17th July 2018
Table of Contents
1 Version Control 2
3 Introduction. 2
4 How is personal data collected?. 3
5 What personal data is collected?. 3
6 Collecting and processing sensitive personal data. 4
7 Legal basis for processing data and the purpose of processing data. 4
8 Statutory/contractual requirement 5
9 Use of personal data for Direct marketing. 5
10 Who can access the personal data we collect?. 5
11 Disclosure of personal data to third parties. 6
12 Safeguarding and Storage of personal data. 6
13 Our website and internet based transfers. 7
14 Data retention. 7
15 Your rights. 7
16 How to make a complaint 8
The following is a list of all changes made to this document, the person making the change, the new version number and the reason why the change was necessary.
7billionideas Ltd is a UK registered Business management consultant business, operating globally from offices in Greater London. 7billionideas exists to connect the 7 billion people on the planet with their own ideas, including your employees. We support organizations looking to implement a culture change innovative programmed which is centered around improving their employee engagement. The tangible business benefits of such a programme can be categorised in seven areas : Improving employee satisfaction, improving client satisfaction, talent identification, revenue generating, R&D budget reduction, cost cutting and productivity gains.
7billionideas Ltd must process personal data so that it can provide these services – in doing so, 7billionideas Ltd has appointed a data protection officer (DPO).
7billionideas Ltd (‘we’; ‘us’; ‘our’) take your privacy very seriously and are committed to protecting the personal information that we collect. We will take appropriate care to keep your information secure and to prevent any unauthorised access or use of it. We implement various security measures to maintain appropriate controls over the processing and transfer of personal data.
This Policy was last revised on: 4th April 2018.
7billionideas Ltd collect personal data in a number of ways. Most commonly these include:
The type of personal data 7billionideas Ltd collect about you will depend on the circumstances in which that data is collected.
The standard personal data 7billionideas Ltd collect and store is: your name, your employer, your job title, and your contact details (e.g. email address, telephone number).
Additional data is collected if you have registered with 7billionideas Ltd as a candidate for partnership, whether currently or in the past. Such data is likely to include a copy of your business card details and partnership agreement and partnership history.
Sensitive personal data is data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
7billionideas Ltd do not typically collect or store sensitive personal data. However, in some pipeline development activities, our clients may request us to collect and process sensitive personal data from prospective partnership or booking. In that event, we will contact you to ask for your explicit consent for this sensitive personal data to be collected and processed. You may refuse to provide any of the sensitive personal information we request.
In addition, as part of our commitment to Equal Opportunity and to monitor compliance with our Equal Opportunity Policy, we may ask you if you would like to complete a Diversity Questionnaire. Should you wish to complete the questionnaire, you will provide your explicit consent for 7billionideas Ltd to store this information, and for how long, and the information you provide is given voluntarily, anonymized and stored separately from your personal records.
7billionideas Ltd have a legitimate interest for processing personal data, given that it is necessary to process personal data in order to provide our services to you. As long as your data protection rights are not infringed, 7billionideas Ltd are allowed to process your data when it is in the interests of the business to do so.
The precise purpose of processing personal data will depend on the circumstances in which that personal data is collected.
7billionideas Ltd will only process your personal data for the reason for which you provided it or for reasons that are directly related to this reason. For example, when you register as our partner, newsletter recipient, trainee or a potential customer, we will use your personal data to assess the viability of our business relationship, to contact you about suitable opportunities, products and services, to provide you with business health checks, and to put you forward for business opportunities when you give us your consent to do so.
Similarly, when we collect personal data from a potential company which will develop your pipeline, we will collect and process the personal data necessary to provide consultancy services to you; to discuss the pipeline with potential companies and to submit leads to the prospective company.
When we collect personal data from an individual engaging with 7billionideas Ltd.’s Training & Coaching Division, we will collect and process the personal data necessary to provide you with Training & Coaching services.
When we collect personal data from an individual invited to join any networking group that 7billionideas Ltd runs, we will collect and process the personal data necessary to run and administer the networking group.
Legitimate interest cannot be used as a lawful basis for collecting and processing sensitive personal data, so in the event that our clients request us to collect and process sensitive personal data, we will contact you to ask for your explicit consent for this sensitive personal data to be collected and processed.
In very rare circumstances, we may have a legal obligation to process personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.
Your personal data is not required as part of a statutory and/or contractual requirement, or a requirement necessary to enter into a contract.
When we collect personal data from you, we welcome the opportunity to share with you market intelligence in the form of Newsletters (whether Indirect Tax, Management Consultancy or Executive Coaching), Market Reports, Market Surveys. We will seek your consent to receive such communications, and when you provide us with this consent, this is knowingly and freely given, informed, clear and specific. You may withdraw your consent from receiving such communications at any time by using the facility to ‘unsubscribe’ included in the email or communication concerned.
In order to provide our services to you, your personal data will typically be accessible by other employees of 7billionideas Ltd as well as the contact by whom the data was originally collected.
Your personal data may also be accessible by third parties who perform functions on our behalf, such as 7billionideas Ltd.’s website development team providers who carry out website development work for our innovation hub.
Personal data is disclosed to other companies (‘third parties’) depending on the reason for which that personal data is primarily held, or for a related reason. This will be for the reason for which you provided it to us; for example, when setting up your innovation hub domain by our website development contractor.
In the event of you being registered as a business partner with 7billionideas Ltd and asking us to run business outside of the country from which you are part, your personal data will be sent to the business partner in that country. Please be aware that the degree of protection of your personal data in a different country may not be the same as in your country of residence. 7billionideas Ltd will only transfer personal data to countries outside the European Economic Area (‘EEA’) for the purposes of providing work-finding or consultancy services. This will be with the permission of the relevant data subject and where the risk to the rights of the data subject is low. The EEA comprises the EU member states, plus Norway, Iceland and Liechtenstein.
Personal data is also processed to third parties who perform functions on our behalf as data processors. These may be physically situated outside of the EEA. These are:
These companies have demonstrated to us that they have appropriate safeguards and security measures in place to ensure their compliance with GDPR.
All personal data is stored on secure cloud-based servers, and every endeavor is made to have in place sufficient technical and organisational measures to safeguard personal data. We cannot however guarantee that loss, alteration or misuse of data will not take place, despite the security measures we have in place to minimise the likelihood of this eventuality.
Using the internet to collect and process data involves the transmission of data on an international basis, given the internet is a global environment. There are risks involved in transmitting data in this way. For instance, by communicating with 7billionideas Ltd electronically via our website (www.7billionideas.co.uk), social networking websites (e.g. LinkedIn, Facebook, Twitter, Instagram, we are unable to guarantee that the personal data you submit will not be intercepted when submitted. External websites operated by other companies will be subject to that company’s privacy practices over which 7billionideas Ltd has no control. 7billionideas Ltd cannot guarantee the privacy practices of any third-party websites.
7billionideas Ltd will retain your personal data only for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. Different laws require us to keep different data for different periods of time.
7billionideas Ltd will typically retain personal data for up to fifteen years from the date of last contact, unless it is deemed necessary to retain such personal data for longer. We have chosen fifteen years as the specialist employment markets for which we provide ongoing advice and consultancy services do not typically feature a high turnover of staff. Therefore, it is in our legitimate interests to retain the data so that we can provide a long term continuous offering for those who may wish to engage 7billionideas Ltd.’s services just once or twice during the course of their careers.
Where we have sought explicit consent for the collection and processing of sensitive personal data, this will only be stored and processed for the defined period of time that you have given your explicit consent for such to be stored and processed.
Please be aware that you have the following data protection rights: the right to be informed about the personal data 7billionideas Ltd processes on you; the right of access to the personal data 7billionideas Ltd processes on you; the right to rectification of your personal data; the right to erasure of your personal data in certain circumstances; the right to restrict processing of your personal data; the right to data portability in certain circumstances; the right to object to the processing of your personal data that was based on a public or legitimate interest; the right not to be subjected to automated decision making and profiling; and the right to withdraw any given consent at any time.
You may contact 7billionideas Ltd to seek access to, rectify, and/or request deletion of the personal data we hold on you. We will require that you provide suitable identification.
To make a request to access your personal information, please email us with your request on https://www.7billionideas.com/contact-us and provide verification of your identity. We will provide this information within 30 days, excepting any information that would interfere with the privacy rights and confidentiality of other individuals or companies.
Your co-operation in helping us store accurate personal data for you is very valuable to us. Please contact us on https://www.7billionideas.com/contact-us to rectify any personal data we hold on file you, for example change of name, address details, etc.
Should you wish for your file to be deleted, we will process this where possible, but please be aware that there may be occasions where we may not be required to do so, particularly where your file also includes financial/employment records that we need to keep for periods up to six years.
Should you wish to access, rectify or delete the personal data we hold, please contact the 7billionideas Ltd.’s Data Protection Officer on https://www.7billionideas.com/contact-us.
If you believe this policy has been breached in any way, please write to or email 7billionideas Ltd.’s Data Protection Officer on https://www.7billionideas.com/contact-us, verifying your identity, and setting out in as much as detail as possible the detail of the personal data affected, and the reason for and circumstances of your complaint. We will provide a written response within 30 days after concluding an internal investigation. We may contact you should we need any additional information.
You also have the right to raise any concerns with the Information Commissioner’s Office in the UK on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
Contact 7billionideas Ltd.’s Data Protection Officer
Email: enquiry@7billionideas Ltd.co.uk
Address: Claremont house, 22-24 Claremont Rd, Surbiton KT6 4QU
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Call us on 0207 7540 398
©2019 7billionideas Ltd.