By requesting information, a publication or a service you will automatically be subscribed to receive similar, complimentary or related publications. All electronic communications sent have an Unsubscribe option at the bottom of the email or E-Newsletter. All print publications are sent with a contact form which can be used to update your contact information or to unsubscribe from that publication. If you would like to update any details or unsubscribe from Ashridge publications, please contact us by email at:marketing@ashridge.hult.edu.
Who has access to your personal information
Ashridge guarantees that your personal information will not be passed to any third parties other than those that are working for or with Ashridge to deliver our various services (delivery of programs, consulting, coaching, research and hospitality) and to carry out the purposes listed above. Ashridge does not sell or otherwise distribute mailing lists to third parties. However, Ashridge has contractual assurances from those companies that the data is only used to send the Ashridge publications and is destroyed afterwards.
Occasionally we may share your information with Hult or other educational partners with whom we work, such as EF Corporate Language Learning Solutions, in order to advise you of services that complement our own. These partners will provide you with an opportunity to opt out of these communications every time they contact you.
Ashridge may share aggregated and anonymised information about our clients, participants and guests with advertisers, business partners, sponsors and other third parties. However, no individual information provided will be shared in this way.
Except as set out here we will not share your personal data with anyone else, except as required by law.
Profiling
When you visit our webpage or use our Leadership Live or psychometric products your details will be added to our CRM and marketing systems. We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources e.g. LinkedIn, to help us get to know you better and provide more effective personalisation.
Your rights, our obligations
You can choose at any time whether or not you wish to be contacted by Ashridge. Every communication we send you will give you the opportunity to opt out of further communications but you can also notify us at any time by email marketing@ashridge.hult.edu. or by telephone on +44 (0)1442 843491to withdraw your consent to marketing or any other contact from Ashridge.
What forms of security protect your personal information
Ashridge operates robust physical and system access controls together with transmission, input, availability, processing and segregation controls to protect your personal data. Many of our SaaS providers are ISO27001 accredited and we follow similar quality controls.
More information can be obtained from our IT Security Policy.
Transferring information overseas
Data protection legislation prohibits us from sending your personal details to a country outside the European Economic Area (EEA) without your informed consent. Ashridge works in partnership with some organisations and individuals that operate outside the EEA. We may consider it to be of benefit to individuals, based in the same geographical location, if their details are passed on to an appropriate Ashridge contact in their area for marketing purposes. At present, the European Commission does not consider certain countries outside the EEA to provide adequate levels of protection for the rights and freedoms of data subjects in relation to the processing of Personal Data, for the purposes of satisfying the eighth Data Protection principle. Nevertheless, Ashridge hereby declares that it is satisfied that the appropriate technological and organisational safeguards are in place in the overseas establishments that we work with and that these are equal to or greater than those required under current relevant data protection laws.
How long will we keep your information?
We will hold your personal information on our systems for as long as it necessary for the relevant activity or services, as required by our accreditors or for as long as is set out in any relevant contract you have with us, whichever is longest. If you exercise any of your rights to restrict the processing, restriction, transfer or deletion of your personal data, we will retain sufficient personal data in order to action, and continue to abide by, that request.
If you have not used your myAshridge or VA account in the last six months then your account may be classed as dormant and may be deleted in line with this Policy.
Your rights to find out what information we hold about you
The right to access (subject access requests) and portability
You can write to us at any time and ask for a copy of the information we hold about you. Please address your letter to the Chief Financial Officer. There is no longer a charge for providing this information, except where we consider the request to be manifestly unfounded, excessive or you request duplicate copies.
We can withhold your personal information in the following circumstances and without giving you justification:
• the prevention, detection or investigation of a crime;
• national security or the armed forces;
• the assessment or collection of tax; and
• judicial or ministerial appointments.
You can also ask us to transfer your data to another organisation.
Right to request rectification, updating or deletion
You may request that your personal information it updated, rectified or completed. We will make every effort to inform all third parties to whom we have disclosed the information of the changes made (unless this is impossible or involves disproportionate effort) and, if you ask us, we will let you know who those recipients are.
You may ask us to delete or cease processing your personal information where it is no longer a needed for the purpose for which it was gathered or you withdraw your consent to such processing. We can refuse to comply e.g. where we need to retain it in connection with legal proceedings or where we are required to retain your personal information by law.
If you wish to update or delete your personal information please write to Anders Ljungdahl, CFO, Ashridge, Berkhamsted, Hertfordshire HP4 1NS or email dataprotection@ashridge.hult.edu and we will arrange for your personal information to be updated or deleted in accordance with your instructions across our internal systems.
Deleting your account(s) will erase any personal information in your account that we have about you and it will mean any data we hold about how you have used myAshridge or VA will be made anonymous.
Right to restrict processing
You can request that processing of your personal information is restricted and only permitted with your consent, except where we need in connection with legal claims or to protect of the rights of others, in the following circumstances:
- where you contest the accuracy of information, for the period it takes us to verify its accuracy;
- where the processing is unlawful and you request restriction rather than deletion;
- where we no longer need the information but it is required by you in connection with legal proceedings; or
- where you have objected to the processing, pending verification of whether we or a third party has an overriding legitimate interest.
Where processing has been restricted, we will inform you before the restriction is lifted.
Right to object
This is a right to object, on grounds relating to the worker's particular situation, to processing based on one of the following:
- the processing is necessary for a task carried out in the public interest
- processing in the exercise of official authority
- the processing is necessary for the pursuance of the legitimate interests of the employer or a third party which are not overridden by the worker's interests
If an objection is received the employer must stop processing unless it can demonstrate compelling legitimate grounds for processing overriding the interests, rights and freedoms of the worker or that it is in connection with legal proceedings.
There are also rights to object to:
- data processing for direct marketing purposes - employer must stop processing
- data processing for statistical purposes - must stop unless in public interest
Right to appeal against automated decision making and profiling
This right allows an individual access to information about the reasoning behind any decisions taken by automated means. You can:
- give written notice requiring us not to take any automated decisions using your personal data;
- even if you have not given notice, you have a right to be informed when such a decision has been taken; and
- you can ask us to reconsider a decision taken by automated means.
This is your safeguard against the risk that a potentially damaging decision is taken about you without any human intervention.
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Time limit for responding**
We will respond to requests for access, rectification, erasure, restriction and objections without undue delay and at the latest within one month. If we need to extend the period of compliance by up to a further two months where requests are complex or numerous, we will notify you in writing within one month, together with the reasons for the delay. If we do not take action on your request we will inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and we will remind you that you may wish to lodge a complaint with the ICO and/or seek a judicial remedy.
Policy Review
This policy was reviewed and updated in May 2018. It is under regular review.