Last updated 21 September 2017, in accordance with the requirements of the General Data Protection Regulation (GDPR).
Our approach to privacy
No action is required by you to protect your privacy, and we will request your specific consent whenever there is a need for us to collect, process or share any information about you that could be used to identify you or profile your online behavior.
Lane4 operates on the basis of Privacy by Design, which means that we ensure that privacy protection for the users of our services is embedded into the design and architecture of our marketing functions, IT systems and overall business practices. This is achieved by making privacy our default setting.
In addition to consent, we also collect and process some personal data in order to carry out some of our basic business functions. This is referred to as “legitimate interests” in the Data Protection rules.
What information do we collect?
Some of our services require you to provide personal information, and we may ask you for contact details such as your name, email address and telephone number. Depending on the service we are delivering to you or your company, we may also ask for information about your employment.
We gather and use certain information about individuals in order to provide products and services and to enable certain online functions via our website. We also collect information to better understand how visitors use our website and to present timely, relevant information to them. Please be aware that any information collected may be transmitted over the internet and is hosted securely on our servers in the UK and Europe.
Some of the information we may collect includes the following:
- Your name
- Contact information including email address
- Website usage data
- Other information relevant to client enquiries, customer surveys and/or offers
Some of the products and services we provide, such as a personality profile or 360 survey, may also require us to collect other data which could include:
- Job title
- Time in team
- Preferences and interests
- Length of employment
- Demographic information, such as postcode
- Other demographic data as agreed with your employer as part of the survey
What do we do with your information and how is it collected?
The information we collect will be used principally to deliver contracted services and products to meet your requirements, and only for the stated purposes. We collect information in a couple key of ways:
- When using our website to register for a webinar, or download a white paper.
- When taking part in a service as part of a development programme we are contracted to deliver.
When using our website to register for a webinar, or download a white paper, the data collected via our website may be used for the following purposes:
- For our own internal records
- To improve the products and services we provide
- To contact you in response to a specific enquiry
- To customise the website for you
- To send you promotional emails about products, services, offers and other things we think might be relevant to you
- To send you promotional mailings or to call you about products, services, offers and other things we think might be relevant to you
- To contact you via email, telephone or mail for market research reasons.
We retain all of the information collected from our website. We do not divulge your information to third parties outside of the company without your prior consent, unless it is necessary to provide any requested services.
When taking part in a service (e.g. diagnostic, survey, workshop) as part of a programme we are contracted to deliver, the information you provide will only be used for the stated purposes and never for marketing.
This may include product research & development, administrative and legal purposes, statistical analysis, systems testing, or service maintenance and development. This information will either be anonymised to prevent you being identified, or deleted after 2 years.
We may need to provide this data to a licensed practitioner (an independent practitioner licensed to deliver Lane4 solutions), or a client practitioner (a colleague in your organisation licensed to deliver Lane4 solutions) if you are completing a diagnostic survey or psychometric test delivered by either party for learning & development. Either of these scenarios may involve transmitting your data to a different country.
Lane4 will only keep data for as long as is necessary to meet these purposes. We will never share, sell, or rent individual personal information with anyone without your advance permission, or unless ordered by a court of law. Your submitted information is only available to employees and contracted service providers managing this information for purposes of contacting you based on your preferences. If required by law, Lane4 may disclose data to government and/or enforcement agencies.
If we intend to use your data for a new purpose outside of those detailed in this policy, we will ask for your consent. Lane4 will never supply your data to third-parties for marketing purposes.
Transmitting your data internationally
Lane4 works with licensed practitioners in different countries, and it is sometimes necessary to transmit your data internationally to deliver the services to meet your requirements. If it is necessary to do so, we will ensure an adequate level of protection is in place to safeguard your data.
Data collected by Lane4 may be stored and processed in another country, including a country that is not in the European Economic Area (EEA). Some countries may not have data privacy laws as strong as those in force in others. We will ensure that the data protection standards employed within the European Union (EU) are observed by our partners with whom we need to share information in all of the countries they operate.
Some safeguards we will implement could include the use of Binding Corporate Rules, or an intra-group agreement to provide a general justification for cross-border data transfers. These safeguards are intended to ensure that, post-transfer, your data is processed in compliance with data protection requirements of the European standard. In some instances, we may seek authorisation from the Information Commissioner’s Office (ICO) prior to a cross-border data transfer.
Keeping your data secure
We are committed to ensuring that your personal information is secure, and we follow strict policy standards of security when gathering, storing and transmitting your personal information. Our website and online services are protected by firewalls to prevent your personal information from being stolen, destroyed or divulged to third parties. We employ the use of secure cloud-based systems to store data, and restrict internal access from unauthorized staff.
Lane4 has implemented security policies, rules and technical measures to protect the data in our control. These security measures are designed to prevent unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
Any information you provide us with when using our website is stored centrally on a secure database. Direct access to this database is restricted to authorised staff and their appointed agents only. We have taken every reasonable step to ensure that your information is held securely at all times, and that access to it is closely monitored. We use security measures to protect against the loss, misuse and alteration of data used by our system.
Please be aware however, that no internet or email transmission is ever fully secure or error free. You should take special care in deciding what information you send to us via email, and keep this in mind when disclosing any personal data to us via the Internet.
For more information on cookies, please visit: www.aboutcookies.org
- Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.
- Identify whether you are signed in to our website. A cookie allows us to check whether you are signed in to the site.
- Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
- Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
- To recognise when you return to our website. We may show your relevant content, or provide functionality you used previously.
Controlling your information
You have the right to request at any time to see the data we hold about you, or the right to request that we change or delete any data we hold on you. If you require this, please contact firstname.lastname@example.org.
It may take up to 40 days for us to action your data requests.
Under data protection laws, you may request details of personal information which we hold about you. A small fee will be payable for us to action these requests. If you believe that any information we are holding about you is incorrect or incomplete, please email us as soon as possible at email@example.com.
You can also use this email address for any of the following:
- To query any aspect of the data or process if you have completed a diagnostic or personality survey with us.
- To request that we delete any data we hold on you, or if would like a copy of the information held then please email.
Who has access to your data?
The data we collect about you is generally accessed only by authorised Lane4 staff for legitimate business purposes and providing contracted services. However, if we work with partners or contractors, they may have limited access to your personal data but only so much to do their job.
If a delegate has completed a Talent Management or personality diagnostic, the profile produced from this data will only be provided to the delegate and will not be shared with anyone else without their prior consent. For example, at a Workshop we would not share anyone’s profile with a group of their peers. During a workshop, an individual may be invited by the Lane4 accredited facilitator leading the session to share some information from their profile with the group and that is their personal choice.
The following outlines who has access to your data, and under what circumstances:
- Lane4 staff who are involved in providing the services to you (where privacy is legally covered under our contract of employment);
- A third-party contractor who is professionally Accredited and contracted by Lane4 to provide the services to you and therefore bound under terms within their contract relating to confidentiality and privacy that is to the same standards and level as Lane4 staff; or
- An Accredited Practitioner employed by the client company. That person is known as a Lane4 ‘Client Practitioner’ and Lane4 provides clear guidance on privacy requirements that is to the same standard as for Lane4 staff. That employee will also have a contract of employment that will address handling confidential information. Should the Client Practitioner allow any other member of staff employed by the customer to handle any personally identifiable information (e.g. a member of administration staff is allowed to access the Lane4 software and our online systems in order to produce the profiles) then again, that employee is bound by their normal terms of confidentiality in their contract of employment.
Links from our website
Our website may contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over the other websites and are not responsible for the privacy practices of such other websites.
If you provide information to a website to which we link, we are not responsible for its protection and privacy. Always exercise caution when submitting data to websites. Read the site’s data protection and privacy policies fully.
Please ensure you regularly review the information posted online to obtain timely notice of such changes. Your continued use of this website after amendments are posted constitutes your acceptance of this policy as modified.
How to contact us
If you have any questions regarding this policy, you can write to us at:
Lane4 Management Group Limited
St Mark’s House