This policy is about how we (West Midlands Employers) use your personal information (‘data’) on the WME360 review service site to deliver a service to our client (your employer).

We respect your right to privacy. Our relationship with you is valuable and we understand the importance you place on the privacy and security of information that personally identifies you.

We take your privacy seriously and comply with the Data Protection Legislation. WME employees who have access to your personal data will respect the confidentiality of that data.

WME is the processor of your personal data and your employer is the controller of your personal data.

What information is being collected about you as the subject of a review?

The personal information we are collecting as part of your WME360 review consists of;

• Your name
• Your e-mail address
• Feedback from your colleagues (raters) about you (Your 360 report)
• Your colleagues name
• Your colleagues email address
• Your colleagues working relationship with you (Manager, Peer, Direct Report etc)

What information is being collected about you as a ‘rater’ in a review?

• Your name
• Your e-mail address
• Your feedback about your colleague
• Your colleagues name and working relationship with you

How is it collected?

As a review subject your name and email address is provided to WME by either yourself or the organisation purchasing the 360 service.

As a review rater your details are provided by your colleague when providing WME with list of suitable contacts to participate within their 360 review.

Your personal 360 report is created by the WME360 system. The system collates the data collected from yourself and your colleagues when completing the 360 review.

Why is it being collected?

Your information is being collected to;

• Provide access for you to participate in a 360 review service
• Send you notifications about progress with your 360 Review and scheduling of feedback sessions

How long will you keep my data for?

By agreeing with your employer to participate in a 360 review and registering for the service you are providing consent for us to hold your personal details to enable us to provide this service to your employer (our client).

Our contract with your employers requires us to hold your 360 review details for 24 months after which your details will be deleted from our system. If your organisation is intending to do repeat reviews to assess your development progress over time, they may request WME retain your details for a longer period in order to create comparison reports that include information from your original 360 report compared with a new report. If WME receives a request to hold your data for a longer period we will contact you to seek your consent.

If you wish to have your data removed before 24 months you will first need to make your request to your employer as the data controller.

Who will my data be shared with?

We keep our privacy policy under regular review and we will update this privacy notice from time to time. This privacy policy was last updated in 1 June 2020.WME will only share your personal data, where deemed necessary to support the effective delivery of this service, with;

• Our processors (See ‘Processors’ section listed later in this policy)
  • To ensure the smooth running of the WME360 service
  • To provide you with feedback on your 360 review
  • If a processors support is required to answer a query you raise with us
• The Service Client
  • To provide the WME360 service to the client (usually your employer)

We will not share your data with any other third parties without your consent to do so unless required to do so by law.

Your rights

Under the Data Protection Act, you have rights as an individual which you can exercise in relation to the information we hold about you.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-myinformation-being-handled-correctly/

Accessing and managing your personal information

You can login to your account on the WME360 site at any time to;

• View and manage your account details (name, e-mail, password)
• Update your password
• View and manage your 360 review

Cookies

Our website uses cookies. Cookies are small text files placed on your computer when you visit a website to help us identify you and your preferences and to make our services work effectively. They may be used to help the website to recognise your computer the next time you visit – for example if you check a ‘keep me signed in’ box when logging in to a website. Some cookies also help us monitor how our website is performing and collect information about our visitors to help us to improve the services that we can offer to you to improve your user experience within our website.

None of the cookies set by the WME360 site jeopardises the security of your computer or device. Cookies are just very small pieces of text with letters and numbers arranged in patterns that only make sense to the web service that created them – they cannot be used to spread viruses or other malicious software.

More detailed information about cookies and what they are used for is available at www.allaboutcookies.org – this website also has detailed information about how you can control which cookies are allowed by you, and enables you to delete cookies from your computer, should you wish to.

You have the ability to accept or decline cookies by modifying the settings in your browser, however please note: if you block or restrict cookies on your machine, the WME360 site may be unable to function correctly.

System Security

The WME360 site has security measures in place to prevent the loss, misuse and/or unauthorised alteration of personal information under our control. You can gain access to your profile and modify the information stored by supplying an email address and password. You must ensure that this information is not given to anyone else. The effectiveness of our safety measures can be enhanced by you creating passwords that cannot be accessed, guessed or reproduced easily by unauthorised persons. The system will request regular password changes to ensure security of your data.

Processors

Data processors are third parties who provide elements of our service for us. We have contracts and/or arrangements in place with our data processors to ensure they cannot do anything with your personal information unless we have instructed them to do so. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct in line with this privacy policy.

These are our processors;

• Headlight Limited

Headlight is an award-winning talent management software and consulting firm that works with clients to define and implement impactful talent management strategies. Talent Cloud ® is their cloud-based portfolio of integrated talent management software Tools.

Headlight provide the technology and the platform supporting the WME360 review service that we collect and manage your personal data in.

The site uses cookies to facilitate certain website features, user authentication and tracking, but no personal information is stored in these cookies.

• WME Staff and Associate Consultants

The WME360 review service requires analysis of feedback provided to the site which is then fed back to the individual review subject via a conversation either face to face or virtually.

WME only uses qualified and trained individuals including our own staff and associate consultants to provide a confidential feedback service to the individual and client. They will use your personal information only for the purposes of providing this service and will only have access to information for the individuals to whom they are providing a feedback service.

• Organisation Feedback providers

Some client organisations have trained personnel to provide the feedback internally; or may choose to involve your manager and any other parties such as an elected member for those who are a Chief Executive Officer as part of the feedback discussion. WME will share your personal information with the feedback provider and/or your manager as instructed by the Service Client.

Site Statistics

The platform enables us to monitor progress for the 360 reviews via the Action Log which outlines all actions that have taken place during a specific period:

• Accepted/Declined/Not responded to Invitation
• Review Status
• Last Login
• Date completed

This information is used by WME to administer and improve our services; including contacting raters to chase information.

About us

The WME360 site is operated by West Midlands Employers whose registered office is at PO Box 16725, Sandwell Council House, Oldbury, West Midlands, B69 9FH. We have informed the Information Commissioner’s Office (ICO) about the ways in which we process personal data. You can see this notice on the ICO’s Data Protection Register of Data Controllers under registration number ZA196788. You can view our general privacy notice on our website www.wmemployers.org.uk/privacy-policy

Complaints

If you make a complaint to us in relation to how we handle your personal data and think we have not dealt with it to your satisfaction, you may send your complaint to the Information Commissioner for investigation. For more information on the Information Commissioner, and how to make a complaint, please visit their website at www.ico.org.uk.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 1st June 2020.

How to contact us

You can get in touch with us by emailing info@wmemployers.org.uk