We are Peopleful Limited (CRN: 13004410).
Our registered office is 1st Floor, Buckhurst House, 42/44 Buckhurst Avenue, Sevenoaks, Kent, England, TN13 1LZ.
1. HOW DO WE USE YOUR DATA?
When you are invited to join the platform. If you receive an invitation to join our platform, this is because your employer has chosen to invite you to use our platform. Your employer will have sent us your name and email address in advance, so we can verify you are entitled to use our platform. Your employer will also usually send to us the business unit or department you work in, and the name of your line manager. Until you decide to register directly on our platform, we hold this data on behalf of your employer, as their data processor. This means that if you have any questions about this initial data transfer, we would suggest contacting your employer first, because they are the data controller in relation to the initial transfer of your data to us.
When you register and use our platform. If you sign up to use our platform, then Peopleful Limited (“Peopleful”) is the data controller over any data you provide to us when you use the platform. We also combine the data you give to us with the initial registration data your employer sent to us when we issued the invitation, and become the data controller over that data too.
The assessments you take on our platform are designed to determine your current work-related wellbeing, and to help you become happier and healthier. We collect your personal data (your name, contact details, and responses to the assessments) when you use our platform, and we rely on your explicit consent to do this.
We provide reports to your employer covering how their employees are feeling at an aggregated level, but your employer will never be shown the individual responses you give to your specific assessment.
If your responses suggest you need support. If your responses to the questions asked by our platform indicate that you would benefit from support, such as executive coaching or counselling, we will let you know. If you consent, we will share your feedback report with a third party to provide this additional support with you, and we will always make clear to you who we would introduce you to for this additional support before you consent. We will never report back to your employer that additional support has been recommended by us, or used by you, in a way that is identifiable to you.
When you contact us. When you contact us either by phone, email or via social media with general queries, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.
When you receive our email updates or marketing information. We will handle your personal information (such as your name and email address) to provide you with our news updates in line with any preferences you have told us about.
When we send you our news updates because you have opted-in to receive them, we rely on your consent to contact you. If you have not opted-in and we send you our news updates emails, or contact your over social media platforms such as LinkedIn, we do this because we have identified you as somebody who may be interested in working with us. The lawful basis we rely on to contact you in this way is our legitimate interest to promote our business.
You can unsubscribe from our updates at any time by clicking the unsubscribe link at the bottom of any of our emails, or by emailing email@example.com.
2. WHO DO WE SHARE YOUR DATA WITH?
One of our executive coaches or counsellors. Where your results have indicated you may benefit from additional support, we will either signpost this on your individual report or, if we are asked to by your employer, introduce or refer you to an executive coach or counsellor, who is not necessarily part of Peopleful. We only do this where you have provided us with your consent to do so.
Your employer. We provide aggregated and anonymised data back to your employer about their workforce’s state, and mood. We will not share personally identifiable data back to your employer (or any specific individual, such as your line manager) related to any aspect of your assessment.
Business partners, suppliers and subcontractors who help us run our business, each of whom has signed stringent data protection contracts with us.
3. WHERE IS MY DATA STORED?
We store your data with a third party called Afriforte. They are Peopleful’s sister organisation, a South African company whose servers are based in South Africa and Ireland. The security features implemented by Afriforte include:
- All data transmissions goes through 256 bit SSL Encryption.
- SSL Security Certificate is provided by Thawte.
- Sensitive data is encrypted by using one way encryption.
- No personal report access is granted without the express consent from the participant.
- All reports are locked per default.
4. HOW LONG DO WE KEEP YOUR DATA FOR?
We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to analyse our programmes and support other similar programmes around the world.
5. WHAT ARE MY RIGHTS UNDER DATA PROTECTION LAWS?
You have various other rights under applicable data protection laws, including the right to:
- access your personal data (also known as a “subject access request”);
- correct incomplete or inaccurate data we hold about you;
- ask us to erase the personal data we hold about you;
- ask us to restrict our handling of your personal data;
- ask us to transfer your personal data to a third party;
- object to how we are using your personal data; and
- withdraw your consent to us handling your personal data.
You also have the right to lodge a complaint with your data protection regulator. You can find which one applies to you here.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.
QUESTIONS, COMMENTS AND MORE DETAIL
Your feedback and suggestions on this policy are welcome.
We’ve worked hard to create a policy that’s easy to read and clear. But if you feel that we have overlooked an important perspective or used language which you think we could improve, please let us know by email at firstname.lastname@example.org.