary to enable or assist you to provide goods or services to us or our clients.
Information processed
· Name.
· Contact details (name, address, email address, phone number).
· Communications sent or received.
· Goods or services purchased and/or delivered.
· Other personal details relevant to your involvement in the services being provided (for example, your CV if you are talent who is contracting to provide services).
· Professional or other accreditation details.
· Passport details.
· Age verification details.
· Bank account or other financial details.
· Details relevant to hospitality being organised or provided (e.g. dietary requirements).
· Details relevant to travel or other facilities being organised or provided in order to assist you in providing the goods or services.
· Consent forms (where relevant to events or other activities in which the data subject is participating).
· Images of you.
Records of public statements.
Legal basis
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if we are contracting with you as an individual) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in carrying out our business – article 6(1)(f) GDPR.
How long we keep it
We will keep the information for as long as necessary to facilitate the provision by you of the relevant goods or services and then for a period of up to 6 years afterwards, after which we will normally delete it. If we consider you, but decide not to select you, to provide such goods or services, then we will normally keep any relevant information provided by you for a period of 6 months, after which we will delete it (unless you have agreed to allow us to retain it in case, for example, we may wish to contact you in future regarding other opportunities to provide goods or services).
if we wish to send you advertising, marketing or promotional material on our own behalf
Purpose of processing
We may process your individual contact details in order to send you direct marketing material in order to advertise, market or promote our services (either to you or the person that you work for, as appropriate). We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you browse our website and view particular content) in order to help us ensure that marketing material that we send you is relevant to what you are interested in.
Information processed
· Name
· Job function; department.
· Work contact details (email address, phone number, address).
· Personal contact details (email address and phone number).
· Events to which you are invited or which you attend.
· Communications sent or received.
· Use of websites (e.g. tracking data from use of our website).
Legal basis
You give consent to the processing – Article 6(1)(a) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR.
How long we keep it
We will keep the personal information for a reasonable period consistent with sending you marketing communications, after which we will either confirm that you are happy for us to continue to do so, or delete it (except to the extent we need to retain it for the so0le purpose of supressing further marketing communications to you).
If you browse any of our websites
Purpose of processing
We may collect information on your visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. We may keep a record of the content on our website that you have clicked on and use that information to target advertising on this website to you that is relevant to your interests and which we have identified based on content you have looked at. This may involve the use of cookies, which is explained in our cookies policy.
Information processed
· You name and/or other identifier.
· Who you work for.
· Your visits to our website.
· Content viewed by you.
· Links followed by you.
Information downloaded by you.
Legal basis
You give consent to the processing – Article 6(1)(a) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR.
How long we keep it
We will keep the information for a reasonable period and then delete it.
If you apply for a position with us
Purpose of processing
We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.
Information processed
Information dependent on the position you are applying for – this will be communicated to you at the time.
Legal basis
The processing is necessary for the performance of a contract to which you are a party or to take steps at your request to enter into such a contract (if you are an individual client) – article 6(1)(b) GDPR.
The processing is necessary for the purpose of legitimate interests pursued by us in providing our services – article 6(1)(f) GDPR
How long we keep it
If you are employed by us, for the duration of your employment and then for a further period of 6 years, after which the information will normally be deleted.
If you are an unsuccessful applicant, for up to 12 months after your application, after which we will delete it unless we have agreed otherwise with you.
Other disclosures we may make
Where appropriate, we may disclose your personal data to third parties:
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
· Appropriate third parties including:
o our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
o data processors acting on our instructions in relation to the processing of your personal data;
o the media, where you are participating in advertising or other marketing or promotion that is intended to be publicly disseminated;
o our auditors, legal advisors and other professional advisors or service providers;
o credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
· In relation to information obtained via our website:
o our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
o analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
· If we or substantially all of our assets are acquired by a third party, in which case personal data held by us or our customers or other persons we deal with will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or our safety or that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where do we process personal data?
The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff who are situated outside the EEA who work for us, for a company in the same group as us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of service delivery, the processing of payment details and the provision of support services.
Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) and that it is treated securely and in accordance with this privacy policy.
All personal data processed by us is stored securely. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
Under data protection law, you have certain rights. Your rights depend on our reason for processing your personal information:
· You may request access to the personal data concerned (please see the section on obtaining access to your personal data, below).
· You may request that incorrect personal data that we are processing be rectified.
· In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
· Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned.
If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Information Commissioner.
How to withdraw your consent to processing
You can withdraw your consent to any relevant processing of personal data:
· By emailing us at info@moving-ahead.org
· By writing to us at the address below.
How to exercise your right of access to your personal data
You can exercise your right of access to your personal data:
· By emailing us at info@moving-ahead.org
· By writing to us at the address below.
Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.
Our details – contacting us
Our full details are:
Moving Ahead Ltd
35A Hart Street
Henley on Thames
RG9 2AR
Email: info@moving-ahead.org
Updates to this policy
Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
Date of this policy
This policy was last updated on 24 April 2020.