PRIVACY POLICY

Background

Clever Together is the trading name of Clever Together Lab Limited. Our company is based in the United Kingdom and all our activities are conducted within the European Union and European Economic Area.

This privacy policy explains how we gather and use personal data we may hold about you.

What data do we process?

Clever Together processes the following data:

• Your personal identification information – your name, email address (usually your work email address) and employee number.

• Your employment information – your job role, staff group, department, division, location and other relevant divisions as defined by your organisation.
• Your demographic data – gender, ethnicity and age. This data will only be collected when we are specifically seeking to understand the varying experiences of different groups of people.
• Your responses to questions we have asked during a conversation (this can be both numeric and free text).

Clever Together does not and will not process:

• medical information such as patient records; or
• financial information such as credit card numbers, salaries, banking details or transactions.

How do we collect your data?

There are three ways for Clever Together to obtain your data:

1. If you are an employee of an organisation that is our client, they may engage us as a data processor and provide us with your data. Under this circumstance, we are a data processor and can only use your information as instructed by your employer.
2. If you have answered a questionnaire to join one of our conversations, we will collect the responses you have given.
3. If you visit our website, via any information you submit to our Contact Us form.

How do we use your data?

Clever Together will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR).

We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

Clever Together is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

With respect to most client projects, Clever Together is a data processor. This means that we only ever use the information we hold as requested to by our clients who are the data controllers. In most cases, the activities we complete are done under the legal basis of your employer fulfilling their obligations to you as an employee.

This information is used for:

1. Authentication. To ensure only authorised participants see and contribute to a given discussion and that each participant may be fairly represented.
2. Communication. To invite participants to an engagement, share results and provide important notices regarding the process in which they are taking part (typically via email).
3. Analysis. To generate insight for our clients (usually your employer or within the NHS, arm’s length bodies such as Health Education England) by understanding views of participants, including how these may differ by various cohorts.
4. Support. To help you with any challenges you may have in accessing or participating in a conversation, workshop, survey or other engagement.

In rare cases, if you have repeatedly or severely breached the rules of an online workshop conversation, we may also use the information for identification.

Clever Together is a group of three companies. Data processing may occur by Clever Together Lab Limited, Clever Together Democratie SAS in France or Clever Together International OOD in Bulgaria.

What is the lawful basis for collecting and processing your data?

In most cases, Clever Together operates as a data processor on behalf of your employer. Usually, your employer has a legitimate interest to process some of your data, and you will need to confirm this with them directly. If you need our help in doing so, please write to us at privacy@clevertogether.com and we will point you in the right direction.

‘Legitimate interests’ is defined in GDPR (article 6 (1)(f)) and DPA(2018) as “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”

In other cases, your employer has asked Clever Together to process the data because:

• 61e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• 92b)processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;

For any conversation where Clever Together is the data controller, we will always ask for your consent to process your information and explain why. You have the right to withdraw this consent at any time and can do so by simply writing to us at privacy@clevertogether.com. 

How do we store your data?

Clever Together securely stores your data in an encrypted format at the following locations:

• In the United Kingdom – on our team’s computers and our system servers.
• In France – on computers of team members based in that country.
• In Bulgaria – on computers of team members based in that country.
• In Ireland – on our application servers, provided by Amazon Web Services.

All of our providers are in compliance with European Union rules and the General Data Protection Regulation. Information is always stored in an encrypted manner and all our systems are updated regularly to ensure they meet and exceed industry standards for data security.

How long will we keep your data?

Upon completion of a project or termination of a service agreement with any client (usually your employer), Clever Together will delete any personal information it holds within 30 days. An encrypted, electronic copy of such data will be sent to the client.

In any situations where we are leading the conversation, we will retain the personal information for up to 12 months.

Marketing and communication

If you are a participant in one of our online engagements, we do not use your  information for marketing purposes.

If you have registered your interest in our services, we will be in touch to discuss your needs and how we can help. We would also like to send you occasional emails sharing our latest thinking on the subject of large-scale engagement. You may always opt-out at any point.

If you no longer wish to be contacted by us with updates relating to one of our online conversations or marketing purposes, please send an email to privacy@clevertogether.com with the subject UNSUBSCRIBE.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review – in the event that Clever Together refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.
• Right to judicial review – in the event that Clever Together refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

To do so, please email privacy@clevertogether.com with the subject COMPLAINT. All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

What are cookies and how do we use them?

Cookies are text files placed on your computer to collect standard Internet log information and basic visitor behaviour. When you visit our websites or platforms, we may collect information from you automatically through cookies or similar technologies.

For further information on cookies, what they can and can’t do, please visit allaboutcookies.org

Clever Together uses basic functionality cookies for two reasons:

1. To keep you signed in, if you have ticked the Remember me box, and
2. To understand how you use our website.

We will never track your behaviour or activities on other websites and we will never use cookies to serve you advertisements.

You can set your browser to not accept cookies or to only accept certain types of cookies. The above website provides you with instructions on how to do this. If you choose to not accept cookies, some of our website or platform features may not function correctly as a result, but this will never limit your ability to share your views in the conversation.

Changes to our privacy policy

Clever Together keeps its privacy policy under regular review and will publish updates to this web page. The last update to this policy was made on 26th October 2022 by our Chief Operating Officer Alex Velkov.

How to contact the appropriate authority

If you feel that our company has not addressed your concern in a satisfactory manner or if you wish to report a complaint, you can also contact the UK’s Information Commissioner’s Office at https://ico.org.uk/

Contact us for more information

If you have any questions about our privacy policy, the data we hold on you or if you would like to exercise one of your data protection rights, please contact us at privacy@clevertogether.com