PRIVACY NOTICE
Please also use the Glossary at the end of this privacy notice to understand the meaning of some of the terms used in this privacy notice.
(a) IMPORTANT Information AND WHO WE ARE
1.1 Purpose of this privacy notice
1.1.1 This privacy notice aims to give you information on how MROI Consultancy LTD (referred to as “we”, “us” and “our” in this privacy notice) collects and processes your personal data when you engage us to provide you with services, via your use of our website, mroi.co.uk, or otherwise.
1.1.2 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2 Controller
1.2.1 MROI Consultancy LTD, a private limited company incorporated in England and Wales under company number 11865064 and whose registered office is at Beehive Cottage, Swan Green, Emery Down, Lyndhurst, Hants, SO43 7DT is the controller and is responsible for your personal data.
1.2.2 If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Email address: maggie.r@mroi.co.uk
Postal address:Beehive Cottage, Swan Green, Emery Down, Lyndhurst, Hants, SO43 7DT
Telephone number: +44(0)7850668341
1.3 Registration. MROI is registered as a data controller on the ICO’s data protection register.
1.4 Right to make a complaint – You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.5 Your duty to inform us of changes – It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2 THIRD PARTY LINKS
Our website and any other materials that we may provide to you from time to time may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3 THE DATA WE COLLECT ABOUT YOU
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store, process and transfer different kinds of personal data about you (this includes any personal data which you may volunteer to us in the provision of our services to you) which we have grouped together follows:
3.2.1 Identity Data includes first name, last name, title, any previous names, marital status, title, date of birth, gender and other identification details, visa details, employment details & history and qualifications, adverse media checks, and other information provided or collected as part of our consultant take on process and as a result of individuals’ interactions with us in the course of our business.
3.2.2 Facilitation Data includes any information you provide us during a session/programme, such as your age, gender, marital status, health conditions, ethnicity and other information you may provide us or that we may have access to as part of the provision of our services. We do not share this data with anyone else and this type of data is only recorded by us in the strictest confidence and only as necessary to provide you with our services.
3.2.3 Demographic Data includes your location, and other information provided or collected as part of our client take on process and as a result of individuals’ interactions with us in the course of our business.
3.2.4 Contact Data includes your email address and telephone number.
3.2.5 Financial Data includes your payment card and bank account details.
3.2.6 Technical Data includes your internet protocol (IP) address.
3.2.7 Profile Data includes services for which we have been engaged by you (including in the past), your interests, preferences, feedback and any survey responses, or services for which we have engaged you to provide us.
3.2.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.3 Our website is hosted on WordPress. WordPress collects, uses and shares non-personally-identifying technical data and usage data, such as the browser type, language preference, referring site, and how a visitor to the site uses the website. Such data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. Please see WordPress’s privacy policy here for more information.
3.4 We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Profile Data to calculate the percentage of our customers using a particular service or we may aggregate your Demographic Data to evaluate and improve our services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3.5 We do not request any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we request any information about criminal convictions and offences. However, you may volunteer to provide us with such information in the course of our business relationship with you and/or in the provision of our services. To the extent applicable, should you provide us with any Special Categories of Personal Data, criminal convictions and offences data or other personal data you must ensure that you have all necessary appropriate consents and notices in place to enable the lawful transfer of such personal data and the lawful collection of the same by us for the duration and purposes of and in connection with the provision of our services or otherwise as relevant to our business relationship.
3.6 If you fail to provide personal data – Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our services). In that case, we may have to cancel the provision of services to you but we will notify you if that is the case at the time.
4 HOW IS YOUR PERSONAL DATA COLLECTED?
4.1 We use different methods to collect data from and about you including through:
4.1.1 Direct interactions. You may give us your personal data by corresponding with us by post, phone, email, filling in forms on our website or otherwise. This includes personal data you provide when you:
4.1.1.1 instruct us to provide you with any of the services we offer;
4.1.1.2 provide us with information in order to allow us to provide you with our services or otherwise fulfil our obligations pursuant to any contract we have with you;
4.1.1.3 or your personnel engage with us in the provision of our services;
4.1.1.4 engage with us on our social media;
4.1.1.5 apply for a position with us, and if successful, become a consultant of ours (and provide us with information in connection therewith such as such as proof of identification and residence, for the purposes of our due diligence and compliance obligations); or
4.1.1.6 give us any feedback.
4.1.2 Our clients. Our clients may give us personal data of their personnel to enable us to provide our services. Any personal data we receive, will be processed in accordance with this notice.
4.1.3 Automated technologies or interactions. If you interact with our website, WordPress who hosts our website may automatically collect your Technical Data. WordPress collects this personal data by using cookies and other similar technologies. Please see WordPress’s cookies policy here for further details.
4.1.4 Psychometric third party service providers. We may receive personal data about you from our third party psychometric providers who provide us with certain tools, questionnaires and tests that we may request you to complete from time to time to assist us in delivering our services to you (such as the 360 feedback). Such providers do not collect Special Category Data. In order to access the tools, questionnaires and tests provided by each provider, each provider requires the person supplying the data to have agreed to their data protection policies. Each provider is listed below with a link to their privacy policies (please note that such policies are updated from time to time by the relevant provider – please see the section ‘third party links’ for further information):
4.1.4.1 Clarity 4D – http://www.clarity4d.com/privacy-statement
4.1.4.2 Myers Briggs – https://www.16personalities.com/terms/privacy
4.1.4.3 Hogan Assessments – https://www.hoganassessments.com/privacy-policy
4.1.4.4 Prophet profiling – https://www.prophetprofiling.com/data-policy
4.1.5 Third parties or publicly available sources. We may receive personal data about you from other third parties and publicly available sources, such as Companies House.
5 HOW WE USE YOUR PERSONAL DATA
5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
5.1.1 We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
5.1.2 Where we need to perform the contract we are about to enter into or have entered into with you.
5.1.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (unless we have your consent or are otherwise required or permitted to by law).
5.1.4 Where we need to comply with a legal or regulatory obligation.
5.2 Purposes for which we will use your personal data
5.2.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
5.2.2 Please note that while different lawful bases might apply to different purposes/activities, only one lawful basis is relied upon per specific sub-purpose/activity. Please contact us via the means set out in paragraph 1.2.2 above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
Lawful basis for processing criminal offence data and special category data |
|
To onboard you as a new client |
(a) Identity Data (b) Contact Data (c) Financial Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (in order to provide you with our services) |
|
|
To onboard you as a new consultant |
(b) Identity Data (c) Contact Data (d) Financial Data (e) Profile Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (in order for you to provide us with your services) |
(a) Information manifestly made public (b) Explicit consent |
|
To provide you with our services |
(f) Identity Data (g) Contact Data (h) Financial Data (i) Profile Data (j) Demographic Data (k) Facilitation Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (in order to provide you with our services) |
(c) Information manifestly made public (d) Explicit consent |
|
To administer, monitor and manage our relationship with you including: (a) ongoing monitoring and to maintain our records (which includes carrying out (to the extent appropriate and relevant) searches and checks relating to identity) (b) notifying you about proposed changes to this privacy notice (c) asking you to leave a review of our services or take a survey (d) legal advice, legal proceedings, such as relating to any investigations and litigation |
(a) Identity Data (b) Contact Data (c) Marketing and Communications Data (d) Profile Data (e) Facilitation Data (f) Financial Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (such as legal proceedings) (c) Necessary for our legitimate interests (to keep our records updated, to ascertain how our customers use our services and to develop our services and grow our business) |
(a) Information manifestly made public (b) Explicit consent (c) Establishment, exercise or defence of legal claims (d) Vital interests |
|
To meet our professional, legal and regulatory obligations and to meet our insurance and audit requirements |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Facilitation Data (e) Financial Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (including in the course of liaising with regulators and other authorities) (c) Necessary for our legitimate interests (for running our business, to keep our records updated) |
(a) Information manifestly made public (b) Explicit consent (c) Vital interests |
|
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Facilitation Data |
(a) Necessary for our legitimate interests (for running our business, network security and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (including in the course of liaising with regulators and other authorities) |
|
|
To deliver relevant content and advertisements/marketing to you and measure or understand the effectiveness of the content and/or advertising/marketing we provide to you |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Marketing and Communications Data |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we provide to you |
|
|
To maintain our business relationship with you including communications with respect to prospective opportunities, including making suggestions and recommendations to you about our services that may be of interest to you (including those of third parties) |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Marketing and Communications Data |
(a) Necessary for our legitimate interests (to develop our services and grow our business) (b) You have provided your explicit consent |
5.3 Services offers from us – We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
5.4 We may use your Identity Data, Contact Data and Profile Data to form a view on services that we think you may want or need, or what may be of interest to you and to assist with our general relationship building with you. This is also how we decide which services may be relevant for you (we call this marketing).
5.5 You may receive marketing communications from us if you have a pre-existing business relationship with us (for example, you have requested information from us) or you have or engaged us to provide you with services and, in each case, you have not opted out of receiving that marketing.
5.6 Third-party marketing – We do not share your personal with any other company for marketing purposes. We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
5.7 Opting-out – We generally do not send marketing messages. However, from time to time where we do so, you can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us via the means set out in paragraph 1.2.2 above.
5.8 Cookies
5.8.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive.
5.8.2 As mentioned above, we do not use any cookies on our website, but our website hosting provider may do. We generally do not have access to any such data that is collected. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our website. For more information about the cookies WordPress uses and how to change your cookie preferences, please see theircookies policy here.
5.9 Change of purpose
5.9.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via the means set out in paragraph 1.2.2 above.
5.9.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.9.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6 DISCLOSURES OF YOUR PERSONAL DATA
6.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.2.3 above.
6.1.1 Internal Third Parties as set out in the glossary to this privacy notice.
6.1.2 External Third Parties as set out in the glossary to this privacy notice. From time to time we may share certain of your personal data with our third party psychometric test providers as mentioned above.
6.1.3 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
6.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7 INTERNATIONAL TRANSFERS
7.1 We do not regularly transfer your personal data outside the UK as our hosting servers are based in the UK.
7.2 However, we work with a number of consultants, some of which who are based outside of the UK, such as Brazil, and we may also transfer your personal data to certain service providers that carry out certain functions on our behalf, such as our psychometric third party service providers. In each case, this may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer your personal data outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
7.2.1 The transfer of your personal data to countries that have been deemed, in accordance with applicable data protection laws in the UK, to provide an adequate level of protection for personal data. The UK has adequacy regulations in respect of European Economic Area countries.
7.2.2 Where we use certain service providers or where any of our consultants are based overseas (such as in Brazil), we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (such as the International Data Transfer Agreement).
7.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8 DATA SECURITY
8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9 DATA RETENTION
9.1 How long will you use my personal data for?
9.1.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.1.2 To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9.1.3 Details of retention periods for different aspects of your personal data can be obtained by contacting us via the means set out in paragraph 1.2.2 above.
9.1.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information.
9.1.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10 Your LEGAL rights
10.1 Under certain circumstances, if you are an individual, you have rights under data protection laws in relation to your personal data as set out below:
10.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
10.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
10.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
10.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
10.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
10.1.5.1 If you want us to establish the data’s accuracy.
10.1.5.2 Where our use of the data is unlawful but you do not want us to erase it.
10.1.5.3 Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
10.1.5.4 You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
10.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us via the means set out in paragraph 1.2.2 above.
10.2 No fee usually required – You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.3 What we may need from you – We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.4 Time limit to respond – We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11 GLOSSARY
11.1 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
11.2 Internal Third Parties means our employees, officers, contractors and consultants who may assist us with providing you with our services.
11.3 External Third Parties means:
11.3.1 Psychometric services providers who provide us with psychometric tools, questionnaires and tests that we utilise in the delivery of our services to you.
11.3.2 Service providers acting as data processors who provide us with payment processing, IT and system administration services.
11.3.3 Professional advisers including bankers, solicitors, auditors, accountants, book keepers and insurers, who provide us with banking, legal, insurance and accounting services (as appropriate).
11.3.4 HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
11.4 Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via the means set out in paragraph 1.2.2 above.
11.5 Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Reviewed April 2025
