Glass Ceilings Change Management’s Privacy Policy

Glass Ceilings Change Management Ltd respects privacy and takes seriously our responsibilities around protecting personal data. This privacy policy sets out your rights in respect of your personal data under relevant legislation. It is important that you read and understand it. It explains who we are; how and why we may use personal data; and, how to contact us. We are the “controller” of personal data under UK General Data Protection Regulations.

Our details

Throughout this Privacy Policy, ‘we, us, our’ refers to Glass Ceilings Change Management Ltd, a private limited company registered in England and Wales (company number 12961669).

Data Protection Officer: Laura Evans

Registered Office: 54 St. James Street, Liverpool, L1 0AB

Email: [email protected]

Definitions

Personal data is information that relates to an identified or identifiable individual.

Special categories of personal data is personal data about an individual’s:

  • race;
  • ethnic origin;
  • political opinions;
  • religious or philosophical beliefs;
  • trade union membership;
  • genetic data;
  • biometric data (where this is used for identification purposes);
  • health data;
  • sex life; or,
  • sexual orientation.

Personal data which also requires a higher level of protection can include information relating to criminal convictions and offences.

Legitimate Interest is when we have a business or commercial reason to use your personal data.

The type of personal information we collect

We currently collect and process the following information:

  • Your name, email address, phone number, and in some circumstances address.
  • Your technical data that enables you to access our website, such as internet protocol address, browser, time zone and location, operating system and platform.
  • Your user data on how you use our website.

Personal data we may collect depending on the service(s) we are providing to you

 

  • Your employment status.
  • Your diversity data, including any of the Protected Characteristics under the Equality Act 2010 or broader personal identifying characteristics about your appearance.
  • Your employment records including, where relevant, records relating to conduct, disciplinary and grievances; sickness and disability; and/or performance and development.
  • Your salary, salary scale, tax code, and National Insurance number if we are required to review pay slips as part of a review of pay and remuneration.
  • Your membership of a Pension Scheme or whether you have ‘opted out’.
  • Your membership of a Trade Union, Professional Body, or other professional organisation.
  • Your membership of organisations related to your beliefs, including religious, non-religious, or philosophical beliefs.
  • Personal data relating to your relationship status, family, and living arrangements.

We will only collect this data where it is relevant to an employment issue you are seeking our advice on and necessary to enable us to provide you with our services; or, where we are providing services to an organisation and have a legitimate reason to review personal data.

 

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you to enable us to provide you with our services or information.

We only collect personal information to provide you with information or marketing where you have given express consent. We do not engage in cold calling or unsolicited marketing.

We may also receive personal information indirectly, from the following sources in the following scenarios:

  • Employers, where we are processing personal data to provide services to organisations.
  • Technology, such as via our computer systems or electronic communications including email; video conferencing platforms; apps; text messaging or

‘Whatsapp’ messaging; social media direct messaging; or, social media sites.

  • The name of your bank or building society, for the purposes of invoicing, Direct Debit Agreements, or other electronic means of receiving payments for our services.

We use the information that you have given us in order to:

  • Provide you with our professional services.
  • Fulfil our contractual obligations.
  • Communicate before we enter into a contractual agreement for provision of our services, such as by providing you with a quote for use of our services based on information you provide to us directly.

We will only use personal data where there is a legitimate interest and you have given consent.

Who we share information with

We would not usually share your information with third parties. In limited circumstances, we may share your information with:

  • Regulatory bodies or law enforcement organisations where necessary to comply with legal processes or investigations; or,
  • Regulatory bodies or Courts and Tribunals Services, where necessary as part of a Conciliation or Employment Tribunal case.
  • Outsourced service providers, such as Accountancy and IT services, only where it enables them to provide us with their services.

Where we store information

We operate in a ‘paperless office’ environment. Personal data is stored on an electronic cloud-based system, backed up on secure servers. Our systems are behind secure firewalls and accessible only by 2-factor authentication. We do not keep paper files. If we take a note of personal data on paper, we would normally write up in electronic format in a timely way and not store. In the event that it is not written up in electronic format on the same day, paper copies are kept securely in a locked filing cabinet, and only for as long as necessary before being shredded and disposed of securely. We do not keep any records at our Registered Office address although personal data may be delivered there through the post before being collected.

How long we keep information

We will only retain your personal data for as long as it is necessary to provide you with our services. Retention periods may differ depending on the service we have provided to you, for example a matter that may result in Employment Tribunal, and the applicable retention period will be set out in our contractual agreement with you.

As soon as we no longer have a legitimate interest in storing or using your personal data, it will be deleted or placed into an anonymous format that cannot identify a living individual.

 

Lawful bases for processing information

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:  

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting: [email protected] (b) We have a contractual obligation.

  • We have a legal obligation.
  • We have a vital interest.
  • We have a legitimate interest.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected]

You can also complain to the Information Commissioner if you are unhappy with how we have used your data. The ICO’s Helpline number is 0303 123 1113.

Reviewed and Published: November 2024
Next scheduled review: November 2025

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