FirstMind Ltd (“we”, “our”, and “us”) is committed to ensuring that your (the Company and test sender) and test takers privacy is protected. Set out below is how we use the information we collect and receive and how to tell us to use collected information, or to limit its use.
We are FirstMind Ltd, a limited liability company registered in England and Wales with company registration number 1245330. Our registered office address is 21 Buckingham Gate, SW1E 6LB.
FirstMind (test provider) provides a web-based and/or app-based platform that offers talent-focused personality assessments to help companies (test sender) make better people decision in regards to recruitment, leadership development, employee development, and team composition. The FirstMind platform enables companies to send out personality assessments to job applicants and employees (test taker) to get greater insights and make more informed people decisions. Test takers are provided with a questionnaire to complete on the FirstMind platform and, on completion, FirstMind generates a personality profile based on FirstMind algorithms derived from neurological and behavioural research. The FirstMind platform can be accessed through the Company’s (test sender’s) personal domain (the “Site”)
FirstMind Ltd is the Data Processer and the Company (test sender) is the Data Controller of any personal data provided and/or collected to complete an assessment on the FirstMind platform and both are subject to applicate data protection laws.
Data Protection Officer
21 Buckingham Gate
Anyone processing personal data must comply with the principles of processing personal data as follows:
INFORMATION WE MAY COLLECT
Information the Company gives us
You may give us information about you and/or test takers by registering or filling in forms on the FirstMind Platform or by corresponding with us by phone, email or otherwise. This includes information you provide when you:
Information we collect from users of the FirstMind Platform
We will collect and store information regarding who you send assessments to through the FirstMind Platform.
We may also automatically collect, store and use information about your visits to the FirstMind Platform and about your computer, tablet, mobile or other device through which you access the FirstMind Platform. This includes the following information:
Information we collect from test takers
The FirstMind Platform allows you to send assessments to yourself through public forms. These forms capture the information, you enter, and stores it in the Company’s database, equally as if the test sender would send you an assessment. This information includes your name, email address, phone number, location, and LinkedIn profile URL.
As you accesses the FirstMind Platform to complete the assessment/questionnaire you have received, we will collect and store the your responses to each of the 220 questions.
WHAT WE DO WITH YOUR INFORMATION
The personal data collected will be used by us to generate a personality profile and the Company in order to gain information about the people (job applicants, employees, and/or others) they wish to assess. The personal data collected will also be used by us to gain information about the usage of the FirstMind Platform and the FirstMind Assessment.
The personal data collected will be used by the Company to:
We consider that these uses of personal data are necessary for the performance of a contract with the Company.
Your personal data will be used by us in order to:
We consider that these uses of personal data are necessary for the purposes of our legitimate interests in maintaining and administering the FirstMind Platform and marketing and developing our services.
Where the Company, Platform user and/or test taker have given us consent, we shall provide information about news and publications, which we think will be of interest. The consent can be withdrawn at any time, but without affecting the lawfulness of processing based on consent before its withdrawal. These details may be updated or change at any time by contacting us as given in “Contacting us” above.
We may also use aggregate information and statistics for the purpose of monitoring website usage and test research in order to help us develop the website and our services. These statistics will not include information that can be used to identify any individual.
SHARING INFORMATION WITH THIRD PARTIES
In order to provide the FirstMind Platform service, we will need to share the Company’s, Platform users, and test taker’s personal information with authorized and approved subdata processors. These subdate processors includes and are limited to:
Subdata processor contracts must be in writing and imposed with the same obligations regarding handling of any subject therein as applies to the data processor under the Data Processing Agreement, as well as existing laws at any time.
Upon request from the Company, we share test taker’s personal data with any member of our corporate group for the member to deliver an ordered service (for example feedback to test taker)
We may also disclose personal information to third parties where there is a legitimate reason to do so including for the following reasons:
SECURITY OF INFORMATION
We store all information in electronic format. We use industry standard procedural security measures to protect information from the point of collection to the point of destruction. We use, as appropriate, encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access. Where appropriate, we use pseudonymisation and / or encryption to protect your information
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Where data processing is carried out on our behalf by a third party, we will endeavour to ensure that appropriate security measures are in place including to prevent unauthorised disclosure of personal information.
FirstMind Ltd offices are currently only in the UK but as part of a growing international organisation we may end up having other offices around but not only subject to Europe. Authorised personnel may access personal information in any country in which we operate.
Regardless of where information is transferred, we shall ensure that the information is safe and shall take all steps reasonably necessary to put in place appropriate safeguards to ensure that information is treated securely and in accordance with this policy and applicable law.
HOW LONG WE KEEP INFORMATION
Personal information received by us will be retained for the maximum period of time as required by law, after which time it will be destroyed in a secure manner. Please note that if personal information is shared with third parties (as detailed above) they may have different retention policies.
Under European Union data protection laws, you have the following rights:
Complaints. If you are located in the EEA and you believe that our processing of your personal data is in breach of data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the EEA where you believe the infringement has occurred. A list of EU national data protection authorities can be found here. You may also contact us at any time if you wish to complain about our processing of your personal data.
All parties can exercise any rights as described in this policy and under data protection laws by contacting the Data Protection Officer.
Save as provided under applicable data protection laws, there is no charge for the exercise of legal rights. However, if requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee (subject to any limits imposed by applicable law) taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity.
A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the FirstMind Platform and is stored on your device’s browser or hard drive.
The cookies we use on the FirstMind Platform won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.
You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
For use where Google Analytics used only. We only use “Google Analytics” on this Site. This cookie provides us with a visitor count and an understanding of how visitors move around and use the website. We can then use this information to improve navigability and the Site generally. The cookies we use on the Site won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.
We are obliged by Google Analytics to state the following:
The FirstMind Platform contains links to other websites for ease of reference. We do not endorse any sites that are linked from the FirstMind Platform and do not assume any responsibility for the content of any such website.
You may not link the homepage or any other parts of this website without out prior written consent.
This policy was last reviewed and updated May 2020.