This policy was last updated on 19th April 2023 (Cyber Essentials Plus Certification Included)
In summary
Management Tests & Surveys Limited ('MTS' 'we', 'us', and 'our') take data protection very seriously and we are committed to protecting your personal information.
This Policy explains what information we gather, what we use that information for, and who we give that information to. It also sets out your rights in relation to your information, how long we keep it and who you can contact for more information.
It is our policy to collect only the minimum information required from you. If you believe we have collected excessive information about you, please contact us (see below) to raise any concerns you may have.
Although you do not have to provide any of your personal information to us, if we ask you to do so and you refuse, we may be unable to provide you with the information or services you want from us.
What is personal information?
Personal information is anything that enables an individual to be identified or identifiable, such as:
- First and last names
Postal and email addresses - Telephone numbers
- Identity documents (e.g. passports & driving licence)
- Identity numbers (e.g. National Insurance and Bank accounts)
- Career & educational documents (e.g. CVs & qualifications)
- Contact information
Your personal information is sometimes called "personal data". We collectively refer to handling, collecting, protecting or storing your personal information as 'processing'.
Collecting personal information
Below are just some examples of how you may provide personal information to us:
- Being nominated to participate in a people development intervention by your organisation / coach
- Contracting us to complete management surveys on your staff
- Asking us to provide other services to you or someone else
- Contacting us, e.g. by phone, letter or email
- Searching and browsing our website
- Accessing our online articles
- Submitting CVs or work history information to us
- Providing us with business cards or other contact information
Using personal information
Client supplied information - we only collect personal data from our clients in order to perform the specific project / that has been requested. We do not use this information for any other purpose unless we state otherwise at the point we collect it from you.
We may also collect and use personal information in the following circumstances:
- Business contact information for ongoing administration and to develop our business and services
- To consider whether to offer someone employment with us
- To administer and manage our website including
- To personalise and enrich your browsing experience by displaying content that is more likely to be relevant and of interest to you
- To sort and analyse user data (such as determining how many users from the same organisation have subscribed to or are using the Website)
- To understand how people, use the features and functions of our website in order to improve the user experience
- To conduct quality and risk management reviews
We do not collect personally identifying information for sale to third parties.
Legal grounds for processing personal information
We rely on one or more of the following processing conditions:
- To perform our contractual obligations to you/ your organisation / coach; and/or
- To satisfy any legal and regulatory obligations to which we are subject; and/or
- To satisfy our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (where this does not interfere with your rights); and/or
- When you have agreed to us processing your personal information.
Security of personal information
We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction.
Only authorised persons are provided access to personally identifiable information we have collected, and such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure.
We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
Sharing personal information
We only disclose client supplied personal information to third parties under the following circumstances:
- When explicitly requested by you
- When required to deliver services requested by you
- As otherwise set out in this privacy policy.
We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation.
We only disclose staff personal information to third parties in order to provide the benefits available to you under your terms of employment.
These third-party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub-processors.
International transfers of personal information
Your personal information may be transferred outside the European Economic Area (EEA).
Any transfer of information, profiles or personal data to outside the EEA will be only made to the specified client contact and any other member of staff specifically directed by that contact.
Retention of personal information
We will retain your personal information only for as long as we need it, given the purposes for which it was collected, or as required to do so by law.
Normally, this means we will retain your personal information for 2 years unless a different retention period is specified by our client.
Marketing
We do not engage in direct marketing.
Rights in relation to your information
You have certain rights in relation to the personal information we hold about you. In particular, you have the right to:
- Request a copy of personal information we hold about you;
- Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
- Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
- Object to our processing of your personal information; and/or
- Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
If you would like to exercise these rights or understand if these rights apply to you, please contact us (see below).
Automated decision making
We do not use your personal information for automated decision making or profiling.
Children
We understand the importance of protecting children's privacy and we never knowingly collect personal information about individuals under the age of 18.
Our website
We do not intend to collect special category (also known as sensitive) personal information through our website (unless we are legally required to do so). Examples of special category information are: race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records.
We ask that you do not provide us with special category personal information when using our website.
Cookies
What are cookies? Cookies are a small text file stored on your computer or device by your browser. They allow websites to store information about your preferences or how you use the website. They are often used so that when come back to the website you are recognised. Find out more about cookies here: https://en.wikipedia.org/wiki/HTTP_cookie
Only cookies that are strictly necessary for our website to function are used. These cookies are non-persistent, don't have any personal data stored in them and without them the website would not be able to work correctly. No other third-party cookies are used for tracking or for any other reasons.
We specifically use cookies to identify you only during the survey and/or feedback process.
Contact us
If you have any questions or complaints about the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us by one of the following means:
Form: https://www.mts360.com/mts/contact.aspx
Email: info@mts360.com
Post: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, UK
You also have the right to lodge a complaint with your local data protection regulator, which in the UK is the Information Commissioner Office (ICO). The ICO can be contacted by the following means:
Form: https://ico.org.uk/global/contact-us/email/
Telephone: 0303 123 1113 (local rate calls to this number cost the same as calls to 01 or 02 numbers). If you're calling from outside the UK please call +44 1625 545 700.
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
We may update this Privacy notice at any time by publishing an updated version here. So that you know when we make changes to this Privacy statement, we will amend the revision date at the top of this page. The new modified or amended Privacy notice will apply from that revision date. Therefore, we encourage you to review this Privacy notice periodically to be informed about how we are protecting your information.