Privacy Policy

Last updated: 2 November 2018

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The GDPR Owner is Vanessa Rogers, Operations Manager, and she is responsible for ensuring that this notice is made available to data subjects prior to Catalyst 14 Ltd “Catalyst 14” collecting/processing their personal data.

2.2 All employees of Catalyst 14 Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured

3. Privacy notice

3.1 Who are we?

Catalyst 14 Ltd, Company Number 10043046.
Registered Office Address: 146 New London Road, Chelmsford, Essex, England, CM2 0AW
Postal address: 1 Dysart Street, London, EC2A 2BX

Director: Damion Wonfor
Operations Manager: Vanessa Rogers

Catalyst 14 Ltd is run by Damion Wonfor – an experienced executive coach, mindfulness trainer, coach supervisor and facilitator. He has coached and trained at all levels within the private and public sectors in the UK and globally.

Damion has worked at all levels within organisations with high potentials, managers, directors, executives and leadership teams across a variety of functions. He is passionate about building strong relationships with his clients and helping individuals and teams explore their personal authenticity and emotional intelligence to make sustainable changes to their behaviour. He brings a high degree of calm presence, support and challenge, enabling his clients to fully accept and embrace change.

Damion’s focus is always on how the individual can fully explore who they really are within their work and how they can make the required shifts in performance to maximise improvements in their work and personal lives. His recent team and individual assignments have been focused on exploring and developing key emotional intelligence capabilities such as confidence (imposter syndrome), empathy, impulse control and resilience.

Vanessa Rogers (GDPR Owner and Operations Manager) can be contacted directly:

Via the Catalyst 14 contact form
Phone: 020 3287 8141
Postal address:1 Dysart Street, London, EC2A 2BX

The personal data we would like to collect from you and process is as follows:

Personal data type:	Source
Name	Obtained directly from you
Email address	Obtained directly from you
Address	Obtained directly from you
Telephone number	Obtained directly from you
Health data	Obtained in Mindfulness events when a health declaration section is completed on the form
Gender	If applicable – obtained from you for ILM membership
Date of birth	If applicable – obtained from you for ILM membership

The personal data we collect will be used for the following purposes:

Administration in arranging the courses / workshops you will be completing with Catalyst 14 (the contracts signed for Organisation / Corporate clients / the completion of the online form / accepting of our Terms and Conditions as confirmed on our website
Sending you information and resources regarding our services and products and future events
Administration relating to ILM membership – where it relates to you
Administration relating to EMCC (open programmes) – where it relates to you

Our legal basis for processing for the personal data:

Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
Legitimate interests: the processing is necessary for your legitimate interests unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Any legitimate interests pursued by us, or third parties we use, are as follows:

Direct marketing
Relevant and Appropriate Relationship
Reasonable Expectations
Employment information

The special categories of personal data concerned are:

Health data – a health declaration section is completed in a form for the Mindfulness events. On receipt of the form, Damion Wonfor reviews the information and assesses their suitability to attend the Mindfulness Training Course. The form is then deleted / destroyed.

3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Catalyst 14 to process personal data, but it must be explicitly given.

You may withdraw consent at any time by emailing us via our contact form. Our newsletters all include an unsubscribe option.

3.2 Disclosure

Catalyst 14 will not pass on your personal data to third parties without first obtaining your consent. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

Third Party	Safeguards in place to protect your personal data
ILM	Agreement in place including confidentiality and GDPR requirements

3.4 Retention period

Catalyst 14 will process personal data for as long as they are in contact with you and you are attending their courses / events and consenting to receiving their marketing info / resources and will store the personal data for 6 years plus the current financial year as required (as advised by their Accountant).

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that Catalyst 14 refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Catalyst 14 (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Catalyst 14’s GDPR Owner.

The details for each of these contacts are:

	Supervisory authority contact details	GDPR Owner contact details
Contact Name:	Case workers at The Information Commissioner	Vanessa Rogers
Address line 1:	Wycliffe House	1 Dysart Street
Address line 2:	Water Lane	London
Address line 3:	Wilmslow	EC2A 2BX
Address line 4:	Cheshire
Address line 5:	SK9 5AF
Email:	[email protected]	Email Vanessa Rogers via our contact form.
Telephone:	0303 123 1113.	020 3287 8141

4 Online privacy statement

Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information
This privacy notice tells you how we, Catalyst 14, will collect and use your personal data for clients who use our services and/or who subscribe to our marketing information / resources.

Visitors to our website
When someone visits www.catalyst14.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of cookies by Catalyst 14
You can read more about how we use cookies on our Cookies Notice page.

E-newsletters
We use a third party provider, Mailchimp, to deliver our monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our email marketing. For more information, please see Mailchimp’s privacy policy.

Facebook

We use a Facebook cookie to track users who click on our Facebook ads, or visit our website. This is so we can serve relevant advertising on the Facebook platform and associated websites to those who have expressed an interest in our services. You can view Facebook’s privacy policy here.

Google Ads
We use a Google Adwords cookie to track users who click on our Google ads, or visit our website. This is so we can serve relevant advertising on Google and its associated websites to those who have expressed an interest in our services. It also allows us to measure the success of our Google Ads campaigns. You can view the Google Adwords privacy policy here.

Google Analytics

We use Google Analytics tracking code to analyse traffic to and activity on our site. You can view Google’s privacy policy here.

Clients or potential clients who email us

We monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Job applicants and our former, current and future employees

What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

Application stage
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

You will also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

Shortlisting
Our management team shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.

Assessments
We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Catalyst 14.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

Conditional offer
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
You will be asked to complete a criminal records declaration to declare any unspent convictions.
We will provide your email address to the Government Recruitment Service who will contact you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
We will contact your referees, using the details you provide in your application, directly to obtain references
We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).

If we make a final offer, we will also ask you for the following:

Bank details – to process salary payments
Emergency contact details – so we know who to contact in case you have an emergency at work

How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

How we make decisions about recruitment?
Final recruitment decisions are made by the management team. All of the information gathered during the application process is taken into account.

Why does Catalyst 14 need to collect and store personal data?
In order for us to provide you with a service we need to collect personal data for correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes, Catalyst 14 would or has already contacted you for additional consent.

Will Catalyst 14 share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Catalyst 14 in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Catalyst 14 procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Catalyst 14 use the personal data it collects about me?
Catalyst 14 will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Catalyst 14 is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Catalyst 14 contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out what personal data that Catalyst 14 holds about me?
Catalyst 14 at your request, can confirm what information we hold about you and how it is processed. If Catalyst 14 does hold personal data about you, you can request the following information:

Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Catalyst 14 or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?
Catalyst 14 accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last 3 months).

Contact details of the GDPR Owner:

	GDPR Owner contact details
Contact Name:	Vanessa Rogers, Operational Manager
Address line 1:	1 Dysart Street
Address line 2:	London
Address line 3:	EC2A 2BX
Address line 4:
Address line 5:
Email:	Email Vanessa Rogers via our contact form
Telephone:	020 3287 8141