Policy Statement Last updated: 23 March 2023
Contact Details - if you have any questions or queries regarding your personal data and/or our processes, please contact our Data Protection Officer either by:
1. Who we are
CMC Partnership Global Ltd is a company registered in England and Wales. Our registered office is Grace Dieu Court, Dingestow, Monmouthshire, NP25 4EB United Kingdom. Our wholly owned subsidiaries are: CMC Partnership (Asia) Pte Ltd, CMC Partnership (Schweiz) GmbH, CMC Partnership Global SA (Pty) Limited and CMC Italy S.R.L.
We collect, process, store, disclose and protect personal information (information by which an individual can be identified) to perform our business activities and to primarily provide change management consultancy, training and coaching services, together with the recruitment and selection of permanent staff, suppliers and products required to deliver those services to you (the "Services"). Automated decision making or profiling is not carried out by CMC Global.
2. Personal data and the law
If you are based outside the UK, when we transfer your personal data to our sub-processors, we make use of the approved Standard Contractual Clauses ("SCCs") where applicable. In line with current legislative updates, we are in the process of updating from SCCs to International Data Transfer Agreements within the 2-year transition period permitted by the UK Government.
UK data protection law requires us to rely on one or more lawful grounds to process your personal information. We will only process your personal information on one of more of the following lawful grounds:
3. CMC Global's ICO registration
CMC Global Ltd is registered as a data controller with the ICO (Registration number ZB372171).
4. Personal data we collect from you
We typically collect, process and store the following types of personal information you provide to us:
In addition to the above, we also collect, process and store the following types of personal information depending on your relationship with us:
5. How we collect your personal data
You may choose to share your personal data with us by various means which may include but not be limited to making an online enquiry or by purchasing our Services through our website(s), or by attending one of our courses or workshops, visiting our website(s) through cookies, by sending us an email, by completing a survey, through a third party website for job applications, from third parties as your nominated referee, or by providing your details by letter or telephone, or by completing an internal form to support your employment or contractual status with us This may include subscribing to any of our Services; requesting newsletters, obtaining downloads, registering for events and online webinars, contacting us through social media channels, accounting and administration (business to business) or applying for an opportunity in which you may be asked to provide your full name, postal address, email and telephone numbers.
6. How we use your personal data
We use the personal data provided by you to provide our Services, fulfil your requests, improve our Services, engage in research and analysis relating to the Services we provide, personalise your experience, track usage of the Services, provide feedback to third parties that are listed on the Services, display relevant advertising, market our Services, provide customer support, contact you, for recruitment, back up our systems, allow for disaster recovery and to enhance the security of the Services.
We will store your contact data so we can provide you with information in regard to other CMC Global products and Services that you may be legitimately interested in. We may also contact you to ask you to complete surveys that we use for research purposes, although you do not have to respond to them. You have the option to unsubscribe from these communications at any time.
7. Who we share your personal data with
Where we have a legal basis to do so we may disclose some or all of your personal information to:
Please be assured that these sub-processors have contractual agreements in place which include data protection Standard Contractual Clauses. CMC Global's list of sub-processors is available to view here.
In the event of sale, merger, de-merger or other reorganisation of the businesses, your personal data will be shared and processed in accordance with the legitimate interests of CMC Global and the relevant third parties. In all cases data sharing will only take place when appropriate contracts, including confidentiality and/or data transfer obligations (where required) are completed with the planned recipient(s) of your data.
We will disclose your personal information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of use, or to protect the rights, property, or safety of our companies, our customers, or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction, or to comply with UK Government regulations.
8. Where your personal data is stored
The personal data that we collect from you is stored in professional datacentres within the UK, EEA and/or the United States of America (USA).
Your personal data may be transferred and stored in the USA, and managed by the following sub-processors who support us in carrying out our Services to you:
Employee and contractor personal data may be shared with third parties and transferred to their storage and sub-processing destinations to support customer delivery arrangements including business travel, etc. CMC Global's list of sub-processors is available to view here.
9. How long we keep your personal data
If you contact us, we may keep a record of that correspondence and we may retain details of your visits to our website(s) including, but not limited to, traffic data, location data, weblogs and other communication data and a record of the resources you access.
We may keep a record of your website preferences and interests, other information relevant to customer surveys, offers made by us and details of the transactions you complete through the website and the fulfilment of your orders.
Data is retained for a maximum of 7 years with the following exceptions
10. Accuracy of your personal data
We make every effort to maintain the accuracy and completeness of your personal information. However, you can assist us by contacting us if there are any changes to your personal information, or if you become aware that we have inaccurate personal information relating to you. We will not be responsible for any losses arising from inaccurate, inauthentic, deficient, or incomplete personal information that you, or a person acting on your behalf, provides to us.
If you believe that any information we are holding about you is incorrect or incomplete and require it to be amended, please contact us using the contact details in our Policy Statement above.
11. Your rights
Under UK data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal information:
You can contact us at any time by using the contact details provided in the above Privacy Statement regarding an of your rights detailed above. You can also tell us at any time to not send you marketing communications by email, by using the contact information in the Privacy Statement, or by clicking on the unsubscribe link within the marketing emails you may receive from us.
12. Protecting your personal data
We are committed to ensuring that your information is secure. We have reasonable technologic and organisational security measures in place to protect your personal information from unauthorised access, use, alteration and disclosure. We are pleased to be Cyber Essentials certified (a UK Government backed scheme that helps to protect an organisation against a whole range of the most common cyber-attacks). Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk.
Once your personal information is received it is managed in line with recognised industry security good practice to safeguard it as best we can, but we cannot guarantee that the security measures we have in place will never be defeated or fail, or that such measures will always be sufficient or effective.
14. IP addresses
When you access our website, use any of our mobile applications, or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet. We may use IP addresses for system administration, investigation of security issues, and compiling data regarding use of our website, including the completion of web-forms and downloads, and/or mobile applications.
15. Cookies - what they are and how we use them
A cookie is a small file which asks permission to be placed on your computer records. Most browsers are initially set up to accept HTTP cookies. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Cookies on CMC Global’s websites (www.cmcpartnership.com, www.cmcpartnership.sg, www.cmcpartnership.it and www.cmcpartnership.com/en-za) are used for a variety of different purposes, but generally speaking their use breaks down into the following categories:
Removing and managing cookies
To ensure that you are in control of your privacy at all times, all web browsers give you the option to disable cookies. Most browsers are initially set up to accept HTTP cookies. For more information about HTTP cookies and how to disable them the following links may be helpful, or you can use the “Help” option in your browser which should tell you how to stop accepting new cookies.
16. Useful links
If you would like to find out more about privacy, cookies and their use on the internet, you may find the following links useful: