Vivat Learning PTY LTD TAS Lever – Transfer of Learning Privacy Policy
Updated 23rd May 2018
We respect your data
We will not sell or rent your data
We will keep your data securely
You can have your data deleted at any time by emailing emma@leverlearning.com or using the unsubscribe link on our home page www.turninglearningintoaction.com
We will not share any data where an individual can be identified
We may anonymise or aggregate data in such a way to ensure that you are not identifiable from it, and use this for statistical analysis of learning transfer trends
By using this Site, you acknowledge and agree to our terms of use and privacy policy.
Please review our full privacy policy below for further details.
The purpose of this policy is to tell you what information Vivat Learning PTY LTD, TAS Lever – Transfer of Learning (“Lever”) collects from you, how and when it may be collected and what happens to it. For the purpose of this policy, “we” and “us” refer to Lever.
Personal information is information from which an individual can be identified, either on its own or when combined with information already held or likely to be held by us. It is more commonly referred to as “personal data”.
Lever is a data controller and can be contacted using the contact details below.
This Notice only applies to personal information processed by or on behalf of Lever. Where our website contains links to other sites, those sites are responsible for any personal information you provide them. We recommend you check their privacy policies/fair processing notices if you are providing them with your personal information.
We may collect information from you when you visit our website, use our services, contact us by telephone or email or receive a communication from us relating to our services. Where our business clients provide us with the personal information of its staff or affiliated individuals, this Notice applies to the information you provide to us. It also applies to any personal information provided to us about a sole trader or partnership.
Contact us
If you have any queries you can contact Lever by emailing Emma Weber at emma@leverlearning.com. Our registered address is:
Vivat Learning PTY LTD, TAS Lever – Transfer of Learning
6/104 Soldiers Avenue
Freshwater
NSW
2096
Australia
If you have a specific question about this Polic or how we use your personal information, you should contact us at the above email address.
What information might Lever collect about me and how?
When you interact with Lever in the different ways described below, we may ask you or the business who is contacting us on your behalf for the following information:
-
personal and contact details (for example your name, role/title, employee number, division, location, manager, email address, telephone number, gender, emergency contact details);
-
personal and contact details that you give us when you sign up to any Lever product or service or when you interact with our website;
-
personal and contact details you give us when subscribing to receive marketing information from us (for example name, role and email address);
-
survey responses and case studies for program events (for example name, location, self-report and colleague/personal contact feedback information on behaviours and impact, business metrics, telephone conversations);
-
behavioural assessment responses of participants – this may be self-reported data and also responses from manager/peers and direct reports. These may contain sensitive personal information;
-
observation notes on individual capabilities
-
coaching which includes one to one sessions and group coaching sessions where personal information is shared and collected
-
information we collect via cookies or similar technology stored on your device about how you use Lever’s website;
-
your IP address;
-
information from Lever’s web servers about online activity;
-
information from social media activity (such as likes, shares and tweets) when you interact with us on social media;
-
information you provide if you report a problem with our website or service.
We will collect and process your personal information in accordance with this Notice.
If you make an enquiry via our website, on the telephone or via email, or via any third party, we will collect the information you provide to us, together with any information provided by that third party. We may monitor and record telephone and written correspondence with you to train our staff and monitor our services.
We also obtain information from other sources of data, including information about you from 3rd party organisations. We will only accept and use information about you from reputable organisations who have either obtained your permission to share your information with us or who have collated information about you from publicly available sources. Occasionally Lever might receive information about you from a trusted Lever partner organisation who will have sought your prior consent to share it with us.
How will Lever use my information?
We use the personal information we collect about you for various purposes. Data protection legislation sets out specific “lawful bases” for processing personal information. The table below sets out under which basis we process different information about you, and explains the purpose of that processing. It also sets out the specific rights you have in respect of that processing, which may depend on the basis we process it for.
|
Personal Information
|
Basis of Processing
|
Purposes of processing
|
-
name
-
role/title
-
location
-
manager
-
contact details
-
details of contact with us
-
self-report/third person information on behaviours and impact
-
business metrics
-
telephone conversations
- coaching records
|
- It is necessary for the performance of our services contract
|
-
To help us identify you.
-
To provide you with the services you have requested.
-
For logistics and providing learning materials
|
-
name
-
role
-
contact details
- survey responses
|
- processing is necessary for the purposes of the legitimate interests
|
-
To contact you regarding our services including market research and other surveys. The specific legitimate interest pursued is evaluation of our services and or data pertaining to learning transfer practises. We have conducted a balancing test in relation to this interest, and have determined that this is of legitimate interest.
-
To report on program impact. The specific legitimate interest pursued is quality of our services and furthering the field of learning transfer. We have conducted a balancing test in relation to this interest, and have determined that this is of legitimate interest.
|
-
name
-
role
-
contact details
-
details of contact with us
-
web usage statistics
- survey responses
|
- You have given us your consent.
|
-
To market to you by email or other electronic means, if you are an individual, sole trader or partnership.
-
To provide information requested to you.
-
To improve and enhance our website.
- For case studies.
|
As set out in the table above, we process some of your personal information on the basis that it is necessary for the performance of our services, or to be able to take steps for entering into our contract with you. The consequences of our failure to do so would be for Lever to discontinue providing our service. For example, if you request additional services but we cannot process the information needed to provide those services, we will not be able to continue to provide those services.
We protect your interests by making it easy for you to control the way in which we use your information. For more information, see the “Control of and access to your information” section below.
Transmission of information online is not 100% secure and we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk.
We may also obtain information about your computer, including where available your IP address, operating system and browser type in accordance with our Cookies Policy.
We may use any of your personal information in connection with any complaint made relating to our service to you, or in respect of reviewing any legal rights or obligations, either on the basis of performing our contract with you or in our legitimate interests to resolve any dispute.
International transfer
Your personal information will be sent outside the European Economic Area, as we store our data in Australia. Consequently, your personal information will be processed in what is one of the “third countries”. It is important to understand that “third countries” are not deemed by the European Commission to have adequate legal protections for personal information. We have implemented appropriate technical and organisational measures to protect your personal information, in the form of standard data protection clause. If you would like to obtain a copy of the standard data protection clauses, please contact us using the details above.
Sharing information
A percentage of our work is a collaboration with training consultancies. If your information has come to us through a third-party partner we may share your personal information with that third party for the purposes of shared services or business management and optimisation.
We may share your information:
-
to generate reports and analytics from the progress review responses provided that relate to you;
-
to provide you with information;
-
to generate surveys and behavioural assessments;
-
Attendance of sessions
-
Communication with participants
-
if we have been asked to provide information about you for legal or regulatory purposes.
Lever will not sell your information.
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal information, in order to comply with any legal regulations or good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of other persons with whom we have a business relationship, or to purchasers or prospective purchasers in relation to a disposal of our business or assets.
Finally, we may use third party service providers to support our provision of the service. This could include:
-
further coaching provider;
-
survey generator;
-
learning transfer bot services
or other, less direct, business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Portions of our services may be provided by organisations with which Lever has a contractual relationship, including subcontractors, and, accordingly, your personal information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.
We will have in place an agreement with our service providers which will restrict how they are able to process your personal information. We specifically ensure they are GDPR compliant. If you would like to see a copy of any relevant provisions, please contact
emma@leverlearning.com.
Sensitive Information
We may collect sensitive information if it is provided to us by you or on your behalf voluntarily. By giving us this information, you agree that we may use such information as set out in this Notice.
Data anonymisation and aggregation
We may anonymise or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymised or aggregated data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor products and services and to conduct risk assessment and analysis of costs and charges in relation to our products and services. We may share anonymised or aggregated data with third parties.
Control of and access to your information
You may withdraw your consent to receiving marketing at any time by emailing emma@leverlearning.com
You can also exercise your data privacy rights as follows:
|
Your right
|
What does it mean?
|
|
Right of access
|
Subject to certain conditions, you are entitled to have access to your personal information which we hold (this is more commonly known as submitting a “data subject access request”).
|
|
Right of data portability
|
Subject to certain conditions, you are entitled to receive the personal information which you have provided to us and which is used by us by automated means, in a commonly-used machine readable format.
|
|
Rights in relation to inaccurate personal or incomplete data
|
You may challenge the accuracy or completeness of personal information which we use about you. If it is found that personal information is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
If you believe any personal information we have about you is incorrect, please contact us at emma@leverlearning.com
|
|
Right to object to or restrict our use of your personal information
|
Subject to certain conditions, you have the right to object to or ask us to restrict the use of your personal information.
|
|
Right to have personal information erased
|
Where we are using your personal information with your consent (and subject to certain conditions), you are entitled to have your personal information erased (also known as the “right to be forgotten”), e.g. where you think that the information we are using is inaccurate, or the use is unlawful.
|
|
Right to withdrawal
|
You have the right to withdraw your consent to any use for which you have previously given that consent.
|
Please contact us if you would like to exercise any of these rights or if you have any concern about how your personal information is processed at
emma@leverlearning.com and we will try to resolve your concerns. However, if you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the Information Commissioner’s Office (
https://ico.org.uk/global/contact-us/). You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation (the “GDPR”).
Marketing preferences
Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant.
We will ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.
Retention
We will retain your personal information whilst you are an active participant as needed bench marking and statistical analysis.
In certain circumstances, we may be required to retain your personal information for longer, where such retention is required by law or record keeping requirements, including managing our relationship with you, defending any claims, or for tax purposes.
Changes to this Policy
We may change this Policy from time to time in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the Notice accordingly. We encourage you to check this Notice online for changes.
