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How we collect and protect your personal data.

Adaptive Intelligence Consulting Limited Privacy Policy

 

Who are we?

Adaptive Intelligence Consulting Limited, hereafter “AIC” is a company incorporated within the UK solely owned by Dr Gary Russell Coulton. AIC operates globally as a management consultancy and provider of executive coaching and group facilitation.

 

Our Data policy principle

We obtain, hold and process your personal data with the sole intent to provide our customers, clients and partners with the most appropriate, products, services and information.

 

What personal information do we hold?

AIC holds names, e-mails, addresses and some other types of social media identifiers (e.g. Twitter names tec.). We very rarely and usually temporarily hold financial or personal details of a more sensitive nature.

 

How did we get your information?

AIC will have gained your information in several ways:

 

  1. You supplied data via our website.

  2. By exchange of business card.

  3. Included in exchange of e-mails or other digital means of communication.

  4. Verbally either in person or by telephone

  5. By one of these methods but by a third person as a means of introduction.

  6. In exchange for a free product (e.g. white paper or e-book).

  7. As part of a registration process to attend an event.

  8. As part of a subscription process.

  9. As part of a commercial contract.

  10. As a statutory requirement by law.

 

Should we obtain your details arising from a third-party introduction we will inform you within a minimum of one month and explain the legal basis of retaining that information. If at that time you do not want AIC to retain your data it will be removed from our databases.

 

Why do we hold your information?

When we originally obtained your information, it was part of a mutually beneficial interchange of business information, experience or insight. We hold your information in order to continue this relationship. Whenever, you feel this relationship no longer adds value we will happily remove your information from our database.

 

What do we do with your information?

AIC may use your information in several ways:

 

  1. To maintain an ongoing business relationship – e.g as a collaborator, client, customer, networker.

  2. For AIC to introduce you to people and organisations that we feel will have a high likelihood of adding value to you and/or your company.

  3. To introduce you to new opportunities we feel would be of specific interest to you based on our historical relationship.

  4. Maintain and update systems to protect your data – training, physical and processes.

  5. Employing password-protected computers, GDPR-compliant third-party providers of cloud back-up servers, contact databases, accounting packages (etc. as become required to support the business activities of AIC).

  6. We will maintain records of all data management activities.

  7. Maintain valid and sufficient cyberinsurance to cover most challenges to the integrity of personal data held by AIC.

  8. We have policies and procedures in place to report and recover from data breaches.

  9. We will sign up to and abide by relevant codes and certifications as AIC becomes aware of them.

 

What we do DON’T do with your information.

AIC will protect your information:

 

  1. AIC will not sell your information to any third party without your prior written consent.

  2. AIC will not give your personal information to a third party without your written or verbal consent. The exception will be if we have already established an understanding that you wish AIC to act as a formal or informal business network introducer on your behalf.

 

Lawful basis for holding and processing your personal data.

Consent

We believe that consent means offering you real choice and control of your personal information. We believe you should be in charge of your information. If we build trust and engagement and give you relevant high value you will give and continue to give your consent to hold sufficient of your information to maintain our mutually beneficial relationship.

 

When we seek consent, we will do so in as specific manner as possible. This will ensure that people are not contacted inappropriately.

 

We will keep evidence of your consent – date, method and how we obtained it.

 

We will review consent annually or when a new consent is required. If required we will contact people directly with specific invitations to opt-in and modify our data records accordingly.

 

During consent reviews we will contact people whose data we hold twice. The first time will be to re-establish contact informing them that we hold their data, how it was obtained and why we would like to retain it. This will be followed up one month later with a reminder. If after that time we have had no reply, we will assume they no longer wish us to retain their data and they will be removed from our records.

Contract

In this instance holding and processing of your data is a requirement for the performance of a contract (written or verbal) to which the data is a party or in order to take steps at the request of the data subject prior to entering into a contract.

 

AIC believes it will have a lawful basis for processing if:

  • AIC have a contract with the individual and we need to process their personal data to comply with our obligations under the contract.

  • AIC haven’t yet got a contract with the individual, but we have been asked to do something as a first step (eg provide a quote) and we need to process personal data to do what is requested.

Specific management of personal data at the end of the contract will be included in the wording of the contract.

 

Legitimate Interest

There are three elements to our legitimate interests basis:

 

  • We determine if there is a legitimate interest.

  • We show that the data processing is necessary to achieve this legitimate interest.

  • We balance legitimate interest against an individual’s interests, rights and freedoms.

We will always balance AIC’s interests against an individual’s (whose data we hold) - would they reasonably expect the processing, or if it would cause unjustified harm to them, their interests are likely to override AIC’s legitimate interests.

AIC’s legitimate interests

AIC is active in management consulting including, executive coaching, business coaching, training, facilitation, organisational cultural development (under the brand AdaptiveIG), executive education, peer-to-peer boardrooms (under the brand The Alpha Group).

We would obtain and retain personal data relating to specific services and products within these broad fields of activity.

 

How we put you in control of your data

Our business is based on creating and maintaining strong mutually beneficial relationships.

We put you in control of the data we hold in several ways:

 

  1. In the way we obtain your data (consent or legitimate interest).

  2. Inform you periodically (minimum annually) that we hold your data, the specific nature of this data, the basis on which we hold it and a means for you to renew your consent.

  3. Annually we review our Privacy Policy and inform all people whose data we hold of any alterations.

 

Right of access to your data

At any time, you have right of free access to the personal data we hold for you. AIC will respond within one month of receipt of the request. No charge will be made for this information.

This should be submitted in writing with an assurance that the actual person whose data we hold makes the request. This may include a request of some form of confirmation of identity or for us to separately approach that individual via another communication channel we hold.

AIC will respond within one month of receipt of the request. No charge will be made for this request.

All data access requests whether written or verbal, will be recorded.

 

Right of rectification

You have the right to alter, amend or extend the nature of the information we hold on your behalf.

This should be submitted in writing with an assurance that the actual person whose data we hold makes the request. This may include a request of some form of confirmation of identity or for us to separately approach that individual via another communication channel we hold.

AIC will respond within one month of receipt of the request. No charge will be made for this request.

All rectification requests whether written or verbal, will be recorded.

 

Right to data erasure

This should be submitted in writing with an assurance that the actual person whose data we hold makes the request. This may include a request of some form of confirmation of identity or for us to separately approach that individual via another communication channel we hold.

AIC will respond within one month of receipt of the request. No charge will be made for this request.

All data erasure requests whether written or verbal, will be recorded.

 

Right to restrict or suppress processing of personal data

This should be submitted in writing with an assurance that the actual person whose data we hold makes the request. This may include a request of some form of confirmation of identity or for us to separately approach that individual via another communication channel we hold.

AIC will respond within one month of receipt of the request. No charge will be made for this request.

All data restriction/suppression requests whether written or verbal, will be recorded.

 

The right to data portability

Individuals whose data AIC holds have the right to request the data we hold. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.

Requests should be submitted in writing with an assurance that the actual person whose data we hold makes the request. This may include a request of some form of confirmation of identity or for us to separately approach that individual via another communication channel we hold.

AIC will respond within one month of receipt of the request. No charge will be made for this request.

All data portability requests whether written or verbal, will be recorded.

 

Your right to object

Under GDPR individuals have in certain circumstances an absolute right to object to the processing of their data.

Requests should be submitted in writing with an assurance that the actual person whose data we hold makes the request. This may include a request of some form of confirmation of identity or for us to separately approach that individual via another communication channel we hold.

AIC will respond within one month of receipt of the request. No charge will be made for this request.

All data portability requests whether written or verbal, will be recorded.

 

Data Controller

Dr Gary R Coulton

CEO Adaptive Intelligence Consulting Limited

Company number - 8598217

 

This privacy policy will be reviewed annually or as statutory regulations require.