Privacy Policy

Infinitely People Limited ("we, us, our") is committed to safeguarding the privacy of our Website and/or platform visitors and users. We are committed to protecting and respecting your privacy, and to acting in compliance with the Data Protection Act 1998 (the "Act") up to but excluding 25 May 2018 and thereafter:

unless and until the General Data Protection Regulation ((EU) 2016/679) ("GDPR") is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK; and then
any successor legislation to the GDPR or the Data Protection Act 1998.

Please read the following Privacy Policy to understand what information you provide us with, how this information is collected, processed and used. The policy also seeks to outline how we safeguard personal information that you may provide us with when you visit or use our Website and/or Platforms.

Simply visiting our Website does not require you to provide us with any personal information, however if you request more information from us, register or order from us or use any of our Platforms, products or services, we collect any personal information you provide and the details of the transaction between both parties. This policy together with our Terms and Conditions of Use explain how we collect, use and process the data you may provide us with. Please at no point provide us with any personal data which belongs to someone else without their expressed permission.

Please read the following Privacy Policy carefully. By using our Website and/or Platforms and/or registering your interest in us or our services online, you consent to its terms. If you do not agree with the terms of the Privacy Policy, you should refrain from using our Website and/or any of our Platforms.

The content of our Privacy Policy includes:

Definition of terms
Key privacy principles
Collection and usage of personal information
Disclosure of personal information
Length of storage of information
Security and international transfers
Cookie usage
Marketing
Access to data held about you
Links to other sites
Applicable jurisdiction
Changes to our privacy policy
Contacting us

1. Definition of terms

In this Privacy Policy:

"Identification data" means personal data such as your name and contact details;
"Assessment data" means your responses to assessments and/or questions needed for the effective running of our various human capital Platforms. It may include but is not exclusively information such as motives, opinions, competencies, behaviour, aptitudes, interests and talents and work experience;
"Research data" means responses about yourself and may include data such as your age, gender, cultural background, educational, job / work related;
"Website" means www.infinitelypeople.com or any sub domains or IT systems used by us;
"Platform" and/or "Platforms" means any one of our online Platforms which contain any of our IT based Human Capital systems including but not exclusively; our applicant tracking platform, our assessment tools platform, our performance and talent management platform, our 360° feedback platform, our employee engagement survey platform, including any bespoke development provided by us or any sub domains or IT platforms used by us;

2. Key privacy principles

The following three key privacy principles guide our use of data:

Notice
We are committed to making information concerning our data practices readily available to you so you can make an informed decision concerning your activities on our Website and/or Platforms (please see the collection and usage of personal information sections below). We actively encourage our customers to do the same when we collect data in the course of providing a service or products to them.
Choice
We provide you with the opportunity to elect not to participate in certain data collection activities through our Website and/or Platforms (please see the collection and usage of personal information sections below).
Access
All visitors to our Website and/or Platforms are provided with the opportunity to access, review, modify and delete any personal information which may have previously been provided or collected.

3. Collection and usage of personal

The Website and/or Platforms contain business-related content and we do not solicit or collect personal information relating to or from children. Depending on how you use or interact with our Website and/or Platforms, the following types of information may be collected, processed, used and stored.

Information provided when you visit our Website

Like most Website providers, some information is collected automatically concerning your computer, your visits to and use of our Website, in order for us to:

understand Website usage including which areas of our Website users prefer;
administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
improve our Website to ensure that content is presented in the most effective manner for you and for your computer; and
keep our Website safe and secure.

The information collected is stored in log files, in an anonymous form, where no individual is identifiable or identified, and may but not exclusively include the following:

technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
traffic data, location data, weblogs and other communication data, required for our own billing and administration purposes;
usage data, such as the source address that the page request is coming from, including your Internet protocol (IP), domain name, date and time of the page request, the referring website (if any) and other parameters in the URL (e.g. search criteria); and
information about your visit, including: the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); pages you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page; and any phone number used to call our customer service number.

Information provided when using or interacting with our Website and/or Platforms

This information may but not exclusively include the following:

Information that you provide when you visit or register with us, whether as a partner, client or candidate. The information we may (but not exclusively) collect from you includes your username, identification data, assessment data and research data;
Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
Information you provide when you request products and/or services;
Information you submit when entering a competition or promotion sponsored by us;
Information you provide when you contact us to report a problem or have an enquiry;
Information provided in completing a survey that we use for research purposes and/or information submitted when you enter any competitions or promotions sponsored by ourselves;
Purchase information you provide when placing an order or making a purchase of our goods and/or services or any other transactions that you enter into through our Website. Information which may be collected in this instance includes your name, email address, contact phone number, physical address and card/payment details;
Information you provide when completing our assessments, questionnaires or utilising any of our other Platforms used via our internet-based scoring and delivery platforms. Information collected here may include identification assessment and research data; and
We may, on occasion, acquire information from third parties (e.g. credit reference agencies) who are legally entitled to disclose that information to us.

In summary typically but not exclusively the information we collect about you above when using our Website and/or Platforms is used for the following reasons:

administration of our Website and/or Platforms including notifying you about changes to our services;
personalisation of the Website / Platforms and services for you to ensure that content from our Website and/or Platforms is presented in the most effective manner for you and your computer, tablet or smart phone;
enabling your access to and use of the Website and/or Platform services;
providing you with services and/or products purchased through the Website and/or Platforms;
billing i.e. sending you invoices and statements;
collecting payments from you;
providing you with, on request, personalised computer-generated reports following completion of our online assessment instrument questionnaires;
sending you marketing communications including promotions, surveys and exclusive opportunities offered by us, where you have consented to being contacted for such purposes;
resolving complaints or responding to inquiries submitted via our Website and/or Platforms;
maintaining and supporting any registered account you may have with us including facilitating your access and providing you with resources and tools/materials available to you;
seeking your views on products and/or services;
engaging in research and analysis in order to maintain and improve our products and services including developing new products;
providing you with information about further assessments, human capital systems and services we offer which are similar to those that you have already purchased or enquired about;
when we have your consent, for the recruitment, selection and development purposes by potential employers, managing recruitment and human resource processes and any related purposes where you have consented to the collection;
using information collected through completion of our assessment instrument questionnaires for research purposes in order to produce statistics such as norms and validity data. You will be asked for your consent prior to this data being collected and can elect to provide it or not. Any data collected is used only for research purposes in the anonymised and aggregated form (i.e. no individual is identified or identifiable from such data);
sharing your information with third party vendors performing functions on our behalf (e.g. vendors who analyse data, assist us with customer service or process credit card payments); and
keeping our Website and/or Platforms secure and preventing fraud.

Information provided when participating in our assessments and/or using one of our human capital Platforms

When you participate in an assessment through our assessment Platform or are a participant on one of our other human capital Platforms, as a prospective or employed staff member with one of our clients, you will be asked to provide responses which may constitute personal data.

Such data may be categorised as, identification, assessment and research data. Each of the types of data will be used as follows:

Identification Data – This data is required for the purpose of identifying yourself. It is required in order for us to administer assessments or effectively provide an accurate and reliable human capital Platform to our clients. We will provide the results to the client who requested your participation in the assessment and/or Platform, which was subsequently made available to you, for your use.
Assessment data – This data is typically data received from your responses in assessments and/or to questions posed on our human capital Platforms. Once again, we will provide the results to the client who requested your participation in the assessment and/or on the Platform, which was subsequently made available to you, for your use.
Research data - This type of data does not form part of the assessment and/or human capital Platforms and is only used for research purposes in order to evaluate our assessments, surveys, questionnaires and systems for fairness and maintain a high standard of product. This data is used to produce statistics including assessment norms and validity data for our assessments;

Where an assessment and/or human capital Platform requests you to provide research data, we will ask for your explicit consent to collect and process such information in a data protection notice. You will have the opportunity to refuse or omit to provide such research data. If you decline or omit data, certain data is not collected or used for research purposes. You will still be able to complete your assessment without completing the research data and not completing the research data will have no effect on your assessment results or ability to use the system. If you do consent, the personal data submitted by you will only be used for research purposes and only in an anonymised aggregated form. If you complete the assessments or partake in a human capital Platform in a jurisdiction that prohibits completion of research data, you should not complete those details to the extent the law prohibits doing so.

Research Data requested may include sensitive personal data (as defined in the Act) and shall be processed in accordance with this Privacy Policy and the Act and we shall ensure that it is treated securely with regard to its nature.

The assessment and human capital Platform reports and services we provide to our clients may be used by them for purposes which may include the selection and development of individuals in an employment or human resources context. We may also provide a copy of the assessment and/or Platform data to our clients for them to use within their own internal human resource management process.

Clients are entitled to use the personal information we provide to them as part of our services for their own purposes. They are however obliged to process such personal information in accordance with their own obligations under the Act, GDPR and other data protection laws as applicable and in accordance with our Terms and Conditions of Use. You will have rights to the manner in which our clients process such personal information provided by us to them.

Third party contact details

As part of some of our assessment and/or human capital Platform processes where we require input from related parties, for example the 360° Feedback Platform or employee engagement survey Platform, we may request and/or you may volunteer the contact details of a third party. You will need to inform such third party that you intend to disclose this information and obtain their prior consent before disclosing their details to us.

If you are contacted by us as a result of your details being disclosed to us by a participant in our assessments and/or human capital Platform processes we confirm that we will use that information and any subsequent information in accordance with this Privacy Policy.

4. Disclosure of personal information

The information held within our system concerning yourself is stored in a secure database and kept private. Access to that information stored under your account is protected by your username and password. Provided you maintain the security of your username and password, no one other than those listed below will be able to access your information.

We will not disclose your personal information to third parties except:

clients in the context of the provision of services to them in connection with the assessments and/or human capital Platforms in which you have participated;
the "Account Manager" of the registered organisation who can view any information pertaining to users accounts and candidate information relating to that organisation;
the "users" of a registered organisation who can access assessment and/or Platform information they have duly been authorised to have access to by the account manager
others to whom the organisations’ key account manager or users instruct us to send information to. The Platforms provide the opportunity to send various reports including but not exclusively; profile reports to an email address. This is executed at your own risk and is dependent upon the right email address being entered;
any of our employees, officers, subcontractors, professional advisers, agents, and suppliers insofar as reasonably necessary for the purposes set out in this policy, each of which is subject to the Act and thereafter GDPR, as applicable;
any parties necessary to fulfil your orders for our services or goods and to validate your payment details;
to suppliers and licensors that process data on our behalf;
where an individual completes one of our instruments under the direction of our qualified customers and we perform a service scoring that instrument for the client, we will send the individual’s results to that client in order for them to provide appropriate feedback to the individual who completed the instrument;
for anonymous research purposes using the information provided for statistical analysis of large groups of individuals. From this research you will not be identified or identifiable and we will not contact you in connection with this;
where we believe, in good faith, that it is necessary to comply with any applicable law, or to protect our safety, that of our customers, their clients or the public;
in connection with any ongoing or prospective legal proceedings or to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention or credit risk reduction); and

in the event that we buy or sell any business or assets including selling our business or assets, our clients and participants assets will be one of the transferred assets in such sale.

5. Length of storage of information

In accordance with the Act, no personal data should be kept for any longer than is necessary for the purpose for which it is collected. This means that data is destroyed/erased from our systems when it is no longer required. Generally we keep information for as long as is necessary for the purposes for which we process information. We may however, delete, destroy or anonymise information about you as we consider appropriate from time to time.

In relation to personal and sensitive personal information collected as a consequence of the use of our assessment and/or some of our human capital Platforms, which contain assessment type questionnaires or other candidate/participant information, this information is generally retained for a period of 12 months after which it is deleted. After that period you will be unable to access candidate/participant information or previous reports and consequently should a candidate report be required, the candidate/participant will be required to complete a new questionnaire from which a new report may be generated.

Any information retained on our system after 12 months is for research or technical purposes (i.e. statistics, validities or compilation of norm groups) and no longer constitutes personal data. The data is anonymised and aggregated on our system at which point no individual is identified or identifiable from such data and the data no longer falls within the scope of the Act. Consequently after the expiry of the 12 month retention period it will not be possible to order new reports or order reprints of previously ordered reports as the personal data of a candidate would have been deleted. A new assessment will need to be completed should you wish to have a further report on a candidate.

Other information collected through our Website and/or platforms is retained for periods in accordance with applicable law and regulation.

6. Security of Data and International Transfers

We implement appropriate security policies, rules and technical measures to protect against loss, misuse and alteration of information under our control.

Due to the international nature of internet based assessments and human capital Platforms we may from time to time appoint third parties to process data containing information about you on our behalf as a data processor, or store such information in, or transfer it to persons, located in countries outside of the European Economic Area ("EEA"). Information that you submit or we collect may consequently be transferred, processed and/or stored on third party data processors located anywhere in the world and outside of your jurisdiction, which may not have data laws equivalent to those in the EEA. Where personal information is transferred outside the EEA, we take all reasonably necessary steps to ensure it is treated securely and that the third parties outside of the EEA provide sufficient guarantees in respect of the technical and organisational security measures and take reasonable steps to ensure their compliance with those measures and in accordance with this Privacy Policy in ensuring our data is adequately protected. However transmission of information via the internet is never completely secure and therefore we cannot guarantee the security of the data submitted on our Website and/or Platforms or via other electronic means. By submitting your information you agree to the transfer, storing and processing of your information in accordance with the above.

7. Cookie usage

Our Website uses analytical and functional cookies. Cookies are pieces of information in the form of little text files that are stored by your browser with your permission; usually (but not always) to make your website experience better when you visit websites. Cookies collect information about the internet user such as names, email details, and user preferences. These cookies are consequently used to allow us to distinguish between the different users of our Website and/or Platforms and in turn help us provide you with a good experience and improve the Website and/or Platforms.

Visiting this Website and/or Platforms may generate cookies that get stored on your computer or mobile device. We use both session and persistent cookies.

Session cookies are temporary cookies which exist only for the period you access the Website and/or Platforms and expire at the end of the user session when the browser is closed. These cookies allow us to link your actions during your browsing session so you are only required to enter information once and it’s remembered for the remainder of your browsing session.
Persistent cookies are cookies that remain on the hard drive of your computer after you have visited our Website and/or Platforms and will remain valid until their set expiry date or until they are deleted by the user before the expiration date. These cookies assist us in identifying you as a unique visitor and recognising you on future visits.

The analytic cookies used help us understand how many people visit our Website and/or Platforms, what they look at, how they find us and to give us an understanding of how our Website and/or Platforms are performing. This data is anonymous and cannot be used to identify individuals. It is possible to restrict or withdraw consent and block cookies used by ourselves. However if you elect to do this it will restrict the services you can use or our Website and/or Platforms may not work as well as it was intended to or not at all.

Information may be provided to third parties but only in relation to providing web or other services to you connected to the service we provide. No information is passed to third parties for marketing purposes.

We use first party cookies set by ourselves only. Please note that third party links on our Website may use cookies over which we have no control. You may however restrict or block third party cookies through your browser settings and this should not affect your use of our Website. Please see below for more information on how to turn off or control cookies.

Turning off or controlling cookies

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by using our Cookie Consent Tool.

All modern browsers also allow you to change your cookie settings. The following links may be helpful in helping you understand how you can update your browser cookie settings:

More information about controlling or deleting cookies can be found at www.aboutcookies.org.

8. Marketing

We do not send marketing communications to people who are registered as candidates or participants on our Website and/or Platforms. However, if you are a client or prospective client who has provided us with your details we may contact you in relation to services/products you may be interested in.

You may also receive advertising relevant to you on our online advertising network, in line with our cookie policy.

If you do not wish for us to use your personal data for marketing communications, we may send you from time to time, of our products and/or services please let us know by emailing us at enquiries@infinitelypeople.com. Whilst you are able to opt out of marketing communications, it is not possible to opt out of communications for administrative or operational reasons.

9. Access to data held about you

You may, subject to applicable law, have the right to contact us and establish what information we hold concerning you, or access, cancel or correct any information held. If you wish to see a copy of the personal information we hold pertaining to you, you may request this by emailing our Data Protection Officer at enquiries@infinitelypeople.com.

If you wish to see information we hold about you, you will need to complete a Subject Access Request Form, the purpose of which is to ensure that you give us all the necessary information to enable us to comply with your request. You are not required to use this form but if you elect not to we encourage you to ensure that all required information on the form is provided.

In accordance with the act, we may charge you a fee of £10.00 for our costs in providing you with a copy of any personal information we hold about you.

10. Links to other sites

This Privacy Policy applies only to information collected by us. Our Website includes hyperlinks to and details of third party websites. Links within our Website to those of other organisations are not covered by this Privacy Policy. It is advised that if you link to other websites, you read their privacy policies before submitting personal information to those sites. We accept no responsibility or liability for the policies of other websites.

11. Applicable jurisdiction

All contracts including this Privacy Policy entered into with us are governed by English law and the place of performance of obligations will be England and Wales.

12. Changes to our Privacy Policy

We reserve the right to modify or update this Privacy Policy from time to time to comply with applicable law or to meet changing business requirements without notice to you. Any updates or amendments will be posted on our Website and/or Platforms. By continuing to use the Website and/or Platforms you agree to be bound by the terms of the updates and amendments and it is your responsibility to ensure you keep yourself up to date with regard to the way we process your personal information.

13. Contacting us

Any questions you have about our Privacy Policy can be submitted by sending an email to enquiries@infinitelypeople.com.

Alternatively you can write to us at:
Infinitely People, 241 Raeburn Avenue, Surbiton, KT5 9DF, United Kingdom