Privacy Policy

INTRODUCTION

Careerminds UK Limited, trading as ‘Renovo’ (hereafter referred to as Renovo) is a leading provider of outplacement and career transition support. We provide career management and transition support for individuals to help them define their next career steps and provide practical support and guidance to help them achieve their career goals.

Your privacy is important to us and we take it very seriously. The policy below lays out in plain English how Renovo handles your personal data. We want to ensure that you know exactly how we use your personal information, that you continue to have peace of mind about how we use your data and that we act transparently, only collecting information about you that we need.

DEFINITIONS

Clients:                        An employer or other Institution sponsoring the provision of our services to you.

You, Your:                   References to ‘you or ‘your’ refer to you as the recipient and user of our Services that are initiated by our Client or by you directly.

Services:                      The career support that Renovo provide to you including but not limited to Personal Career Coaching (telephone and face to face), access to online career resources and Workshops (online and face to face).

RENOVO AS A DATA CONTROLLER AND OUR REGULATOR

1. Renovo is registered as a Data Controller with the Information Commissioner's Office Certificate Number Z121949X.
2. Our Data Protection Representative is Chris Parker, Managing Director. If you have any queries in relation to data security or wish to make a subject access request, you can email dataprotection@renovo.co.uk
3. The office of the Information Commissioner is the office appointed by the UK Government with responsibility for data protection, and they can also assist with any complaints or questions you may have. They can be contacted at ico.org.uk.

HOW DO WE COLLECT INFORMATION ABOUT YOU?

1. From one of our Clients (e.g. employer or other Institution) who provide us with basic personal information about you to initiate the Services on your behalf. This typically includes name, personal email address, personal telephone number and job title.
2. Directly provided by you to Renovo during the provision of the Services e.g. notes from Career Coach interventions, information you store on the online platform (Workfriend), information collected if using the wellbeing support, survey information etc.
3. Indirectly from you, via the use of Cookies when you browse our online resources.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We may collect and process different types of information about you in order that we can effectively provide the Services. Some examples of the information we collect include:

1. Standard contact information including your name, address, post code, telephone number(s), email address, etc.
2. Records of your education, work experience, achievements, skills, preferences or other biographical information that you may provide to us or hold in documents stored by us while accessing the Services.
3. Information pertaining to your specific job search, including roles applied for, interviews, feedback and outcomes.
4. Information about your wellbeing and health (only so far as provided by you directly) when accessing the confidential wellbeing support line or follow up counselling.
5. Information relating to your views on our Services including e.g. responses to survey information.
6. Usage and log data automatically collected when you visit our website(s), including IP address and associated general location, device information, browser type, operating system, your progression through the site, what areas you viewed and where you abandoned it.
7. Social media data you choose to provide (e.g links to LinkedIn profile)

WHY DO YOU NEED TO PROCESS MY PERSONAL DATA?

Renovo is committed to processing your personal data in accordance with the principles of lawfulness, fairness and transparency, data minimization, accuracy, storage limitation and integrity, and confidentiality. In simple terms we need to process your personal data in order that we can:

1. Effectively provide the Services to you, including communicating with you, recording activities and administering your account.
2. Fulfil our contractual obligations to our Clients to provide the Services.
3. Meet legal or regulatory requirements.
4. Administer, maintain and improve our Services by monitoring interaction with various aspects of those Services, e.g. levels of engagement with personal career coaching or level of interaction with certain online resources.

WHO WE MAY SHARE PERSONAL DATA WITH

We do not sell mailing lists to any third parties for their marketing purposes. We stress that we will not disclose your personal information to any third parties unconnected to the provision of the Services to you. For clarity however, it is worth noting that:

1. We may use carefully selected third parties to carry out certain activities to help us provide the Services to you effectively. These third parties have access to, and are associated with, the processing of your personal information and are legally obliged to respect the confidentiality of your data and are bound by contract to do so. These third parties would operate as our Data Processors and include:

• Access Technologies - who manage and host our Workfriend resources and Case Management system that helps Coaches keep up to date with your journey.
• Maximus UK - who operate the independent, confidential wellbeing helpline. Please note that the only data being processed by Maximus is shared by you on activation of this element of the service.
• Associate Coaches – our trusted network of independent career coaches, who provide the career coaching support to you but administered and recorded within our systems or that of our data processors.

2. If the Services being provided to you have been sponsored by our Clients (e.g. an employer), we may disclose information to them for the purposes of them assessing the success and quality of the Services being provided to you. You have the right to request that this information is not shared with our Clients by emailing dataprotection@renovo.co.uk
3. Regulators or Law Enforcement agencies if required by law to do so.

HOW LONG WILL MY DATA BE STORED AND WHAT CRITERIA WILL DETERMINE HOW LONG YOU HOLD IT?

We store personal data in line with legal, regulatory, financial and best-practice business requirements and in line with our data retention policy which can be requested by emailing dataprotection@renovo.co.uk. We have a process in place on an annual basis to review the different categories of data we hold and determine the necessity to hold that data, taking into account fully the lawful bases for continuing to process.

YOUR RIGHTS OVER YOUR PERSONAL DATA

Under the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, you have a number of rights in relation to your personal data. These rights are not absolute and may apply only in certain circumstances.

You have the right, in certain circumstances:

• to be informed about the collection and use of your personal data.
• of access to the personal data we hold about you and to obtain a copy of that information (commonly known as a “subject access request”).
• to rectification of inaccurate or incomplete personal data that we hold about you.
• to erasure of your personal data (also known as the “right to be forgotten”).
• to restrict processing of your personal data.
• to data portability of your personal data to you or to another organisation, where technically feasible.
• related to automated decision-making and profiling where decisions are made about you solely by automated means and produce legal or similarly significant effects.

To exercise any of these rights, please contact our Data Protection Representative at dataprotection@renovo.co.uk. We may need to request specific information from you to help us confirm your identity before responding to your request. We will respond to legitimate requests without undue delay and, in any event, within one month, although this period may be extended where permitted by law.

If you are dissatisfied with how we process your personal data, you also have the right to lodge a complaint with the Information Commissioner's Office (“ICO”). Further information can be found on the ICO website: ICO website.

CROSS BORDER TRANSFERS OF PERSONAL DATA

We do not typically transfer your personal data from the European Economic Area (EEA) or the European Union (EU) to a country outside the EEA or the EU except when you access the Services from outside the EEA or the EU. In the event that this was deemed necessary for the effective provision of the Services, we would guarantee only to use third parties that meet the data protection regulation standards in the EEA or EU and in accordance with data protection legislation e.g. EU-U.S. Data Privacy Framework (DPF).

SECURITY

Renovo has comprehensive IT, data and physical security arrangements in place. All of our data is held securely within the EEA and appropriate back-up procedures are in place. Our staff are subject to screening and are trained in the importance of ensuring data is used and managed correctly in line with current Data Protection Legislation. In the event of a suspected breach, we have a clear process in place for investigation and notification of data subjects.

Please be aware that communications over the internet, such as e-mails/webmails that may form part of our communication to you while delivering the Services, are not secure unless they have been encrypted. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

HOW AND WHEN WE MAY CHANGE THIS POLICY

We will keep this Policy under review and any changes made from time to time will be posted on this page. Please check back regularly to keep informed of updates or changes to this privacy statement. Your continued use of the Services shall constitute your acknowledgment of these changes.