Introduction to the Training Data Protection Notice

Please read this Training Data Protection Notice (“Notice”) to continue. It sets out how and why your Employer and SHL collect your personal information. For any defined terms which are not defined on this page, please see the definitions included within the Notice.

Please read the entire Notice carefully.

If you have questions about this Notice, please email dataquestions@shl.com.


Training Data Protection Notice

This Notice was last updated 14 May 2018.

  • Who we are

This Notice describes how;

  • your Employer (“Employer”); and
  • SHL Group Limited of The Pavilion, 1 Atwell Place, Thames Ditton, Surrey KT7 0NE, England (together, SHL or we or us)

respectively use your information collected through this online training.

SHL will process and collect information about you when you complete SHL Training (“Training”) in accordance with this Notice. Some information is (“Personal Information”), personal information about you or from which we can identify you.

This Notice also covers us, and our affiliated group of companies, where we are data controller. Each group company is a data controller and we’ve listed them here.

This Notice sets out the way the Employer and SHL use your information: what is collected, how it is collected, how it is used, why it is used, who it is shared with and the rights to which you will be entitled.

Section 2 (Employer as the Data Controller) provides further information on processing of your personal information by the Employer as the data controller.

Section 3 (SHL as the Data Controller) describes processing of your Personal Information by SHL for our own purposes as data controller.

Section 4 (The Employer and SHL as the Data Controller) provides additional information on who SHL and the Employer share your data with and an overview of your rights under data protection law.

2          Employer as the Data Controller

SHL collects your Personal Information on behalf of your Employer. If you have a query as to the identity of the Employer, please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice

The Employer will be the data controller in respect of your Personal Information and the Employer will decide what data is collected, the purposes for which it is collected and who it is shared with.  You will be able to exercise your rights directly against the Employer in respect of this Personal Information (see section 4 (The Employer and SHL as the Data Controller) for more information)).

The data collected

We collect and process the categories of data on behalf of the Employer as set out below. The categories of data which are collected about you vary depending on the type of Assessment and instructions we receive from the Employer. Not all the categories of data listed below may be collected about you. If you require further information as to the extent of the data that is collected you should contact the Employer directly.

What we collect

Information that you give us and the Employer when you complete an Assessment, including:

  1. “Candidate Data” which includes your:
  • name;
  • email address; and
  • account log in details.
  1. “Training Data” which are your responses to any Training or Learning provided.

Using the Candidate Data and Training Data, we generate the (“Results Data”), which includes the results of your Assessment.

What we do with the data

We use your Candidate Data, Training Data and Results Data, on behalf of the Employer to:

  1. use the Results Data to compile a report given to the authorised representatives of the Employer
  2. provide our services to you / the Employer; and
  3. manage and administer our services.

Why this data is collected and how long it is retained by us

We hold and process your Candidate Data, Training Data and Results Data in accordance with the Employer’s instructions. The reasons why the Employer collects your Personal Information will vary but generally, the Employer will instruct us to process your Personal Information because you are completing a training or learning initiative.  

We will keep your Personal Information on behalf of the Employer in accordance with the Employer’s instructions. The period of time that we are instructed to hold your Personal Information, varies from Employer to Employer. We will not delete your Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

You should contact the Employer directly if you require more information on this section

Data Sharing

We will only share your Personal Information processed on behalf of the Employer with the Employer and on the Employer’s instructions. The Employer may share your Personal Information with other third parties including its group companies and those parties listed at section 4. You should contact the Employer for more information on who they share your Personal Information with.

  •  
  • SHL as the Data Controller

When you complete Training we will collect Personal Information about you for the purposes outlined below. We will be data controller in respect of this information and we will be responsible for your Personal Information including for what purposes your information is collected and used.

If you have any questions on the processing of your data by SHL as data controller you can contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

What we collect

  1. Information that you or the Employer give us when you complete Training: including your Candidate Data, Training Data, and Results Data.

 

  1. Technical Information relating to the systems you used to take the Training including:
  • browser types;
  • operating systems;
  • IP addresses;
  • Date / time stamps.
  1. We also collect your country of residence (Country of Residence Information).

How we use it

  1. We use your Training Data, Results Data, Employer Provided Data, and Candidate Data to provide a record of the training that you have completed certifying your level of knowledge.

 

  1. We use your Technical Information to primarily provide you or the Employer with service support and for our own purposes including to identify issues with the training and your experience of it.

We collect your Country of Residence Information because we have a legitimate interest to comply with legislation applicable to the SHL group, in particular US Trade Sanctions law.

Why we use it

We use your Training Data, Results Data, Employer Provided Data, and Candidate Data in order to confirm your level of training you have completed certifying your level of knowledge.

Technical Information because we provide technical support to the Employer as well as individuals who reach out to us using our web help form and we have a legitimate business interest in understanding how our training is accessed, how it is used and any problems users have with them across multiple devices.

If you require further information regarding our legitimate interests as applied to your personal data, you may contact please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice

We will also process your Personal Information if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims against us.

How long we keep it

We keep your Training Data, Results Data, Employer Provided Data, and Candidate Data, perpetually in order to be able to confirm that you have obtained a certain level of training.  We will not delete your Personal Information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

Where your Personal Information will be held

We store your Personal Information in data centres located in the United Kingdom.

We are happy to provide you with copies of the regulator-approved SCCs, which you can request from the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice

When do we share Personal Information

We have set out the circumstances in which we will share your data with third parties below:

  • We will share a combination of your Assessment Data, Results Data, and any Employer Provided Data within our group companies when required to provide maintenance and support services and so that we can continue to improve the services we provide across the group.
  • We will also share your information with our trusted third party service providers, including our survey tool provider, IT security provider and cloud hosting platform provider. Our service providers will be required to meet our standards on processing information and security.
  • The Employer and SHL as the Data Controller

Data Sharing

The Employer and SHL as data controller will share your data with the following third parties in the below circumstances:

  • If we are discussing selling or transferring part or all of our business, Personal Information will be transferred to prospective purchasers under suitable terms as to confidentiality;
  • If we are reorganised or sold, Personal Information will be transferred to a buyer who can continue to provide services to you;
  • If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
  • If we are defending a legal claim your Personal Information will be transferred as required in connection with defending such claim.

Data Subject Rights

We’ve listed the rights you have over your Personal Information and how you can use them below. These rights are subject to exemptions in applicable law and will only apply to certain types of information or processing.  As described above, the Employer will be data controller so you should contact them directly if you want to exercise a right over data for which they are data controller.

For the Personal Information where we are data controller, you can exercise these rights by contacting the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice

  1. The right to withdraw consent: Where we or the Employer have obtained consent for some of the ways we use your information you can remove that consent at any time by contacting the Employer or the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.
  2. You can ask us to confirm if we are processing your Personal Information and, if we are, you can ask for access to that Personal Information as well as further details including why your data is being used and for what purposes.
  3. You can ask to correct your Personal Information held by us and the Employer if it is wrong.
  4. You can ask us and the Employer to delete your Personal Information.
  5. You can ask us and the Employer to restrict how we use your Personal Information.
  6. You can ask us and the Employer to help you move certain Personal Information to other companies. To help with that you have a right to ask that we or the Employer provide your Personal Information in a machine readable format to another company.
  7. You can ask us and the Employer to stop using your Personal Information, but only in certain cases. This applies where we are processing your personal information based on a legitimate interest (or those of a third party) and you can object to processing on this ground. However we will be entitled to continue processing your information based on our compelling legitimate interests.

You also have a right to make a complaint to a Supervisory Authority. Where we are the data controller you can contact the UK Information Commissioner’s Office; or the local data protection regulator in your jurisdiction.

Where the Employer is the data controller, you can contact the regulator in the location where the Employer is based.

Questions or Complaints

Questions about the results of your assessment or the Employer’s use of your Personal Information should be sent directly to the Employer at whose request you are taking the assessment.

If you have any questions about this Notice please contact the please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

Changes to the Notice

This Notice will be changed from time to time. If we change anything important about this Notice (the information we collect, how we use it or why) we will provide a prominent link to it for a reasonable length of time following the change.

If you would like to access previous versions of this Notice, please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice

Other policies

Security

We are committed to keeping your personal information safe. We have implemented physical, technical and administrative measures to help prevent unauthorised access or use of your information. Sanctions

SHL products and services are subject to US sanctions law. As a result, prohibited individuals, or those located in certain countries (Cuba, Iran, North Korea, Sudan and Syria), are not authorised to take assessments on our systems. Please contact us at dataquestions@shl.com with any questions.

SHL Data Protection Officer Contact Details:

Email: dpo@shl.com

Postal Address: Data Protection Officer, SHL Group Ltd, The Pavilion, 1 Atwell Place, Thames Ditton, Surrey, KT7 0NE, England.