We collect, use and disclose 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. Automated decision making or profiling is not carried out.
This policy is effective from 15 April 2021
An online version is available http://www.cmcpartnership.sg/privacy-policy
1. Personal data handling and the law
If you are based in the European Economic Area (EEA), when we transfer your personal data to our Sub-processors, we make use of the European Commission-approved Standard Contractual Clauses (SCCs) where applicable.
We will only process your information where:
You have given your consent to such processing by voluntarily providing us with your information, which you can withdraw at any time; The processing is necessary to provide our services to you;
The processing is necessary for compliance with our legal obligations; or
The processing is necessary for our legitimate interests, or those of any third party recipients that receive your personal information.
2. Information which we may collect from you
We typically process the following types of personal information:
Full name, email, address, phone number, project data (if applicable) and customer service interaction notes;
For in person training- dietary requirements, special requests and / or health issues (if any);
For job applications- employment verification information, including criminal record checks;
Learning and development records, including certifications;
Information to support your employment with us and provision of benefits; and/or
Information available from online open sources such as LinkedIn.
You may choose to share your personal data with us by making an online enquiry or purchase through our website/s, or by sending us an email, by completing a survey, or by providing your details by letter, by telephone, or by completing an internal form to support your employment or contractual status with the company. 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 name, address, email and contact numbers, etc.
If you contact us we may keep a record of that correspondence and we may retain details of your visits to the website 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.
3. Use of your information
We will use your personal information to contact you in response to your enquiry or application, or to support your continued employment/contractual arrangements with the company. We will store your contact data so we can provide you with information in regard to other CMC 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.
4. Location of your information
The data that we collect directly from you by email, hard copy, or through the use of our websites is stored in professional datacentres within the UK, EEA and/or the United States of America (USA).
Your data may be transferred and stored in a USA based datacentre managed by HubSpot who act as our contracted sub-processor for managing this service;
Your data (name and email address) will be shared with Prosci on your completed registration to attend a Prosci Change Management Training Event (see 5. Disclosure of your information). In this case your contact data will also be stored within a USA based datacentre managed by Prosci.
Your data (name and email address) may be shared with Teachable if you choose to attend a CMC Skills Builders workshop. (see 5. Disclosure of your information). In this case your data will be stored within a USA based datacentre managed by Teachable.
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.
Please be assured that these Sub-processors have contractual agreements in place which include EU data protection Standard Contractual Clauses. A full list of Sub-processors used by us can be provided on request.
5. Disclosure of your information
Where we have a legal basis to do so we may disclose your personal information to:
Any member of our organisation, this includes employees of our global subsidiaries: CMC Partnership (Asia) Pte Limited, CMC Partnership (Schweiz) GmbH and CMC Partnership Global SA (PTY) Limited.
Other third party contractors and suppliers including but not restricted to benefit providers, travel providers, IT service and data hosting providers, parties supporting remote working on customer sites and external business advisors, such as lawyers, accountants and auditors.
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 and the relevant third parties. In all cases data sharing will only take place when appropriate contracts, including confidentiality and / or data transfer obligation (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.
6. Controlling your personal information
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 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, or if you would like a copy of the data we hold for you, or would like to request the removal of your information from our records, or require further information or would like to provide us with your feedback you may contact us at any time.
Please email or write to CMC Partnership Data Protection using the following address; CMC Partnership Global Ltd, The Barn, Grace Dieu Court, Dingestow, Monmouth, NP25 4EB.
You can at any time tell us not to send you marketing communications by email, by using the contact information above, or by clicking on the unsubscribe link within the marketing emails you may receive from us.
CMC Partnership Global Ltd. is registered as a data controller with the ICO Z7927342.
We are committed to ensuring that your information is secure. We have reasonable security measures in place in order to protect your personal information from unauthorised access, use, alteration and disclosure. 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 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.
Your personal information will only be seen by those who have a legitimate reason for seeing it.
Your data may be processed by staff operating outside the UK or the EEA who work for us, or for one of our suppliers.
Our staff may be engaged in, amongst other things the downloading of your CV, fulfilment of your order and the provision of our services.
By submitting your personal data you agree to this transfer, storing and processing.
Third parties who are authorised to access, store and manage our data sets (which include your personal information records) are bound by confidentiality agreements.
Our .com website is assessed as PCI compliant
We do not collect, access, store or process any payment information on our websites. The processing of payment transactions is carried out in a third party secure Payment Gateway provided by Stripe.
8. Links to other websites and social media platforms
Our websites and other communications you receive from CMC Partnership may contain links to other websites of interest. If you use these links please be aware that we do not have any control over that other website and therefore we cannot be held responsible for the protection and privacy of any information which you provide whilst visiting such sites. Such sites are not governed by this privacy statement. Please exercise caution and look at the privacy statement applicable to the website in question.
9. 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.
10. Cookies - what is a cookie?
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 the company’s website and subsidiaries (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:
Strictly Necessary Cookies:
These are required for the operation of the website. They include, for example, cookies that enable approved users to log into secure areas of the website.
We use Google Analytics to gain insight into how our website is used, analysing information on the most visited pages on our website, the geographical locations of our visitors, time spent on the website and the number of times a link has been clicked, amongst many other useful anonymous statistics. _gat,_gid, and_ga are enabled.
These improve the functional performance of our website and make it easier for you to use. For example, such cookies are used to remember that you have previously visited the website and asked to remain logged in to it if you have a user account. Cookies are also used by www.cmcpartnership.com to protect the security of the site, for example by blocking multiple form submissions. In order to give the best possible browsing experience, we use session cookies to temporarily store data. Session cookies are used to keep track of your activity as you move from page to page through the website. Our session cookies do not collect any personal/traceable data about you and are automatically deleted when you close your browser
These record your visits to our websites, identifying the webpages you have visited and the links you have followed.
12. 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.
If you would like to find out more about privacy, cookies and their use on the internet, you may find the following links useful: