OPDC Ltd Privacy Policy

OPDC Ltd is part of a group which includes OPDC Service Ltd. This privacy policy will explain how our organisation uses the personal data we collect from you as a client or as a participant on an event facilitated or delivered by us.

Topics:

1. GDPR compliance
2. Our lawful basis for processing data
3. What data do we collect?
4. How do we collect your data?
5. How will we use your data?
6. How do we store your data?
7. Marketing
8. What are your data protection rights?
9. What are cookies?
10. How do we use cookies?
11. What types of cookies do we use?
12. How to manage your cookies
13. Privacy policies of other websites
14. Changes to our privacy policy
15. How to contact us
16. How to contact the appropriate authorities

1. GDPR (General Data Protection Regulation)

GDPR came into force on 25th May 2018. It aims to ensure all organisations that collect or process personal data, protect the personal data of EU citizens.

OPDC Ltd has taken the following steps to demonstrate our commitment to Compliance. We have:

• Completed a gap analysis process and implemented key activities.
• Strengthened organisational and technical security measures.
• Obtained Statements of Commitment to Compliance from third party suppliers.

2. What is OPDC Ltd’s lawful basis for processing data?

Legitimate interest:

• In holding client contact data for the processing of contracts
• In holding participant data supplied by their employers to enable full participation of participants in particular programmes
• To provide you with appropriate pre-programme, inter-module and post-module information or activities
• To process 360° and other questionnaires in order that you have the information available to use on a programme
• In programmes which have a Graduation, to validate your completion of the required activities
• Where appropriate to verify to employers that a participant has taken part in, or completed, a particular programme.

3. What data do we collect?

OPDC Ltd collects the following data:

• Personal identification information which may include salutation, name, business/company name, job title, profession, contact information such as email addresses and telephone numbers, the name and contact details of managers and others in your business who may have nominated you
• Data you send to us on questionnaires
• When you complete questionnaires using the software or platforms of one of our third party providers we notify you before completion of the identity of the third party provider. After you have completed a questionnaire we receive and process your personal report and make this available to you as a hardcopy workbook on a subsequent module.
• Data you send us with pre-programme and intermodule tasks or a record of completion of programme activities

4. How do we collect your data?

• We will ask your employer to email us your contact details when they nominate you for a programme, event, coaching or other activity
• When we email you OPDC questionnaires, we will receive the completed questionnaires by email from you. On these we ask you to provide your initials rather than your full name.
• When we email you a link to a questionnaire run on 3rd party platform, you will enter your details on their website, we will obtain a copy of the processed results which our consultant(s) will provide to you in hardcopy form for your use on the particular programme.
• When programmes have a series of tasks for you to complete, you email us either the outcome of the task or confirmation that the task has been completed.
• When you voluntarily complete a participant or client survey or provide feedback on any of our message boards or via email.

5. How will we use your data?

• For the purposes of the particular programme in which you are a delegate
• We will retain a record of your name, role, location and email address a) to enable future validation that you have taken part in a particular programme b) where Alumni groups are run within a particular organisation: to validate that you have taken part in a particular programme.

6. Who will it be shared with?

• Your contact details will be shared with the consultant(s) who run your programme and with those on the administration team at OPDC Ltd who manage the completion of your pre-programme, inter-module and post-module activities, including those who print materials for programmes.
• All those involved have signed non-disclosure agreements with OPDC Ltd.
• In programmes which have a Graduation, we will inform your employer that you have or have not completed the required activities.

7. How do we store your data?

• Emails to and from you are accessible only through our password protected email accounts
• OPDC Ltd securely stores your data at our offices on password protected desktop and laptop computers which have hard discs encrypted using GDPR compliant software for malware/virus protection and encryption enforcement and monitoring.
• OPDC Ltd questionnaires are password protected when they are sent by us to you or by you to us. They are unlocked by our administrative team and our programme consultant(s) for processing
• Our administrative team and programme consultants use GDPR compliant password software to store and access data.
• In the case of 3rd party questionnaires only you hold the personal password or access code
• We delete all questionnaires and evidence of your completion of tasks during a programme 6 months after a programme
• We will retain a record of your name, role, location and email address a) to enable future validation that you have taken part in a particular programme b) where Alumni groups are run within a particular organisation: to validate that you have taken part in a particular programme.
• In the event of loss or theft of data during a programme or in the 6 months after a programme, we will inform you within 72 hours of the breach of data, and also the local authority and ICO.
• In the event of such a breach: Dr David Kearney, our GDPR Representative, is responsible for alerting all administrative staff and consultants, the local authority and ICO.
• Our back-up plan and protocol will enable retrieval of your data to enable your continued participation on a programme.

8. Marketing

OPDC Ltd would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies in the OPDC Ltd Group:

• OPDC Services Ltd

You have the right at any time to stop OPDC Ltd from contacting you for marketing purposes or giving your data to other members of the OPDC Ltd Group.

9. What are your data protection rights?

OPDC Ltd would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to be informed – Anyone processing your personal data must make clear what they are processing, why and who else the data may be passed to.

The right to access – You have the right to request OPDC Ltd for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that OPDC Ltd correct any information you believe is inaccurate. You also have the right to request OPDC Ltd to complete information you believe is incomplete

The right to erasure – You have the right to request that OPDC Ltd erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that OPDC Ltd restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to OPDC Ltd’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that OPDC Ltd transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Rights in relation to automated decision making and profiling – You have the right not be subject to a decision based soley on automated processing.

Data Protection Officer:  The small scale of our business does not require a Data Protection Officer.  In the case of a client organisation or individual participant who may have concerns, questions about their individual rights or other matters, or a complaint about our use of their data, or wish to see data we hold, they may contact:

Dr David Kearney, Director: who is the Representative for the company for all matters related to GDPR.

Email: davidkearney@opdc.co.uk

10. What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

• For further information, visit allaboutcookies.org.

How do we use cookies?

• We do not use cookies on your website

What types of cookies do we use?

• None

How to manage cookies

• Not applicable

11. Privacy policies of other websites

Where OPDC Ltd website contains links to other websites, our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

12. Changes to our privacy policy

OPDC Ltd keeps its privacy policy under regular review and places any updates on our web page. This privacy policy was last updated on 17 September 2019.

13. How to contact us

If you have any questions about OPDC Ltd’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Dr David Kearney, Director: who is the Representative for the company for all matters related to GDPR.

Email: davidkearney@opdc.co.uk

14. How to contact the appropriate authority

Should you wish to report a complaint or if you feel that OPDC Ltd has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Web: https://ico.org.uk/make-a-complaint

Tel: UK 0303 123 111