1. Who we are
We are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner. We are a “data controller” for the purposes of the United Kingdom General Data Protection Regulation (UK GDPR) which means that we are responsible for, and control the processing of, your personal information.
2. How we collect information about you
We will collect personal information from you when you:
- apply to be involved in a programme, service or event (such as a programme participant on a session or at an event );
- apply to support our work (such as becoming a Consultant or mentor to our programme participants);
- join our community;
- apply for a role with us or request to be added to our recruitment database;
- make a donation to us; or
- provide such information when you make an inquiry or otherwise interact with us (such as through the Contact Us function on our website).
We also collect personal information about you from:
- MeWe Foundation (Company number 08332290) our delivery partner
- KO Management Ltd, (Company number 13572353) our marketing communications partner.
- third parties with whom you interact in connection with our programmes, services, events and/or community (e.g. when you provide a donation through a third party networking event, or one of the other third parties with which we may work with);
- third party business lead and professional data enhancement organisations, including Hunter Web Services Inc. and Lusha Ltd; and
- publicly available sources, including LinkedIn, Twitter, Facebook and other social media platforms and public-facing websites.
3. Information we collect and why we use it
We may collect the following personal information about you:
- full name;
- date of birth;
- email address;
- postal address (including postcode);
- telephone number;
- LinkedIn profile
- diversity data including ethnicity, country of origin, gender identity, socioeconomic status, sexuality and details of any disabilities;
- salary or any other numeric indicators relating to remuneration reward
- educational or professional qualifications including school and/or university accreditation;
- information provided in communications between us and you.
We will use this information for the purposes and pursuant to the lawful basis set out in the table below:
|Purpose of processing
|Assess your suitability for a programme, service, event or support role as a consultant
|Necessary for our legitimate interest of ensuring that our programmes, services, events and supporters align with our mission to promote diversity within the sectors we operate
|Provide, and manage your participation in a programme, service, event and/or community
|Necessary for our legitimate interest of providing our programmes, services, events and communities which promote diversity within the sectors where we operate, including for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards
|Add you to our recruitment database and either propose consulting opportunities (as applicable) that may be of interest to you
|Necessary for our legitimate interest of providing diverse candidates for consulting opportunities including proposing candidates that may be of interest to you
|Update you with important administrative messages about your relationship with us, by attending an event, or consulting services you have requested
|Necessary for our legitimate interest of organising and managing programmes, services and events to further our mission to promote diversity and racial equity within the sector
|Keep an ongoing and updated record of your relationship with us, such as consulting with us, and to administer the consulting agreement
|Necessary for our legitimate interest of ensuring that our programmes, services, events and supporters align with our mission to promote diversity and racial equity within the sector
|Find candidate organisations that are suitable for our programme, service, event and/or community
|Necessary for our legitimate interest of generating interest in and finding suitable candidate organisations for our programmes, services, events and communities which promote and support diversity and racial equity within the sector
|Cleanse, verify and supplement the personal information that we hold about you
|Necessary for our legitimate interest of being able to contact potential suitable candidate organisations for our programmes, services, events and communities and ensuring that the personal information that we hold about them is accurate and up to date
|Contact you by email, post or phone call (depending on your contact preferences)
|Necessary for our legitimate interest of promoting our programmes, services, events and communities
|Record, consider and respond to any enquiries that you raise with us
|Necessary for our legitimate interest of considering and responding to your enquiries and maintaining an audit record of them
|Dealing with legal disputes or other legal claims involving you or other individuals
|Necessary when dealing with legal disputes or other legal claims involving you or other data subjects
|Conducting data analytics studies to review and better understand diversity and racial equity and to analyse the performance of different marketing channels, including the anonymisation of personal data
|Necessary for our legitimate interest of providing our programmes, services, events and communities which promote diversity and racial equity within the sector
|Obtaining professional advice
|Necessary for our legitimate interests of obtaining legal and other professional advice in connection with our organisation(s)
|Complying with our regulatory requirements
|Necessary for our legitimate interests of complying with laws and regulatory requirements
|Sharing with our Funder and Investment partners
|Necessary for our legitimate interests of furthering our mission to promote diversity within the sector by sharing aggregated and anonymised data with our partners.
|Corporate transactions and restructuring
|Necessary for our legitimate interests of enabling: (i) the reorganisation financing, investment or other transaction involving us; (ii) relevant parties to undertake due diligence in relation to a potential transaction involving us; (iii) obtaining professional advice; and (iv) forecasting, business planning and dealing with legal claims
If you do not provide this information, we will not be able to sign you up for a particular service such as an event, a programme, an educational session or provide services that you have requested, such as a consultancy service.
We may also use your personal information to make initial contact to you about our ongoing work and how you can support Create Equity.
If you make a donation to us, we will collect your full name, email address, postal address (including postcode), donation amount and card details for the purpose of processing your donation. Our lawful basis for such processing is necessary for our legitimate interests of collecting donations to fulfil our mission to promote diversity and racial equity within the sector.
4. Profiling: making our services unique to you
We want to improve how we communicate with you and the information we provide through our website and services. To do this we sometimes use profiling and screening methods so that we can better understand your preferences and we do so to provide a better experience for you when communicating with us.
We may carry out targeted activities using manual profiling techniques to identify particular demographics to promote based on the information that we hold about you.
This information can be appended to the information that you have provided, which allows us to use our services more effectively.
You can of course opt out of this activity at any time. To do this, email us at firstname.lastname@example.org
We will only contact you about our activities and how you can support or get involved in helping us achieve our mission by phone, email or text message if you have agreed for us to contact you in this way.
You can update your preferences or to stop us sending you these communications at any time by contacting us directly by emailing email@example.com or by clicking on the unsubscribe link in the relevant communication.
6. Sharing your information
The personal information we collect about you will be used by our employees so that they can support you.
Third party providers
In addition, where necessary as part of our business, your personal information will be shared with:
- our professional legal, accountancy and other advisors and auditors in order to obtain legal, accountancy and other professional advice; and
- our IT service providers to which we have outsourced those elements of our business.
Some of our third party providers will transfer your personal information to countries that are not automatically deemed to provide an adequate level of protection for personal information. In such circumstances, we have received commitments from our third party providers that they have in place appropriate safeguards to protect your personal information in accordance with applicable data protection laws. You can request further details of the appropriate safeguards applicable to transfers of your personal information by emailing us at firstname.lastname@example.org
Sale or transfer of organisation or assets
In the event that we sell or transfer (for example in outsourcing or reorganisation) any part(s) of our organisation and/or assets, we will also disclose your personal information to actual or potential purchasers or transferees of parts of the business or assets, and their respective advisers and insurers for the potential purchaser’s or transferee’s legitimate interests of:
- undertaking due diligence on, and valuing, the business and/or assets;
- transferring the personal information in connection with any relevant sale and the transfer of our contractual rights and/or obligations; and
- the use of such personal information by a purchaser or transferee for the operation of its organisation/business.
We will disclose your information if required to do so by law (for example, to comply with applicable laws), regulations and codes of practice or in response to a valid request from a law enforcement agency, regulatory body or competent authority.
7. Keeping your information safe
We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately, the transmission of information using the internet is not completely secure and we cannot guarantee the security of data during transmission to our site.
Our websites may contain links to other sites. We are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or websites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites.
8. How long we hold your information for
Given the long-term nature of our relationship with you and our intention to support and engage with you throughout the duration of your business career, we will hold your personal data for as long as you maintain your relationship with us, whether by being registered on our consultant database, attending our events or receiving our email updates about current and future programmes.
9. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting us directly at email@example.com.
You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office: https://ico.org.uk
- Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you.
- Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest to process that personal information. If we are unable to demonstrate our legitimate interests for that processing, we will no longer process your personal information for those purposes. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Consent: If you have given us your consent to use personal information you can withdraw your consent at any time.
- Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
- Erasure: You can ask us to delete your personal information where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such personal information.
- Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form.
- Restriction: You can ask us to restrict the personal information:
- whilst we verify your personal information as set out in “Rectification” above;
- pending verification of our legitimate grounds as set out in “Right to Object” above; or
- if the processing is unlawful or no longer necessary but you wish for us to retain your data for the purposes of establishing, exercising or defending legal claims.In such circumstances, we will only process your personal information (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) reasons of important public interest.
- No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you unless you have given us your consent, it is necessary for a contract between you and us, or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. However, we do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and, therefore, we may not fulfil every request.
If you would like to exercise any of these rights or you have any concerns about how your personal information is processed, please contact us at firstname.lastname@example.org.
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 in accordance with Article 77 of the General Data Protection Regulation. More information on lodging a complaint with the Information Commissioner’s Office can be found at https://ico.org.uk/concerns.
10. Cookies on our websites
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We may use all one or all four categories of cookies:
- “Strictly necessary cookies” are essential for you to move around our website and to use its features, such as the my account feature.
- “Performance cookies” collect anonymous information about how you use our site, like which pages are visited most and we do this to improve the website user journey. Using analytic tools such as Google analytics for the Website hosted by 123.Reg, Meta Business Suite for Facebook and Instagram, Brevo.com and Typeform.
- “Functionality cookies” collect anonymous information that remembers choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a recording or commenting on a blog.
- “Targeting or advertising cookies” collect information about your browsing habits in order to make advertising relevant to you and your interests, however we do not currently serve advertising messages on our website.
You can opt out of all our cookies (except the strictly necessary cookies). But, if you choose to refuse all cookies, our website may not function for you as we would like it to.
11. Recording and programme evaluation
Programme event sessions are often recorded and shared within our community and/or used for programme evaluation and quality assurance purposes. In addition, our communications with our teams (including by telephone or email) may be recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
To find out more about this policy and how we look after your personal information, please contact us by email at email@example.com.
The UK GDPR is the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (EU GDPR) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419).
Effective Date 14th December 2023