THE QUO GROUP LIMITED PRIVACY NOTICE FOR DIAGNOSTICS, ASSESSMENT and
PSYCHOMETRIC TESTING SUBJECTS
WHAT IS THE PURPOSE OF THIS DOCUMENT?
The Quo Group Limited ("Quo Group", "us" or "we") is committed to protecting the privacy and security of your personal data.
This privacy notice describes how we collect and use personal data about you when you undergo our diagnostic, assessment and psychometric testing, in accordance with the General Data Protection Regulation (GDPR).
The Quo Group Limited is a private limited liability company, incorporated and registered in England and Wales with company number 02837913 whose registered office is at 3 Bath Mews, Bath Parade, Cheltenham, Gloucestershire, England, GL53 7HL.
The Quo Group is a "data controller". This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the data contained in this privacy notice.
Quo Group acts as a joint controller with our clients wherever they have commissioned us to provide diagnostic or assessment and psychometric testing for development, selection or recruitment purposes. You will have been briefed by our client on the specific project for which it has commissioned us to prepare a report relating to you.
It is important that you read this notice, so that you are aware of how and why we are processing your personal data.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal data we hold about you must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
THE KIND OF DATA WE HOLD ABOUT YOU
Personal data, or personal data, means any data about an individual from which that person can be identified. It does not include data where the identity has been Website removed (anonymous data).
There are "special categories" of more sensitive personal data which require a higher level of protection. Special category data is personal data which reveals your racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, or criminal convictions. We do not process any special category data relating to you in carrying out our development diagnostics, assessment or psychometric testing services.
We will collect, store, and use the following categories of personal data in completing diagnostic or assessment surveys and reports.
Username and password for completing our online questionnaires
Questionnaire and diagnostic activity response data
Profiling data resulting from our analysis of your questionnaire responses
Interpretation data of your questionnaire results
360 survey result (self, boss, peers and direct reports inputs.)
HOW PERSONAL DATA IS COLLECTED
We collect personal data from you directly through you:
interacting with us by email and telephone
completing our online questionnaires
meeting with our consultants
HOW WILL WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
A lawful basis for processing personal data is where the data subject has given consent to the processing of his or her personal data for a specific purpose.
For consent to be valid it must be a freely given, specific, informed and unambiguous statement or action signifying your agreement to the processing of your personal data.
We will only carry out our diagnostics or assessments with your consent. We have asked you to confirm your consent to us processing your personal data in order to prepare a report relating to you for our client. You will have been briefed by our client on the project. If you choose not to give your consent, we will not be able to provide a diagnostic or assessment outcome.
Consent must also be as easy to withdraw as it is to give. This means, once you have given your consent to the processing, you have the right to withdraw it at any time. If you withdraw your consent we may not be able to complete diagnostic or assessment outcomes relating to you. This will not affect the lawfulness of any processing carried out by us based on your consent prior to you withdrawing your consent.
Other circumstances where we may use your personal data
We may also use more limited personal data about you where:
we need to comply with a legal obligation; or
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
This may include, for example, processing personal data such as your name and personal details in connection with performance of our contract with our client.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Scientific research or statistical purposes
We may process your personal data for scientific research or statistical purposes. You have the right to object to us processing your personal data for such purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for scientific research or statistical purposes, in which case we may use this data indefinitely without further notice to you.
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We are allowed to use automated decision-making where you have given your explicit consent and where appropriate measures are in place to safeguard your rights.
We do not use automated decision making in our diagnostic or assessment consulting services. Where we use psychometric tests as inputs to our diagnostic or assessment services, the test suppliers may use algorithms to complete individual or team/group profiles. However, all results are subject to human interpretation by our specialist consultants.
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal data outside the EEA. If we do, you can expect a similar degree of protection in respect of your personal data.
Why might you share my personal data with third parties?
We will share your personal data with third parties where required by law or where it is necessary for our legitimate interests, such as with third party service providers, in the ordinary course of our business.
Which third-party service providers process my personal data?
Our third party service providers change from time to time and we can let you have details of parties who are processing your data at any given time upon request. We routinely share personal data with IT service providers, cloud storage providers, our bank, accountants, legal advisers, other professional advisers and other service providers.
We may also share your personal data with specialist consultants who we engage to assist us in preparing our reports.
How secure is my data with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business, or if it is required for legitimate business activities. We may also need to share your personal data with a regulator, HMRC or to otherwise comply with the law.
Transferring data outside the EEA
We may transfer your personal data outside the EEA. If we do, we will ensure there are appropriate measures in place to provide a similar degree of protection for your personal data as that required in the EEA.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Where we are otherwise authorised to transfer your personal data, for example where you have given your explicit consent to the transfer, where it is necessary to performance of a contract between you and us, or where it is for the establishment, exercise or defence of legal claims.
Please contact our data privacy manager if you want further data on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place measures to protect the security of your data. Details of these measures are available upon request.
Third parties will only process your personal data on our instructions and where they have agreed to treat the data confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will only retain your personal data for a period of 36 months after we have prepared our report on you, after which time it will be securely destroyed.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RETRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object to processing of your personal data for scientific research or statistical purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the designated person within our client's organisation in writing. We will work with our client, as joint controller, in dealing with any such request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific data from you to help us confirm your identity and ensure your right to access the data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to withdraw consent
Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our data privacy manager. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data privacy manager
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the data privacy manager. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time.
Privacy notice update 2021: EU representative contact details
If you have any questions about this privacy notice, please contact our Data Privacy Manager: firstname.lastname@example.org