This privacy statement applies to all Edgecumbe owned websites, domains, services, applications and products including but not limited to Edgecumbe Dr 360, Edgecumbe Health & Edgecumbe Surveys
Edgecumbe Consulting Group Limited of Whitefriars, Lewins Mead, Bristol BS1 2NT is committed to protecting the privacy of the data that we process and hold, and complying with GDPR.
We hold personal data about our clients and their employees; this document explains what information we hold, how we use it and your rights regarding that information.
What data do we hold?
The data we hold may include some or all of the following:
- Identifying Information – name, GMC number
- Contact Information – e.g. email address, postal address, phone number
- Professional Information – e.g. job title, Specialty, Place of qualification, year of qualification, CV / biography, education level, job grade or level, employment start date, department/ function, location (your place of work), contract type, working hours, performance rating, income level
- Ethnicity Information – nationality, race
- Physical Characteristics – age, gender, disability
- Religion, sexual orientation
- Behavioural data – psychometric data (e.g. responses to personality questionnaires), attitudinal data (e.g. survey responses), responses to 360 feedback questionnaires, data gathered in interviews
- Preference information – consultant notes taken during an interview or focus group
Online payment information
In addition to the above, if you elect to pay for our services by Stripe or PayPal, we may hold the last 4 digits of your payment card number.
Where do we get your data from?
The personal data that we hold is provided to us by you, your respondents to your 360° feedback or your employer.
If you elect to pay by PayPal or Stripe, they may provide us with the last 4 digits of your payment card number.
How do we use your personal data?
- Contractual relationship. We may use your data to fulfil a contract to provide services to you or our client (usually this would be your employer).
In carrying out these services we may do one or more of the following:
- use data provided to us by Stripe and PayPal for the purpose of matching service users and payments
- use your details so that we can communicate with you by email or phone
- use data provided by completing psychometric questionnaires to prepare a report which summarises your personality profile. This may include showing how your responses compare to those of a comparison or norm group, so that your profile can be interpreted fairly and objectively
- use data provided by respondents completing 360⁰ feedback to provide an external view of an individual’s behaviours and performance
- use feedback requested during 360⁰ from colleagues, peers and patients to support the revalidation process for hospital doctors and GPs
- include your name and email address in the colleague nominations address book for each organisation or Primary Care area portal on the system where you have previously started a feedback exercise or been nominated to give colleague feedback
- use data provided via an employee survey to help an organisation measure and improve their employees’ experiences at work and the organisation’s performance
- use data provided during assessment interviews, coaching and feedback sessions to inform the professional opinion of a consultant / psychologist
- aggregate data collected on individuals within a team or a group of participants in a programme to provide a report on the group as a whole, in order to help with the group’s development and performance
- aggregate data collected on individuals within a focus group to create a report on the group as a whole, in order to identify themes and patterns in participant attitudes and preferences
- use personal data in order to conduct organisational research to help our clients to improve their organisation’s culture and/or performance
- use personal data in order to provide analyses of trends and patterns in different data sets for an individual, team or organisation (e.g. to track changes over time).
- Legal compliance. We may hold your data if we are legally required to do so.
- Legitimate business interests. We may anonymise your data for research purposes in order to:
- produce relevant norm groups so that individuals, teams and organisations can compare themselves to others
- improve the quality of our services and products
- conduct and publish research to provide thought leadership in our field.
- Information that we collect automatically on our Websites.
The personal information we hold is stored and processed securely in line with the UK government’s guidelines for Cyber security controls, Cyber Essentials*.
- Your personal information is held and processed in the UK.
- Your personal information may also be held and processed in the EU.
- Where we transfer your Personal Information outside the EEA to other countries, we will ensure that appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to protect your Personal Information. We will only transfer your Personal Information outside the EEA in accordance with applicable laws.
- Online payment processing.
What we don’t do with your personal data
- We do not use any automated decision-making systems relating to your personal data
- We do not sell your personal data to any third party
- We do not transfer your personal data to any third parties other than sub-contractors whose services are necessary for us to carry out our contracted service
- We do not collect or store Credit Card details
How long do we keep your personal data?
The information we use to communicate with you will be kept until you notify us that you no longer wish to receive information from us, or you want us to delete your personal data. Any personal data that we hold will be kept in line with the requirements of the Data Controller (this is usually your employer), or if the Data Controller has not provided a deletion policy we will hold the data until we are requested to delete it.
What are your personal data rights?
If at any point you believe the personal data we hold on you is incorrect, you want us to correct or delete that information, or you no longer want us to hold that information or contact you, you can exercise your rights under the current Data Protection laws. These rights include:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
For more information about your personal data rights please visit the Information Commissioner Office website at: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/individuals-rights/
Who do I contact if I have an issue with or question about the personal data that you hold about me?
Please contact our Data Protection Officer, Johannah Palmer on 0117 3328255 or email us at GDPR@edgecumbe.co.uk
How do I make a complaint about how my personal data is being held or processed?
If you wish to raise a complaint regarding the way we have handled your personal data, you can contact our Data Protection Officer (details above) who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data in a manner which is not in accordance with the instructions of the Data Controller or the law, you can contact the Information Commissioner’s Office (ICO) https://ico.org.uk/ Their Helpdesk number is 0303 123 1113.
* For more information about Cyber Essentials please visit: https://www.gov.uk/government/publications/cyber-essentials-scheme-overview