Privacy Policy

Data Protection Policy

1. Our Use(s) Of Personal Data and our Purpose(s)

We may collect, hold and/or process the following personal data:

Personal data category

Purpose of data collection, storage or processing

Organisational Information. For example, organisation charts.

In order that we can understand the organisational context to be able to fulfil our contract with a client.

Contact information. For example, email addresses, postal addresses, telephone numbers.

In order that we can contact individuals to fulfil our contract with a client.

Descriptions of Mentors. For example, their name, role in the business and the current opportunities and challenges they are facing.

In order that we can effectively match Mentes with a suitable Mentor to fulfil our contract with a client.

Personal data captured during mentoring sessions (mentoring notes).

In order that the Mentor can deliver effective mentoring to a high standard by referring to notes from previous sessions. To fulfil our contract with a client.

2. Our specific data protection measures

In relation to our use of personal data we take the following measures:

Encryption

We require our employees and Mentors to enable encryption on their smartphones and where appropriate, on laptop and desktop drives.

2. Erasure, destruction and or deletion

We delete or destroy personal data within 6 months of the completion of a contract with a client.
In relation to hard copy notebooks or paper, these are destroyed using a shredder. Electronic files are deleted manually and removed from back-up systems.

3. Transmission via email

The Mentor Hub uses a well-known email service provider whose service includes email security to protect against malware, ransoming and phishing.
We encourage our employees and Mentors to check email addresses before sending emails in order to minimise incidents of emails being received by unintended recipients.

4. Transmission of hard copies

Hard copies are sent by secure mail and where appropriate, tracked or signed for postal services are used to protect personal data.

5. Storage of emails and email content

The Mentor Hub’s email service provider provides safe storage of emails.

6. Access of employees

Sue O’Brien OBE (Executive Chair of The Mentor Hub) controls the access that employees and Mentors have to client data (including personal data). Individuals are not given access to client data unless they are specifically working on a contract for the client in question. To receive access, Sue O’Brien OBE must actively assign an employee or associate to a particular file on our system.

7. Access of third parties

Sue O’Brien OBE (Executive Chair of The Mentor Hub) controls the access that third parties (e.g., our IT support desk) have to client data (including personal data).

8. Storage of hardcopies

Hard copy documents and notes such as mentoring notes are stored in locked filing cabinets.

9. Storage of electronic copies

Electronic documents and files are stored on a cloud-based file hosting service which has AES 256-bit encryption for data at rest and AES 128-bit encryption for data in transit. Access to the file hosting service is protected by a two-step verification process and secure passwords.

10. Sub-processing

Where sub-processing is necessary, we ensure that suppliers or third parties have appropriate data protection policies and processes in place. For the avoidance of doubt, we only sub-process personal data where necessary and in line with the policy outlined in this document.

11. Viewing on devices

We train our employees and Mentors to be aware of their environment and potential risks when viewing personal data on devices in public spaces.

12. Passwords

The Mentor Hub requires that all employees and Mentors update passwords for laptops and phones every three months. In addition, we require that passwords for The Mentor Hub email accounts and other shared applications are also updated every three months. Passwords must meet criteria to ensure they are not obvious.

Section A: Overview

The reason for this policy

You have legal rights regarding the way your personal data is handled.
In the course of our business activities, we collect, store and process personal data about our customers, suppliers and other third parties and therefore, in order to comply with the law and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this data.
All people working in or with our business are obliged to comply with this policy when processing personal data.

Introduction

This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, for example, customers and business contacts, or that is provided to us by data subjects or other sources.
In this policy when we say “you’ or “your” we are generally referring to the data subjects unless the context requires otherwise.
It also sets out our obligations in relation to data protection under the General Data Protection Regulation 2016 (“the GDPR Rules”).
This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer, and store personal data.
We agree to ensure that all our directors, managers, employees, mentors, and agents comply with this policy.
We aim to ensure the correct, lawful, and fair handling of your personal data and to respect your legal rights.

The meaning of key Data Protection terms

data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address, or date of birth) or it can be an opinion about that person, their actions and behaviour.
data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our business for our own commercial purposes.
processing is any activity that involves the use of personal data. It includes obtaining, recording, or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring personal data to third parties.

Summary of the Data Protection Principles

This Policy aims to ensure compliance with the GDPR Rules. The GDPR Rules set out the following principles with which any party handling personal data must comply. All personal data must be:

Processed fairly and lawfully – and it must be processed - in relation to you as the data subject - in a transparent manner
Processed for limited purposes and in an appropriate way – the purposes for which it is collected must be explicit, specified, and legitimate
Adequate, relevant, and not excessive for the purpose
Accurate – as well as being accurate it must be kept up to date with inaccurate data deleted
Not kept longer than necessary for the purpose
Processed in line with data subject's rights
Held securely – there must be appropriate technical or organisational measures to ensure appropriate security.

In addition, personal data must not be transferred outside the European Economic Area (the “EEA”) without adequate protection.

Section B: Data Protection Principles

Notifying Data Subjects

As part of complying with the principles in paragraph 4 above, if you provide us with personal data, we will always try to tell you:
the purpose or purposes for which we intend to process that personal data
the types of third parties, if any, with which we will share or to which we will disclose that personal data
how you can limit our use and disclosure of the personal data
if we receive personal data from other sources.

2. Lawful, Fair, and Transparent Data Processing

The GDPR Rules are not intended to prevent the processing of personal data but to ensure that it is done fairly and without adversely affecting the rights of data subjects. The processing of personal data is lawful if one (or more) of the following applies:

(consent) the data subject has consented for a specific purpose;
(contract) if the data subject requests the processing with a view to entering into a contract or the processing is necessary for the performance of a contract;
(legal obligation) if the processing is necessary for the compliance with a legal obligation to which the data controller is subject;
(protection) processing is necessary to protect your vital interests or those of another natural person;
(public interest) it is in the public interest for a task to be carried out which requires such processing, or the task is to be carried out as a result of the exercise of any official authority held by the data controller; and, or
(legitimate interests) for the legitimate interest of the data controller or the party to whom the personal data is disclosed.

3. Processed for limited purposes and in an appropriate way

In the course of our business, we may collect and process the personal data set out above. This may include personal data we receive directly from you (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
We will only process personal data for the specific purposes set out above or for any other purposes specifically permitted by the GDPR Rules. We will notify those purposes to you when we first collect the personal data or as soon as possible thereafter.

4. Adequate, Relevant, and not excessive for the purpose

We will only collect and process personal data for the specific purpose(s) set out above.

5. Accuracy of Data and Keeping Data Up To Date

We will keep your personal data accurate and up to date. We will check its accuracy regularly. When we find inaccurate or out of date data, we will take reasonable steps to amend or erase that data.

6. Timely Processing

We will only keep your personal data for a period of time which we judge is relevant and necessary, taking into account the purpose(s) of collecting the personal data which are specified above.

7. Processing that is secure

In addition to the measures above:

we will make sure that the personal data we collect is kept securely and that it is not subject to unauthorised processing. We will also act to prevent the loss, destruction, or damage of personal data.
we will ensure that only people who are authorised to use personal data can access it and that we have measures in place to prevent unauthorised access including:
1. entry controls to our premises and systems;
2. lockable desks and cupboards for confidential personal data; and
3. destruction of hard copy documents and digital storage devices that are no longer required.
  1. all authorised persons must ensure that personal data is not inadvertently made visible to passers-by, for example, by logging off from unattended devices and being aware of device use in public spaces.

Section C: Data Subject Rights

You, as a data subject, have the right to information about:
1. who we are;
2. the purpose(s) of collecting your personal data and the legal basis for collecting it and what our legitimate interest is for processing your personal data;
3. the categories of personal data collected and where is to be transferred, especially if outside the EEA;
4. the length of time we hold personal data (or, where there is no predetermined period, details of how that length of time will be determined); and
5. your rights as a data subject including your right to withdraw your consent to processing, the right to complain to the Information Commissioner and also things such as details of any legal requirement for processing personal data that may exist and any automated decision-making that we carry out.

We will try to provide this information when we collect the personal data or, if we collect the personal data from another party, when we communicate with you after the personal data is received.

2. Data Subject Access

You may request access to any data held about you by us (a subject access request (“SAR”)
We reserve the right to charge reasonable fees for onerous or repetitive requests.
Data subjects must make a formal request for information we hold about them. This must be made in writing.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
1. we will check the caller's identity to make sure that information is only given to a person who is entitled to it; and
2. we will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.

3. Accuracy of personal data: right to rectification

We will do our best to ensure that all personal data held about you is accurate and complete. We ask that you notify us of any changes to information held about you.
You have the right to request that any incomplete or inaccurate information held about you is rectified and to lodge a complaint with us and the Information Commissioner's Office.
We will respond to requests to rectify this within one month.

4. Right to be forgotten

You have the right to request the deletion or removal of personal data, however requests for erasure can be rejected in certain circumstances.

5. Right to restriction of Processing

You can block the processing of your personal data. This means we may be able to store it but cannot process it further without consent. Restricting data is required where the accuracy of data is challenged - but only until the accuracy has been verified.

6. Right to data portability

If you have provided personal data to us, you have the right to transfer it from us to someone else.
If you request it, and where feasible, we may be required to transmit the data directly to another organisation. We must respond without undue delay and within one month, or two months if the request is complex.

7. The right to object

You have a right to object to the processing of your data. On receipt of your objections, we must stop processing unless we can demonstrate legal grounds for the processing.

8. Automated decision-making

You have the right not to be subject to a decision based on automated processing if such a decision produces a legal effect or other significant effect on you.
You can request human intervention where personal data is processed using automated decision-making and can ask for an explanation of the decision to use automated decision-making.

9. Profiling

If we use your personal data for profiling purposes:

we will give you information fully explaining the profiling that will be carried out, including its importance and the likely results of that profiling;
we will make sure that appropriate mathematical or statistical procedures are used;
we will implement required technical and organisational measures to minimise the risk of mistakes and to enable such mistakes to be easily corrected; and
we will make sure that all personal data processed by us for profiling purposes is kept secure so as to avoid discriminatory effects resulting from such profiling.

Section D: Our Other Obligations

1. How we deal with personal data internally

We will:
1. train our employees and Mentors in relation to our responsibilities under the GDPR Rules;
2. ensure that only appropriately trained, supervised, and authorised personnel have access to personal data held by us; and
3. regularly evaluate and review our collection and processing of personal data and the performance of employees, Mentors and third parties working on our behalf to ensure that data processing is in accordance with the GDPR Rules.
4. We will keep internal records of personal data that we collect and process including, in relation to that personal data, details of the categories, any transfers, our security measures, our purpose of collection and the duration of retention of that personal data. We will also retain details of all third parties that either collect your personal data for us or that we use to process your personal data.
5. We will carry out privacy impact assessments as required by law.

2. Transferring personal data to a country outside the EEA

We may transfer personal data to countries outside of the EEA, however we will ensure that the transfer is:

to a place that the EU has judged to provide adequate levels of protection for personal data;
to a place that provides adequate safeguards under either an agreement with a public body, rules that bind companies or standard data protection clauses adopted by the EU or some other form of approved code of conduct approved by a supervisory authority or certification or other contractual clauses or regulatory provisions;
necessary for the performance of a contract between you and us or with a view to creating that contract;
made with your consent;
necessary for important public interest reasons, legal claims, to protect your vital interests.

3. Notification of personal data security breach

If a personal data security breach occurs, we will manage and respond to it effectively in accordance with GDPR. We will immediately report any breach to our Data Protection Officer.
We will notify the Information Commissioners Office (ICO) and any data subject of personal data security breaches to the extent we are required to do so by GDPR.
If disclosure is not required by GDPR, we will nevertheless investigate closely all the circumstances surrounding the breach and examine the seriousness of the breach and the benefits that might be obtained by disclosure (such as limiting risks of fraud) and we will give careful consideration to any decision to notify the ICO or you, especially if your rights and freedoms as data subjects are affected.

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