Purely Media People is committed to ensuring that your privacy is protected. We
understand our responsibilities to handle your personal data with care, to keep it secure, and to comply with legal requirements. This privacy statement explains what personal data we collect from you, how we use that data and who we share that data with.

This policy sets out how we will handle your personal information.

What information do we collect?

We may collect, store & use the following types of personal information:

• Information about your computer, your visits & use of this website, such as your IP address, approximate geographical location, browser, operating system, referral source, length of visit, page views, navigation & downloads.
• Registration information including, but not limited to; name, email address, company name & your question or message.
• Any other information that you deliberately send to us.
• If you are completing an online psychometric assessment, we process personal data relating to either your application with a potential employer or an internal assessment with your current employer.
• If you are completing an online 360 assessment, we process personal data relating to an internal assessment with your current employer. We do not sell, rent or exchange your personal information with any other third party for commercial reasons. We will follow the confidentiality arrangements set out in the email you received asking you to take part in the feedback process. If you require a copy of this email, please do contact us on info@purelypeople.com.

What do we do with your data?

Our lawful basis for processing personal data is as follows:

• To carry out our obligations arising from any contracts entered into between us
  and the Client.
• To deliver carefully collated feedback for the purposes of personal development
  as well as reviews recorded for performance management.
• We share the data with third party service providers to help manage our business
  and deliver services. For example, we have service providers who provide IT
  applications or systems, which means that your personal data will be hosted on
  their servers, but under our control and direction. We require all our service
  providers to respect the confidentiality and security of personal data.

How long do we keep your data?

• Data is retained for five years from the end of the contract, unless the Data Controller specifically requests an alternative retention period.

Using your personal information

Personal information submitted via this website will be used for the purposes specified on the website.

We may use your personal information to:

• administer the website
• personalise the website
• facilitate your use of the services available on the website
  supply services you have purchased
• send statements & invoices to you & collect payments from you
• send you general commercial communications
• send you email information that you specifically request
• provide third parties with statistical information about our users, but this information
• will not be used to identify you personally
• deal with enquiries & complaints made relating to the website
• send you a newsletter & other marketing materials relating to our business which
• we think may be of interest to you by email (you can require us at any time to stop
  sending marketing communications)

Where you submit information for publication on our website, we will publish &
otherwise use that information according to your instructions.

We will not provide your personal information to any third parties for the purposes of
direct marketing. We do not sell, rent or exchange your personal information with any other third party for commercial reasons. If you are applying for a vacancy with a potential employer, then, by submitting this information, you grant us the right to share this information with your potential employer and your recruitment agent. If you are undertaking an internal assessment with your current employer, then, by submitting this information you grant us the right to share this information with your current employer.

Disclosures

We may disclose information about you to any of our employees, agents, suppliers or
subcontractors where it is reasonably necessary for the purposes as set out here.

In addition, we may disclose your personal information:

• to the extent required to do so by law
• in connection with legal proceedings or potential legal proceedings
• to establish, exercise or defend our legal rights (including fraud prevention information sharing)
• to the purchaser (or prospective purchaser) of any business or asset which we are selling, and
• to any person who, in our reasonable opinion, we believe may apply to a court or other similar authority for disclosure of such, where, again in our reasonable opinion, such court or authority would be likely to order such disclosure

Except as provided in this privacy policy, we will not provide your information to third parties.

Your Rights

Under the General Data Protection Regulation, you, as a data subject have a number of rights which are listed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions. All requests to exercise your rights should be made to the appropriate Data Controller.

Access to personal data: You have a right to request a copy of the personal information that we hold about you. Our feedback products store feedback that users have given about each other. Where the nature of the feedback product is such that this feedback is open, such as appraisal feedback, then all such data are accessible. However, where the process has been designed on the understanding that the feedback is anonymous and aggregated, such as confidential 360 feedback, then we reserve the right to withhold access on the grounds that it would ‘adversely affect the rights and freedoms of others’.

Correction of personal data: You can request that we rectify and correct any personal data that we are processing about you which is incorrect.

Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.

Right to erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.

Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.

Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.

We reserve the right to withhold such personal information to the extent permitted by
law.

You may instruct us not to process your personal information for marketing purposes by email at any time. In accordance with the General Data Protection Regulation we will ensure that people are made to actively opt-in to continue to receive our direct marketing from 25th May 2018.

Security of your personal information

We will take reasonable precautions to prevent the loss, misuse or corruption of your personal information.

We will store all the personal information you provide on our secure servers. However, data transmission on the internet is insecure & we cannot guarantee the security of data as it travels over the internet.

You must keep your password & user details confidential. We only ask you for your password when you log in.

Our website contains links to other websites. We are not responsible for the content, privacy policies or safety of such third-party websites.

Purely Media People have a procedure in place if a breach of security leads to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed. We will assess the scope and impact of the breach. Based on the assessment of the likely risks to individuals, we will notify the individuals and/or their connected organisations that a data breach has occurred where this may result in a significant risk to the rights and freedoms of individuals, or where we may be in breach of a contractual obligation.

Any such notification to individuals will be carried out as soon as reasonably possible and will include information on the nature of the breach, the name and contact details of our Data Protection representative, the likely consequences of the breach, measures taken or proposed by Purely Media People to address it and recommendations for affected individuals to mitigate any potential adverse effects. Such individuals will also be provided advice on how to make a complaint to the ICO.

If, due to the nature of the breach that Purely Media People is required to inform the ICO, we will do so within 72 hours of becoming aware of the essential facts of the breach. Such notification must include at least: your name and contact details; the date and time of the breach (or an estimate); the date and time we detected it; basic information about the type of breach; and basic information about the personal data concerned.

Cookies

Our website uses cookies. By using our website, you consent to our use of cookies as described here.

A cookie consists of information sent by a web server to a browser & stored by the browser. This information is sent to the server each time you request a page. The web server can thus identify & track the web browser.

We will use the session cookies to: keep track of you whilst you navigate the website; & anonymously aggregate information about the way users use the site.

We will use the persistent cookies to: enable our website to recognise you when you visit; recording the details you give us when you post a comment.Session cookies are deleted from your computer when you close the browser. Persistent cookies remain stored until deleted or until they expire.

3rd Party Cookies

Our website contains links to other websites. We are not responsible for the content, privacy policies or safety, of such third-party websites.

If you click on a link from Purely Media People’s website to any third-party website, you may be sent cookies from these third-party websites. Third party websites will have their own privacy and cookie policies which we cannot control. Please check the third-party websites for more information about their cookies and how to manage them.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical information about the website using cookies which are stored on your computer. Google will store this information but are not allowed to share anything which would personally identify you. Google’s privacy policy is available at: https://www.google.com/privacypolicy.html.

Web browsers allow you to reject cookies. Blocking all cookies will, however, have a
negative impact upon the usability of many websites, including this one.

When you comment on our blog, you get cookies stored on your computer. This is purely a convenience so that you won’t need to re-type all your information again when you want to leave another comment. Three cookies are set for commenters:

• comment_author
• comment_author_email
• comment_author_url

The commenter cookies are set to expire a little under one year from the time they’re set.

For more information on how websites use cookies and what you can do about them go to aboutcookies.org.

International data transfers

Information which you provide may be transferred to countries including the United States, where our web server is located, & other countries which do not have data protection laws equivalent to those in force in the European Economic Area.

In addition, personal information that you submit for publication on the website will be published on the internet & will be available, via the internet, around the world. We
cannot prevent the use or misuse of such information by others.

We shall require anyone handling your data in other countries to comply with the
restrictions placed upon us in the UK by GDPR and the Data Protection Act (2018).
You agree to such transfers of personal information.

Policy amendments

We may update this privacy policy by posting an amended version on this website. You should check this page occasionally to ensure you are happy with any changes.

Contacting us

Please tell us if your personal information needs updating or correcting.

If you have any questions about this policy or our use of your information, please write
to us by email at enquiry@purelymediapeople.com. Our registered office is: Purely Media People, 27 Old Gloucester Street, London, WC1N 3AX.