All material used in training, coaching and consultancy sessions remains the sole intellectual property of The Active Bystander Training Company Ltd. Any reproduction or publication without appropriate attribution is strictly prohibited unless accompanied by our express written authority.
All training, coaching and consultancy sessions are carried out in good faith and the content of all one-to-one coaching sessions is confidential. The Active Bystander Training Company Ltd agrees to treat all clients with due discretion apart from where a legal duty of disclosure arises.
Travel and accommodation costs are charged for bookings which require a return journey of more than 4 hours. Business Class tickets are required for flights of more than 4 hours in duration.
CANCELLATION POLICY
Bookings cancelled within 5 working days of the due start date will incur the full fee unless otherwise agreed in advance.
PRIVACY POLICY
THE KIND OF INFORMATION WE HOLD ABOUT INDIVIDUALS OTHER THAN CLIENTS AND HOW THIS DATA IS USED
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
During the course of our day to day basis we acquire information regarding individuals other than our clients and we will retain this data where we have a legitimate business reason to do so.
Typically we acquire personal data on individuals other than clients in the following circumstances:
We have a legitimate business interest in retaining this data on the basis that we must retain some personal data on third parties and suppliers in the ordinary course of business.
We may also use this data to send informative blogs, event details or other updates relating to our services or something that we believe relates to your interests. We have a legitimate interest in retaining your data for this purpose however you have the right to ask us to erase or rectify your data and you have the right to opt out of receiving marketing, networking information or information we think might be of interest to you.
Why might we share your personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
“Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”
DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Details of these measures may be obtained directly from Scott Solder – scott@activebystander.co.uk
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where We are legally required to do so.
The transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with us by email then you assume the risks of such communications being intercepted, not received or delivered or are received by individuals other than the intended recipient.
DATA RETENTION
How long will we use your information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
In respect of Client data we will typically hold data relating to your instructions for a period of 7 years after completion of the last training or coaching interaction. The reason for this is that the Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to 6 years after the events. We therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.
Given the nature of our services clients often return to us with repeat instructions within weeks, months or years of contacting us in the first instance. The 7 year period referred to above will start from the last contact we had with the client or business to ensure we are able to assist as and when we need to. Should you not contact us for 7 years, we will confidentially destroy all data held for you.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us by email – scott@activebystander.co.uk
Please note that where you ask us to erase, correct, object to process or seek to restrict our processing of data we may refuse your request where we have a legal obligation, contractual or other legitimate business interest to refuse your request. If we refuse your request then we will notify you of this refusal and you will have the right to appeal.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact scott@activebystander.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
DATA PROTECTION MANAGER
Scott Solder is appointed as a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact scott@activebystander.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
CONTACT AND FURTHER INFORMATION
If you have any questions about this privacy notice, or wish to submit a complaint then please email scott@activebystander.co.uk.
You have the right to make a complaint to the Information Commissioners Office or such other regulatory body or supervisory authority as may be appointed from time to time.
If you make a complaint then we will respond to let you know how your complaint will be handled.