Data Privacy Notice
Human Behaviour Change for Life CIC (currently registered as HBCA) is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation that replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your new rights under the GDPR are set out in this notice and apply since the GDPR became law on 25th May 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of data protection legislation in force from time to time the data controller is Human Behaviour Change for Life CIC (HBCL CIC), UK.
Who we are and what we do
We are a Community Interest Company, registered with Companies House (Company Number 10880678). We provide resources, expertise, ideas, courses, innovation, advice and support and may hold limited information about you to carry out our core business and ancillary activities. Unless you work very closely with us, this is likely to just be for you to be on our mailing list or events list and consist of your name, email address and affiliation.
Information you give to us or we collect about you
This is information about you that you give us by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register with us to enter our database, subscribe to our services, attend our events, or social media functions.
The information you give us or we collect about you may include your name, your affiliation, and perhaps demographic information such as address, e-mail address and phone number. If relevant we might also include relevant HBC expertise, responses to our emails, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or website.
Information we obtain from other sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, your business card, personal recommendations, and any relevant social media sites.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your area of work, interests or to your organisation in relation to HBC.
To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our subscribers is informing them of HBCL events, activities and news that could be of interest to them by phone and emails. To clients, we mainly offer consultancy services for specific projects and our contact is relevant to completing the agreed deliverables. However, our service expands to supporting individuals and organisation’s resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into an agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
When we work in a consultancy role, our legitimate use of our client’s data refers to information that allows us to contact our clients and undertake our deliverables.
When we provide training, our legitimate use of trainee’s data refers to information that allows us to contact them and tailor training to their needs.
When we circulate resources and newsletters to our subscribers, our legitimate use of their data refers to information that allows us to send them information, and they can unsubscribe at any time.
To deliver our ancillary services we need to contact some people on a regular basis, through various routes such as email, phone, job alerts and other relevant notifications.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other uses we will make of your data:
• Use of our website;
• To notify you about changes to our service;
• To ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• To allow you to participate in interactive features of our service, when you choose to do so;
• As part of our efforts to keep our site safe and secure;
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
To undertake our work, we do share personal information with selected third parties including:
• Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
• Subcontractors including email marketing specialists and event organisers.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If HBCL or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third-party processing will include:
• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• Satisfaction of their contractual obligations to us as our data processor;
• For the purpose of a contract in place or in contemplation;
• To fulfil their legal obligations.
Where we store and process your personal data
All information you provide to us is stored on our secure servers and securely with a cloud provider.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
• Prior to making an introduction we check that we have accurate information about you
• We keep in touch with you so you can let us know of changes to your personal data
You have the right to ask us not to process your personal data for marketing purposes.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
To unsubscribe from our e-newsletters, please email [email protected]
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.