The Company is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we hold on you. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:

Loren Snow – info@neurodiversetraining.org

In relation to your personal data, we will:

• process it fairly, lawfully and in a clear, transparent way

• collect your data only for reasons that we find proper for the course of our engagement with each other

• only use it in the way that we have told you about

• ensure it is correct and up to date

• keep your data for only as long as we need it

• only process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate).

We collect data about you in a variety of ways, for example:

• from you directly

• notes made by our team

• directly from you when you complete forms

• directly from you in the form of documentation you provide us

In some cases, we will collect data about you from third parties, such as agencies, former employers when doing things such as gathering references for employment.

Personal data is kept in personnel files or within the Company’s HR and IT systems.

We may hold types of data about you, (although most of these are only if you’re employed by us or working with us), including:

• your personal details including your name, address, date of birth, email address, phone numbers

• your photograph

• gender

• marital status

• dependants, next of kin and their contact numbers

• medical or health information including whether or not you have a disability

• information used for equal opportunities monitoring about your sexual orientation, religion or belief and ethnic origin

• information included on your CV including references, education history and employment history

• documentation relating to your right to work in the UK

• driving licence

• bank details

• tax codes

• National Insurance number

• current and previous job titles, job descriptions, pay grades, pension entitlement, hours of work and other terms and conditions relating to your employment with us

• letters of concern, formal warnings and other documentation with regard to any disciplinary proceedings

• internal performance information including measurements against targets, formal warnings and related documentation with regard to capability procedures, appraisal forms

• leave records including annual leave, family leave, sickness absence etc

• details of your criminal record

• training details

• CCTV footage

• building entry card records.

We do not store sensitive personal information in the cookies we use.

We use no third party cookies.

We only use cookies strictly necessary for the functionality of our website.

These cookies fall outside of the need to request consent: see ICO.

If you prefer to avoid the use of cookies on our website, first you must disable the use of cookies in your browser and then delete the cookies saved in your browser associated with this website. You may use this option for preventing the use of cookies at any time.

We will only collect criminal conviction data where it is appropriate (eg for employees).

The law on data protection allows us to process your data for certain reasons:

• in order to perform contracts that we are party to

• in order to carry out legally required duties

• in order for us to carry out our legitimate interests

• to protect your interests and

• where something is done in the public interest.

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:

• business planning and restructuring exercises

• dealing with legal claims made against us

• preventing fraud

• ensuring our administrative and IT systems are secure and robust against unauthorised access

Special categories of data are data relating to your:

• health

• sex life

• sexual orientation

• race

• ethnic origin

• political opinion

• religion

• trade union membership

• genetic and biometric data.

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:

• you have given explicit consent to the processing

• we must process the data in order to carry out our legal obligations

• we must process data for reasons of substantial public interest

• you have already made the data public.

We will use your special category data:

• With your consent to inform the service we provide (as data around physical health and neurodivergence informs the training we offer you and your staff and the advice and consultancy we provide)

• to determine reasonable adjustments

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties.

We share your data with third parties only where absolutely necessary to carry out our normal business operations [eg to ensure your reasonable adjustments are met by a third party, to ensure you are safe].

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.

We do not share your data with bodies outside of the European Economic Area.

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your engagement with us though in some cases we will keep your data for a period after to support further work together. Retention periods can vary depending on why we need your data.

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice

• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request to Loren Snow at info@neurodiversetraining.org

• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it

• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it

• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct

• the right to portability. You may transfer the data that we hold on you for your own purposes

• the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests

• the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

ICO Registration Reference: ZB268215