Insights General Privacy Notice (“Notice”)
Purpose
This Notice sets out how Insights collect and process personal data in order to provide you with our products and services. This Notice complies with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
We may process types of personal data as listed below:
We are The Insights Group Limited (SC166543), a company registered in Scotland and headquartered at Terra Nova, 3 Explorer Road, Technology Park, Dundee, DD2 1EG. Any reference in this Notice to “we” “our”, “us” or “Insights” means The Insights Group Limited and our affiliates. Insights is a "controller”, this means that we are responsible for deciding how we hold and use personal information about you.
If you are providing personal information about, or on behalf of, another person, you must make sure that you tell them what you are providing to us, why you are providing it and make them aware of this Notice. Please do not provide any personal information to us unless you have the right to do so.
This Notice governs our practices in relation to the personal data collected and processed by Insights only. If you are receiving Insights products through your employer, we refer to your employer as our “Direct Client” and we refer to their employees that have been accredited by Insights as “Client Practitioners”. You may also receive services through a third party that we refer to as an Insights “Partner” who, as an independent controller, will distribute Insights products in their chosen location worldwide. Insights may deliver products directly to you in the context of a debrief, workshop, experience and/or learning event (an “Insights Event”). However, we also enable customers to deliver products to you through our Client Practitioners or through an Insights Partner.
It is important that you read this Notice and that you are fully aware of how and why we are using your data. This Notice does not govern the practices of third parties which Insights does not own or control such as, but not limited to, our Direct Clients and/or Partners.
Where you undertake the Insights Discovery Evaluator or attend an Insights Event facilitated or delivered by a colleague, it is likely that your employer has paid for them to be accredited to deliver Insights products internally within your organisation. We provide Insights products to Client Practitioners for the purposes set out in this Notice.
Although Client Practitioners are accredited by Insights, they are under the control of your employer and may act upon your employer’s instructions. Where your employer instructs or permits a Client Practitioner to process your personal data in a manner not set out in this Notice, they must have a lawful basis to do so, and they should provide you with a separate privacy notice or statement covering their processing activities.
We are not responsible for any processing activities carried out by:
or otherwise, for any purpose other than those purposes specified in this Notice.
We may provide products to Partners. Although we share your personal profile, colour preferences, team wheel and/or any other Insights products with them for the purposes set out within this Notice, these third parties are not controlled by us. Partners are responsible for their own compliance with data protection laws including providing you with a privacy notice with any lawful basis for their processing activities.
We will only collect and process personal data if we have a lawful basis to do so. We will collect and process your personal data in the following circumstances:
We generally collect your personal data in order to provide you with products and services . However, we may also collect information from third parties. Collecting personal data may take the form of any of the below:
We may also collect personal data about you from third parties or publicly available sources including:
For avoidance of doubt, whilst we provide psychometric “profiles”, we do not use any type of automated decision-making such as profiling as defined in data protection laws.
In order to produce products such as our personal profiles, and team wheels (which illustrate where each individual team member sits in relation to each other team member), we require to collect your name and email address. Once we have received your name and email address, we can provide you with a link to the questionnaire which we refer to as the “Insights Discovery Evaluator”. This tool uses a simple and memorable colour model to help individuals understand their style, their strengths and the value they bring to their team.
The Insights Discovery Evaluator consists of a series of statements, and you will be asked to rank how well you believe each statement describes you and/or your personal preferences in a business environment. Your answers will be processed by our algorithm and results in a “personal profile” which is personal to you.
We also keep a copy of your Insights Discovery Evaluator responses on file to:
You are entitled to opt out of being included in a team wheel. If you chose to opt out of the team wheel you can do so by contacting us by email:dpo@insights.com and by letting your Client Practitioner or Partner know.
Once a team wheel is created and printed, your personal data may be shared with other members of your team and/or with your employer. We can remove your wheel position from future electronic copies of team wheels, but we may not be able to remove you from hard copies or electronic copies which are already in existence.
If you would not like to receive a personal profile, please do not complete our Insights Discovery Evaluator because once completed, a personal profile will automatically be generated.
Once a personal profile is created and printed, your personal data may be shared with an Insights Accredited Practitioner or administrators. Whilst we can delete any copies which we hold, we will not have control over any hard copies or electronic copies stored by your employer, Insights Accredited Practitioner or administrator. It is important that you also request that your Insights Accredited Practitioner and/or administrator also deletes any copies which they hold from their own systems. Insights has no control over personal information that is not stored on our own internal systems.
We may have to share your personal data with third parties for processing or sub-processing purposes in order to provide you with Insights products and services. We undertake a selection process and periodic review in relation to processors and sub-processors. We may also share your personal data with controllers. For avoidance of doubt, we do not sell any personal data we collect.
We may share your personal data with third parties some of whom may be located outside the EEA as follows:
Where personal data is transferred outside the EEA, we take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Notice.
We will only retain your profile personal data for 5 years from the date that it was last accessed.
All other personal data will only be retained us for as long as necessary taking into consideration appropriate legal obligations to retain records.
You have the right to:
You may access those rights by contacting our Data Protection Officer at: dpo@insights.com.
If you have any questions or concerns about this Notice please contact us at dpo@insights.com or by writing to our registered address, detailed above.
You may also wish to raise any concerns with the relevant data protection supervisory authority. The UK Information Commissioner’s Office (ICO) is the relevant supervisory authority for Insights. The ICO can be contacted at casework@ico.org.uk
We may change this Notice from time to time so please check regularly to keep informed of updates. We will endeavour to keep you informed of updates via our website, applications and/or through the email address you provided to us. We also ask that you check our websites for any updates which may affect you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can contact us at any time to update your personal data.
Last updated: 12 June 2024
