MDA Training Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who uses our psychometric Assessment and reporting (“Services”) and our website, www.mdatraining.com (“Site”), and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site and Our Services. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and the Data Protection Act 1998 (“UK Act”).
means MDA Training Limited, a limited company registered in England under company number 2192786, whose registered address is Suite 3, Metropolitan House, 38-40 High Street, Croydon, Surrey, CR0 1YB.
Information About Us
MDA Training Limited of Suite 3, Metropolitan House, 38-40 High Street, Croydon, Surrey, CR0 1YB. is a data controller for the purpose of the Data Protection Act 1998 and GDPR with respect to personal data about you that we receive from you and/or from our clients. We may also act as a data processor depending on how we are using the data that we receive from you.
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 8);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 9);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 5 but if you would like Us to delete it sooner, please contact Us using the details in section 9);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 9 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
We process information about you which is necessary for the purposes of the provision of Our Services. We may provide these Services to you as the person or company that has purchased our Services (“Client”) or you may provide responses (“Participate”) in any of our psychometric Assessments (“Assessments”) as a Participant for whom one of our Clients has requested an Assessment.
You may give us information about you by filling in forms on our website at Our Site, by corresponding with us by phone, email or otherwise, or through our psychometric Assessment platforms.
You may provide personal information to us when you register to use our Site, complete one of our Assessments, subscribe to our information services, enter a competition, promotion or survey, and when you report a problem with our Site.
Information you give us when using our site
The information you give to us when using Our Site may include your name, occupation, company for which you work, business address, home address, email address and phone number, financial and credit card information, and biographical information.
With regard to each of your visits to our Website, we may automatically collect the following information:
- technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- traffic data, location data, weblogs and other communication data, required for our own billing and administration purposes;
- usage data, such as the source address that the page request is coming from, including your Internet protocol (IP), domain name, date and time of the page request, the referring website (if any) and other parameters in the URL (e.g. search criteria); and
- information about your visit, including: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page; and any phone number used to call our customer service number.
If you contact us, we may keep a record of that correspondence.
Information you give us when participating in assessments
Clients may provide personal information about you in relation to Assessments in which they would like you to Participate. This information may include a Participant’s name, email address and other contact details. You may also provide such information and/or additional information to us as a Participant.
When you Participate in an Assessment we will ask you to provide responses that may constitute personal data. We categorise such data as follows:
• “Identification Data” which means information such as your name, email address and other contact details;
• “Assessment Data” which means your responses in Assessments, this may include information such as:
• interests; and
• behaviour in the workplace.
• “Research Data” which means responses to questions about you and which will include information such as:
• your gender;
• your age;
• your cultural background;
• your qualifications;
• your work experience; and
• details regarding your employment, responsibilities and work.
Research Data may include sensitive personal data (as defined in the UK Act). Research Data does not form part of the Assessment and is only used for research purposes (once aggregated and anonymised) in order to monitor our tests and questionnaires for fairness and maintain a high standard of Assessment.
Where an Assessment will ask you to provide Research Data, we will ask for your explicit consent to collect and process such information in a data protection notice and further information is provided at the point at which such information may be provided by you. You will have the opportunity to refuse or omit to provide such Research Data.
If you participate in any Assessments, we may ask you to provide Research Data. You do not need to provide all of the Research Data that we ask for; however, we would be grateful if you could complete all the questions as this will help us to monitor our tests and questionnaires for fairness and maintain a high standard of Assessment. Your ability to complete an Assessment will not be affected by your choice not to provide such Research Data, nor will this choice affect your Assessment results.
You must provide Identification Data as this is required in order for us to administer the Assessment, provide the results to the Client who requested that the Assessment is made available to you, and for the purposes set out in the section 5.
How Do We Use Your Data?
Information you give to us when using our Site
We will use information you give to us in the course of providing Services to you as a Client for the following reasons:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and Services that you request from us and billing you for the products and services provided;
• to provide you with information about further Assessments, reports and services we offer that are similar to those that you have already purchased or enquired about;
• to notify you about changes to our service.
Personal information provided by you in relation to each of your visits to our Site will be used:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to better understand Website usage including what areas of our Website users prefer;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer; and
• as part of our efforts to keep our site safe and secure.
This information is stored in log files and is used for aggregated and statistical reporting.
Information you give to us when Participating in an Assessment
We process Identification Data and Assessment Data provided in relation to your Participation in Assessments for the purpose of providing Services to our Clients. This may include processing this data in order to:
• identify your Assessment and responses;
• assess your aptitudes and preferred working styles;
• produce Assessment reports for our Client who has made this Assessment available to you.
We may process Research Data for research purposes. We research responses to our Assessments in the light of areas such as gender, age and cultural background over the longer term; this is considered best practice and allows us to monitor our Assessments for fairness in use.
The Research Data that we collect goes through the process of aggregation and anonymisation. Our research is then based on this anonymised and aggregated group level data only. The Research Data that is personally identifiable to you is not individually disclosed to any Client or any third parties.
If you complete the Assessment in a jurisdiction that prohibits completion of such Research Data you should not complete those details to the extent such law prohibits doing so, though we would be grateful if other details were completed.
We may also process your personal information for the purposes of using and refining Assessment tools, analysis, accounting, billing and audit, credit or other payment card verification, security, administration, enforcing and defending legal rights, systems testing, maintenance and product development, customer relations, performing our obligations to you; our Participants and our Clients whether under contract or otherwise, and to help us in future dealings with you.
The Assessment reports and services we provide to our Clients may be used by them for purposes which may include the selection and development of individuals in an employment or human resources context.
We may also provide a copy of the Assessment Data to our Clients for use by them for their own internal human resource management purposes.
Clients are entitled to use the personal information that we provide to them as part of our Services for their own purposes; however, such Clients are obliged to process such personal information in accordance with their own obligations under the UK Act, other data protection laws (as applicable). You will have rights with respect to the manner in which our Clients process such personal information provided by us to them.
Third Party Contact Details
As part of our Assessment process, we may request or you may volunteer contact details of a third party, for example, someone who can answer questions about your work in order to generate a 360 feedback report. You should inform such third party that you intend to disclose this information and obtain their prior consent to such disclosure.
We do not send marketing communications to Participants who are only registered as Participants; however we may contact you if you have provided us with your contact details and are a Client or prospective Client of our Services.
If you do not wish to receive any marketing communications we may send to you from time to time, please let us know at any time by emailing us at firstname.lastname@example.org.
How long do we keep information about you?
We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
Do We Share Your Data?
Information about you will be disclosed to our Clients in the context of the provision of Services to them in connection with the Assessment(s) in which you have Participated.
To facilitate the Assessment process, information about you may also be passed to other companies within from time to time and their respective suppliers from time to time which includes providers of:
• systems to facilitate the service such as email services and enquiry response services;
• cloud based services;
• human resource and other Assessment services;
• web based accounting systems; and
• professional advisors and auditors.
We may also pass data containing your information but which is not identifiable to you in an anonymised and/or statistically aggregated form to our approved agents as described above, current or future potential Clients or research institutions.
Due to the international nature of internet-based Assessment and training services, we may from time to time appoint third parties to process data containing information about you on our behalf as a data processor, or store such information in, or transfer it to persons located in, countries outside of the European Economic Area (“EEA”). These countries may not have data protection laws equivalent to those which are in force in the EEA to protect your information. Where we transfer your information to such third party data processors and/or third parties outside of the EEA, we shall ensure that they provide sufficient guarantees in respect of the technical and organisational security measures, and take reasonable steps to ensure their compliance with those measures in order to ensure your information is adequately protected in accordance with the UK Act and GDPR.
We may disclose your personal information to third parties:
• In the event that we sell any part of our business or assets of our business, in which case we may disclose your personal data to the prospective buyer of the business or assets. We may also disclose your personal data to a vendor of another business or assets that we are acquiring or to a joint venture or merger partner.
• If our assets are acquired by a third party, personal information held about our Clients and Participants will be one of the transferred assets.
How Can You Access Your Data?
You are entitled to see the personal information that we hold about you. You may ask us to make any necessary changes to ensure that personal information about you is accurate and kept up to date, this of course does not apply to any of your Assessment Data.
If you would like:
• any further information about the personal information that we collect, the purposes for which we collect it and how we protect it;
• to verify information we hold about you; or
• a copy of the information we hold about you,
then please write to us at: MDA Training Limited of Suite 3, Metropolitan House, 38-40 High Street, Croydon, Surrey, CR0 1YB., or email us at email@example.com. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.