Privacy Policy
WHO WE ARE
Our website address is https://www.inclusiveboards.co.uk.
COMMENTS
Last updated November 2020
Thank you for choosing to be part of our community at Inclusive Boards Limited (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at hello@inclusiveboards.co.uk.
When you visit our website inclusiveboards.co.uk and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our Sites and our services.
This privacy policy applies to all information collected through our website (such as www.inclusiveboards.co.uk), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services“).
Please note that Inclusive Boards may amend this Privacy Policy from time to time. To stay up-to-date, please visit this page which will always display all amendments.
Should you be dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
This Privacy Policy applies to any business activities that are carried out in relevant countries. This allows us to ensure that Inclusive Boards is complying with all applicable data privacy protection, no matter where you are.
Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.
1. WHAT INFORMATION DO WE COLLECT?
The personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, and payment information where appropriate.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services when participating in activities on the Services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Publicly Available Personal Information. We collect first name, maiden name, last name, phone numbers, email addresses, business email, business phone number, social media, and other similar data.
Personal Information Provided by You. We collect CV and other job application data such as background checks, data collected from surveys, financial information (credit card number, purchase history, invoices), and other similar data.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Depending on the relevant circumstances and applicable local laws, we may collect some or all the information listed below to enable us to offer you relevant job opportunities which are tailored to your skills set, expertise and interests. We may also collect data for our executive leadership programme, conferences and events provided by Inclusive Boards.
Candidate Data
In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:
- Name
- Date of Birth
- Gender
- Photograph
- Marital Status
- Contact Details
- Education Details
- Employment History
- Emergency Contacts
- Details of Dependants
- Referee Details
- Immigration Status (whether you need a work permit)
- Nationality/Citizenship/Birthplace
- Copy of Driving Licence and/or Passport/Identity Card
- Financial Information (where financial background checks are required)
- NI Number (or your country equivalent) and any other tax-related information
- Diversity Information including (but not limited to)
- Racial or Ethnic Origin
- Religious or Other Beliefs
- Physical or Mental Health including disability-related information
- Details of any criminal convictions (should this be a requirement for a role that you are interested in applying for)
- Details about your current remuneration, pensions & benefits arrangements
- Information about your specific interests & needs regarding future employment, both collected directly and inferred, for e.g. from jobs and/or articles posted on our website
- Any additional information you choose to share with us
- Any additional information your referees choose to share about you
- Any additional information our clients may choose to share about you, or that we come across via other Third-Party sources such as job sites
- IP address
- Date, time and frequency of access to our services
- CCTV footage if you visit our offices
Client Data
The data we collect about clients is rather limited.
We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to maintain an effective business relationship. We also hold information relating to your online engagement with candidate profiles and other material published by Inclusive Boards, to ensure that you receive timely marketing communications relevant to you.
We may also hold additional information that someone in your organisation has chosen to share with us. In certain circumstances, such as for training purposes our calls with you may be recorded, depending on the applicable local laws and requirements.
Supplier Data
The data we collect about suppliers is rather limited to maintain an effective business relationship.
We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details so that we can pay you. We may also hold additional information that someone in your organisation has chosen to share with us. In certain circumstances, such as for training purposes our calls with you may be recorded, depending on the applicable local laws and requirements.
Persons whose data we receive from Candidates & Employees
In the case of ‘referees’, we require confirmation of information that we have already obtained from our candidate or prospective Inclusive Boards employee to enable them to secure a job.
In the case of an ‘Emergency Contact’ – details provided in the case of an emergency
When requesting a reference, we require the referee’s contact details (such as name, email address and telephone number).
Information automatically collected
Inclusive Boards may automatically collect your data where appropriate and in accordance with any local laws and requirements when you access our website or open, read or click on an email from Inclusive Boards.
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect devices, applications, tools and protocols, such as IP (Internet Protocol) addresses, cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data.
Client Data
Inclusive Boards collects personal data from clients:
- When it is given to Inclusive Boards;
- Inclusive Boards receives from other sources
- Inclusive Boards collects automatically
Personal data given to us
Inclusive Boards receives data directly from clients as follows:
- When you contact Inclusive Boards by phone or email
- When Inclusive Boards contacts you by phone or email
- When Inclusive Boards contacts you through our consultants’ business development activities
Personal data received from other sources
Inclusive Boards may seek further information about yourself and/or your colleagues from other sources generally by way of due diligence or other market intelligence including (but are not limited to):
- Third-party market research such as on/offline media
2. HOW DO WE COLLECT YOUR PERSONAL DATA?
Candidate Data
Inclusive Boards collects personal data from candidate:
- When it is given to Inclusive Boards;
- Inclusive Boards receives from other sources
- Inclusive Boards collects automatically
Personal data given to us
To offer you a bespoke service, Inclusive Boards requires to collate certain information about you. This enables us to provide you with suitable job opportunities that match your specific search criteria. This also ensures that you are not subject to jobs and services that are not relevant to you.
The various ways that you may share your information with Inclusive Boards include (but are not limited to):
Entering personal details on the Inclusive Boards website by downloading reports or insight reports, completing a contact form, a job application form or a candidate registration form, as part of the registration process
- Hard copy of CV obtained at an Inclusive Boards networking event or offices
- CV is emailed to an Inclusive Boards consultant
- CV is handed to Inclusive Boards consultant during the interview process
- Applying for a job via an aggregator
Personal data received from other sources
Personal data may also be received from other sources such as:
- Referees
- Clients
- Third party sources for e.g. LinkedIn and other job sites
- Twitter and other social media platforms
- RPO or MSP supplier
3. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at Data@inclusiveboards.co.uk and be sure to include your name, testimonial location, and contact information.
- Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To deliver services to the user. We may use your information to provide you with the requested Service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing, and your experience. We may use and store this information in aggregated and anonymised form so that it is not associated with individual end-users and does not include personal information. We will not use identifiable personal information without your consent.
Candidate Data
Inclusive Boards utilises personal data from candidate:
- Recruitment Activities
- Marketing Activities
- Equal Opportunities Monitoring
- Legal Claims
Please note that we also utilise data for career coaching and mentoring services provided by Inclusive Boards
Recruitment Activities
Below is a list of the ways, Inclusive Boards may use and process your personal data for recruitment, where appropriate and in accordance with any local laws and requirements. This includes but is not limited to:
- Collecting data from yourself and other sources
- Storing and updating your details on our database
- Provision of Inclusive Boards recruitment services
- Facilitation of Inclusive Boards’ recruitment process
- Assessing your data against job vacancies to suit your specific requirements
- Sharing your information with clients, to apply for job vacancies or to assess your eligibility for job vacancies
- Enabling you to submit your CV
- Enabling you to apply online for job vacancies
- Enabling you to subscribe to job alerts matching your search criteria
- Allowing you to participate in specialist online training
- Allowing you to participate in the interactive features of our services
- Carrying out Inclusive Boards obligations arising from any contracts between Inclusive Boards and yourself
- Carrying out our obligations arising from any contracts between Inclusive Boards and third parties in relation to your recruitment
- Facilitating our payroll & invoicing processes
- Carrying out customer satisfaction surveys
- Verifying details provided by yourself, using third party resources for e.g. psychometric evaluations or skills tests, or to request information for e.g. references, qualifications and potentially any criminal convictions)
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties
- Processing your data to enable Inclusive Boards to send you targeted, relevant marketing materials or other communications which may be of interest
We may utilise your personal data for the above purposes, should we deem it necessary to do so for our legitimate interests.
Marketing Activities
Below is a list of the ways, Inclusive Boards may send you information that may be of interest to you or to request your assistance to connect other candidates with jobs. Specifically, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. This includes but is not limited to:
- Developing and marketing other products and services
- Marketing our full suite of recruitment services
- Sending you details of reports, promotions, offers, networking and client events, and industry news which might be of interest to you
- Displaying promotional excerpts from your details on Inclusive Boards’ website(s) as a success story (only where we have obtained your explicit consent to do so)
- Share information about certain discounts and offers that you are eligible for by your relationship with Inclusive Boards.
Should you wish to not receive Inclusive Boards marketing communications, please submit a written request to unsubscribe to data@inclusiveboards.co.uk.
Should you have unsubscribed from our marketing communications, it is possible that your details may be re-captured through public sources in an unconnected marketing campaign. We will endeavour to ensure this never happens, however, if it does due to human error, we would like to apologise in advance. In such instances, we suggest you unsubscribe again.
Equal opportunities monitoring
Inclusive Boards is committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities.
- Some of the data we may collect about you falls under the umbrella of “diversity information”. This could be data relating to your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, Inclusive Boards will use this data on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to our clients where this is contractually required or when specifically requested by clients to enable them to comply with their own employment processes.
- Such data is referred to as ‘sensitive’ personal data and stricter data protection rules apply. Inclusive Boards requires your explicit consent before we can utilise/share such data. We’ll ask for your consent by offering you an opt-in. This means that you must explicitly and clearly state that you agree for Inclusive Boards to collect and utilise such data. This is often captured through the Diversity Monitoring Form online.
- Inclusive Boards may collect other sensitive personal data, such as health-related information, religious affiliation, or details of any criminal convictions (where appropriate and in accordance with local laws) and if it is required for a job vacancy that you are interested in applying for. Please note that Inclusive Boards will never carry out any such activity without your explicit consent.
- For our Diversity Reporting, we source our data from the public domains i.e. data that is publicly available. Upon collection, data is anonymised.
Legal claims
In a very rare instance, Inclusive Boards may use your personal data to help us to establish, exercise or defend legal claims.
Profiling
Currently, all Inclusive Boards recruitment activities involve human decision-making during the full cycle process. Looking ahead, Inclusive Boards may choose to utilise automated technologies such as expert systems or machine learning to complete the candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements
Where necessary, Inclusive Boards will seek your consent to carry out some or all these activities. If you do not consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of successfully placing you in a new job.
Client Data
Inclusive Boards utilises client data for:
We use client information for
- Recruitment Activities
- Marketing Activities
- Legal Claims
Recruitment activities
Inclusive Boards’ primary work activity is recruitment – Executive Search, Recruitment, Board & Diversity Research and Advisory and Executive Training.
Below is a list of the ways, Inclusive Boards may use and process your personal data for recruitment, where appropriate and in accordance with any local laws and requirements. This includes but is not limited to:
- Storing and updating your details on our database
- Keeping records of our conversations and meetings
- Carrying out customer satisfaction surveys
- Processing your data to enable Inclusive Boards to send you targeted appropriate marketing campaigns.
We may utilise your personal data for the above purposes, should we deem it necessary to do so for our legitimate interests.
Marketing activities
Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as the Inclusive Boards Leadership Programme, sector diversity reports and other such reports to a corporate postal or email address.
Legal Claims
In a very rare instance, Inclusive Boards may use your personal data to help us to establish, exercise or defend legal claims.
Supplier Data
Inclusive Boards utilises supplier data to:
- Store and update your details on our database, enabling Inclusive Boards to contact you in relation to our agreements
- Offer services to you or to obtain support and services from you;
- Perform certain legal obligations
- Help Inclusive Boards share targeted, relevant marketing campaigns
In a very rare instance, Inclusive Boards may use your personal data to help us to establish, exercise or defend legal claims
We may utilise your personal data for the above purposes, should we deem it necessary to do so for our legitimate interests.
Subject to any applicable local laws and requirements, Inclusive Boards will not seek your consent when sending marketing materials to a corporate postal or email address.
Persons whose data we receive from Candidates & Employees
Inclusive Boards utilises the data our candidates share about you for the following purposes:
- If our candidates or employees name you on our form as an emergency contact, Inclusive Boards will contact you in the case of an accident or emergency
- If our candidates or prospective employees name you as a referee, Inclusive Boards will contact you to take up a reference. This is an integral part of our candidate quality assurance process and could be the deciding factor in whether the candidate gets the job or not.
We may utilise your personal data for the above purposes, should we deem it necessary to do so for our legitimate interests.
Website users
Inclusive Boards utilises your data to help improve your user experience, for e.g. by analysing your recent job search criteria allowing Inclusive Boards to present you with job opportunities or candidates we think you’d be interested in.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
Inclusive Boards may share your personal data in a variety of ways and reasons, where appropriate and in accordance with local laws and requirements. This includes the following categories of people (but are not limited to):
- Any of our associated companies, foundations and/or charities
- Individuals and organisations who hold information related to your reference or application to work with us, for e.g. current, past or prospective employers, educators and examining bodies and employment and recruitment agencies
- Tax, audit, or other authorities, when Inclusive Boards is of the belief that the law or other regulation requires us to share this data. For e.g. at the request of a tax authority or in connection with any anticipated litigation
- Third party service providers who perform functions on our behalf – external consultants, business associates and professional advisors (solicitors, auditors, accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems)
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place
- Marketing technology platforms and suppliers
- In the case of candidates:
- Potential employers and other recruitment agencies/organisations to improve your chances of finding a job
- Third party partners, job boards and job aggregators to increase the chances of finding a job
- In the case of candidates and prospective employees’ referees:
- Third parties who provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 3 years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data).
- For those candidates whose services are provided via a Third-Party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than three years from that point.
- When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital messages from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services contact a member of our team directly from here.
HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals within the EU with regards to data privacy. This means that you retain various rights in respect of your data.
DATA SUBJECT USER RIGHTS
The GDPR provides the following rights for individuals/data subjects:
RIGHT TO OBJECT
This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to Inclusive Boards, processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- Inclusive Boards can demonstrate that we have compelling legitimate grounds for processing which overrides your interests
- Inclusive Boards is processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, Inclusive Boards must act on your objection by ceasing this activity.
RIGHT TO WITHDRAW CONSENT
Where Inclusive Boards has obtained your consent to process your personal data for certain activities – for e.g. for our marketing arrangements or automatic profiling, you may withdraw this consent at any time. Inclusive Boards will cease to carry out the specified activity that you previously consented to unless we consider there’s an alternative reason to justify our continued processing of your data for this purpose; in which case, Inclusive Boards will inform you of this condition.
RIGHT TO ACCESS
More commonly known as DATA SUBJECT ACCESS REQUEST (DSAR)
You may request Inclusive Boards to confirm what information we hold on you at any time, and submit a request to modify, update or delete such data. Inclusive Boards will ask you to verify your identity and request further information about your request.
Should Inclusive Boards provide you with access to the information we hold, you will not incur a cost unless your request is “manifestly unfounded or excessive”.
Should you request additional copies of your data, Inclusive Boards may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, Inclusive Boards may refuse your request. If we refuse your request, we will always share the reasons for doing so.
RIGHT TO ERASURE
You have the right to request Inclusive Boards erases your personal data in certain instances. The data must meet one of the following criteria:
- The data no longer necessary for the purpose for which we originally collected and/or processed
- Where previously given, you have withdrawn your consent for Inclusive Boards to process your data, and no other valid reason exists for Inclusive Boards to continue processing
- The data has been processed unlawfully i.e. in a manner which does not comply with the GDPR
- It’s a requirement for the data to be erased for Inclusive Boards to comply with our legal obligations as a data controller
- If Inclusive Boards processes the data because we believe it necessary to do so for our legitimate interests, you object to the processing and, Inclusive Boards is unable to demonstrate overriding legitimate grounds for our continued processing.
- Inclusive Boards would only be entitled to refuse to comply with your request for one of the following reasons:
- To exercise the right of freedom of expression and information
- To comply with legal obligations or for the performance of a public interest task or exercise of official authority
- For public health reasons in the public interest
- For archival, research or statistical purposes
- To exercise or defend a legal claim
When complying with a valid request for the erasure of data we will take all necessary steps to delete the relevant data.
RIGHT TO RESTRICT PROCESSING
You have the right to request that Inclusive Boards restricts the processing of your personal data in certain instances. This means that Inclusive Boards can only continue to store your data and will not be able to carry out any further processing activities until either:
- One of the circumstances outlined below is resolved
- You consent
- Further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest
The circumstances in which you are entitled to request that Inclusive Boards restrict the processing of your personal data are:
- Where you dispute the accuracy of the personal data that Inclusive Boards is processing. In this instance, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified
- Where you object to our processing of your personal data for our legitimate interests.
In this instance, you can request that the data be restricted while Inclusive Boards verify our grounds for processing your personal data - Where our processing of your data is unlawful, but you would prefer Inclusive Boards to restrict our processing rather than erasing your data
- Where Inclusive Boards has no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with Third Parties, Inclusive Boards will notify them about the restricted processing unless this is impossible or involves disproportionate effort. Inclusive Boards will notify you before lifting any restriction on processing your personal data.
RIGHT TO RECTIFICATION
You also have the right to request that Inclusive Boards rectifies any inaccurate or incomplete personal data that we hold on you. If Inclusive Boards has shared this personal data with any Third Parties, we will notify them about the rectification unless this is impossible or, involves disproportionate effort. Where appropriate, Inclusive Boards will also inform you which Third Parties we’ve disclosed the inaccurate or incomplete personal data to. Where Inclusive Boards thinks it is reasonable not to comply with your request, we will explain our reasons for this decision.
RIGHT OF DATA PORTABILITY
You have the right to transfer your personal data between data controllers. This means that you can transfer your Inclusive Boards account details to another online platform. To allow you to do so, Inclusive Boards will provide you with your data in a commonly used machine-readable format that is password-protected so that you are able to transfer the data to another online platform.
Alternatively, we may directly transfer the data on your behalf. This right of data portability applies to:
- personal data that Inclusive Boards processes automatically
- personal data provided by yourself
- personal data that Inclusive Boards processes based on your consent or,
to fulfil a contract
Should you wish to exercise any of these rights, or withdraw your consent to the processing of your personal data, where consent is Inclusive Boards’ legal basis for processing your personal data, please contact in writing to data@inclusiveboards.co.uk
Please note that Inclusive Boards may retain a record of your communications to help us resolve any issues which you raise.
It is important that the personal data Inclusive Boards holds on you is clean, current and accurate. Please keep Inclusive Boards informed if your personal information changes during the period for which we hold your data.
To get in touch about your user rights, please write to Inclusive Boards. 16 Upper Woburn Place. WC1H 0AF or send an email to data@inclusiveboards.co.uk We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that Inclusive Boards may keep a record of your communications to help us resolve any issues which you raise.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
9. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Katie Petrou, by email at Data@inclusiveboards.co.uk, by phone at 0207 268 8369, or by post to:
Inclusive Boards Limited
Katie Petrou
16 Upper Woburn Place, London WC1H 0AF, United Kingdom
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by clicking here. We will respond to your request within 30 days
GLOSSARY
Candidate – includes applicants for all roles advertised or promoted by Inclusive Boards, including permanent, part-time and temporary positions and freelance roles with Inclusive Boards clients; as well as persons who have supplied a speculative CV to Inclusive Boards not in relation to a specific job. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Inclusive Boards will be treated as candidates for the purposes of this Privacy Policy. In addition, any persons Inclusive Boards has speculative conversations with regarding potential job opportunities are also included.
Clients – this category covers our customers, clients, and others to whom Inclusive Boards provides services in the course of its business.
Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example, if it is waiting to be over-written. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or employees.
General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Other people whom Inclusive Boards may contact – these may include emergency contacts and referees for candidates and Inclusive Boards employees. We will only contact them in appropriate circumstances.
Recruitment Process Outsourcing (RPO) services – full or partial outsourcing of the recruitment process for permanent employees to a recruitment provider.
Employees – includes employees and interns engaged directly in the business of Inclusive Boards (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to Inclusive Boards (even though they are not classed as employees). Likewise, independent contractors and consultants performing services for Inclusive Boards fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.
Suppliers – refers to partnerships and companies (including sole traders), and typical workers such as independent contractors and freelance workers, who provide services to Inclusive Boards. In certain circumstances, Inclusive Boards will sub-contract the services it provides to clients to Third Party suppliers who perform services on Inclusive Boards’ behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as candidates for data protection purposes. Please note that in this context, Inclusive Boards requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at candidates) to their employees.
Website users – any individual who accesses any of the Inclusive Boards websites and/or microsites