Our Intent. We are committed to safeguarding the privacy of users to our site and we will only use the information that we collect about you lawfully and in accordance with the Data Protection Act 1998 (the “Act”).
Changes to Data Protection Legislation. Data Protection legislation and the Act is currently going through a period of change. The introduction of the European Union’s General Data Protection Regulation (GDPR) and the new British Data Protection Bill, which will replace the Act and is currently passing through Parliament is the basis of this change. This Privacy Notice is therefore intended to comply with the Act and GDPR but may change over time.
The Data Controller. This website www.xlg.co.uk is owned and operated by XL Global Group. References to “we,” “us,” our,” or “the website” are references to XL Global Group. We are a company registered in Scotland SC547315
Data Protection Officer (DPO). Our DPO fulfils a number of roles, one of which is to be the primary and independent point of contact for Data Subjects. The mechanism for Data Subjects to raise concerns regarding the processing of their personal data by XL Global Group is to email: firstname.lastname@example.org, or telephone 01224 798400; or send a letter by registered mail to XL Global Group, XL House, Woodburn Road, Blackburn, Aberdeen AB21 0PS at which point the inquiry will be forwarded to the DPO for action.
Purpose of Processing Personal Data. We collect personal data for two reasons. Firstly, in relation to employment opportunities and secondly, to provide you with the best possible service, including providing promotions on behalf of our third party partners.
Lawful Basis of Processing Personal Data. The lawful basis of processing your personal data are as follows:
- Legitimate Interest. As part of general marketing activities, XL Global Group’s Legitimate Interest is to collect your personal data when you visit this website.
Categories of Personal Data Processed. The information we hold should be accurate and up to date. The personal information which we hold will be held securely in accordance with our internal security policy and the law. The type or categories of personal data we may collect about you includes your:
- Postal address;
- Email address;
- Employment History
Category of Recipients of Personal Data. Personal Information relevant to your past experience and employment including Your name, email and postal address and training and employment history.
Transfer of Personal Data Outside the EEA (European Economic Area). We see no reason why your data would be transferred out of the EEA. If this is required, consent will be explicitly requested from you.
Sensitive Personal Data. We will never collect sensitive personal data about you without your explicit consent and a clear explanation why it is required.
Sale or Passing of Personal Data to Third Parties. We will not sell or pass your personal data to any company.
Retention of Personal Data. We will retain your personal data to support our records for 3 years to support our obligations to HMRC, and for reference of attendance and quality assurance of courses. Once this period is reached we will securely dispose of your personal data.
Data Subject’s Rights. Under the Act and in even more so under the GDPR you have a number of Rights which we have outlined below:
- Right of Access. You are entitled to access your personal data so that you are aware of and can verify the lawfulness of the processing. This is achieved through the mechanism of Subject Access Rights (SAR) and you have the right to obtain:
- Confirmation that your data is being processed;
- Access to your personal data (a copy); and
- Other supplementary information, which corresponds to the information in this privacy notice.
Fees and Timings. Until 25 May 2018, the Act allows XL Global Group to charge £10 for a SAR. Under GDPR and from 25 May 2018, this information will be provided without charge; without delay and within one month. If an extension is required or requests are considered manifestly unfounded or excessive, in particular because they are repetitive, XL Global Group may choose to: charge a reasonable fee taking into account the administrative costs of providing the information; or refuse to respond. The reasons for this will be formally notified to you and your rights to appeal to the appropriate supervisory authority will be highlighted.
Identify Verification. To protect your personal data, XL Global Group will seek to verify your identity before releasing any information, which will normally be in electronic format.
- Right of Rectification. You are entitled to have personal data rectified if it is inaccurate or incomplete. XL Global Group will respond within one month of your request. In the unlikely event XL Global Group does not take action to the request for rectification, XL Global Group will inform you of your rights to complain or seek judicial remedy.
- Right of Erasure. You may request the deletion or removal of personal data where there is no compelling reason for its continued processing. The Right to Erasure does not provide an absolute ‘right to be forgotten,’ especially once the processing is based upon a contract. However, you do have a right to have personal data erased and to prevent processing in specific circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
- When you withdraw consent (and this is the basis of processing);
- When you object to the processing and there is no overriding legitimate interest for continuing the processing;
- The personal data was unlawfully processed;
- The personal data has to be erased in order to comply with a legal obligation; and
- The personal data is processed in relation to the offer of information society services to a child, which XL Global Group does not provide.
- Right to Restrict Processing. Under the Act, you have a right to ‘block’ or suppress processing of personal data. The restriction of processing under the GDPR is similar. When processing is restricted, is XL Global Group permitted to store the personal data, but not further process it. In this event exactly what is held and why will be explained to you.
- Right to Data Portability. You may request to obtain and reuse your personal data for your own purposes across different services. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The Right to Data Portability only applies:
- To personal data you have provided to XL Global Group ;
- Where the processing is based on your consent or for the performance of a contract; and
- When processing is carried out by automated means.
In these circumstances XL Global Group will provide a copy of your data in CSV format, free of charge, without undue delay and within one month. If there is a delay to this, you will be informed.
- Right to Object. You have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling); and
- Processing for purposes of scientific/historical research and statistics.
XL Global Group do not participate in the first and third activities, however do conduct marketing activities as explained above.
- Automated Decision Making and Profiling. XL Global Group does not employ any automated decision-making or conduct profiling of Data Subjects. However, if you have consented to be held on our Customer Relationship Management (CRM) data base we may periodically send you marketing information so that you are informed of upcoming events, training and updates to information within the membership forum. These will be automated but they do not involve automated decision-making or profiling.
What Information Do We Collect About You and Why? The information we collect from you enables us to fulfil your request for our products – namely, to send you products that you order and receive – to send you information or content in which you may be interested, and keep you abreast of any updates related to our Site. We also use this information to personalise and continually improve our Site.
Information We Collect Directly From You. You may browse our Site without registering. If you would like to place an order, then we require you to register with us and become a member on our Site so that we can fulfil your request. To register with us, we request your name and email address. As a part of the registration process, we will also ask you to select a password. In certain circumstances, such as when making a purchase, we will request that you provide your credit or debit card information and your billing and shipping address.
We may also use automated devices and applications, such as Google Analytics and Facebook Insights, to track usage of our Site. We may use the information gathered through these methods in anonymous or aggregated form to analyse ways to improve our Site. This information may also be associated with your username or email address and may be combined with other information, including personally identifiable information that we collect about you.
Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Site Analytics. As noted, we may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site, performance and user experiences.
How Do We Use Your Information? We may use the information that we gather about you to:
- To fulfil your orders or otherwise provide services related to your Account to you, to communicate with you about your use of our Site, your Account and/or products that we offer or make available through the Site, and for other customer service purposes.
- To respond to any inquiries, you submit to us.
- To carry out or enforce a transaction or agreement with us.
- To operate and improve the Site.
- Where permitted by law, for marketing and promotional purposes; for example, we may use your information, such as your email address, to email you news and our newsletters, special offers, and promotions.
- To better understand how users access and use our Site and Account, both on an aggregated and individualised basis, for the purposes of improving our Site.
- To acquire information about potential employees
Third Party Website Links. Our Site may contain links to other third party websites. Any access to and use of such linked websites is not governed by this Policy, but, instead, is governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.
How We Secure Information About You. We have implemented commercially reasonable precautions, including, where appropriate, password protection, encryption, SSL, firewalls, and internal restrictions on who may access data to protect our Site and the information we collect from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.
Changing Personal Information? You may modify any personal information that you have submitted by logging into the ‘My Account’ page and updating ‘Edit My Address’. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
Emails. We may send periodic emails to interested users regarding various promotions or other information that we believe may be of interest to our users. If we send you any news and newsletters, special offers, promotions or other information we think may interest you, you may tell us to stop sending you such e-mail communications by following the opt-out instructions contained in any such e-mail. Please note that it may take up to ten (10) days for us to process opt-out requests. Please note if you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account you have requested or received from us.