Privacy Policy
Your privacy is important to us. Learn how we safeguard your information.
Read more about how we comply with data protection laws like GDPR and CCPA.
Data protectionLast updated: 15 November 2023, to break down the policy by individual groups of data subjects.
Test Partnership respects your privacy and is committed to protecting your personal data. This privacy notice explains how we look after your personal data when you visit our website (including browsing, taking an assessment, or setting up tests as a client) and tell you about your privacy rights and how the law protects you.
1. Important Information and who we are
Contact details
Our full details are:
Full name of legal entity: Test Partnership Ltd
Data Protection Officer: Charles Day
Email address: info@testpartnership.com
Postal address: Censeo House, 6 St Peters Street, St Albans, AL1 3LF, United Kingdom
Telephone number: +44 (0)20 8142 8208
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Test Partnership is registered with the ICO under Registration number: ZA228041.
We have an EU Representative who can be contacted as follows:
Test Partnership Ltd
Rickert Rechtsanwaltsgesellschaft mbH
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-testpartnership@rickert.law
How we fit in to the processing of your data
When you are a candidate: where an organisation using our services (the "Client") has instructed us to assess an individual (the "Candidate"), the Client is the data controller and Test Partnership is the data processor. We are acting on the Client's behalf as their service provider and processor.
When you are a client: where we process the personal data of an employee or representative of a Client for the purposes of accessing or ordering our services, Test Partnership is the data controller.
When you are one of our staff: where we employ you on a permanent or temporary basis, Test Partnership is the data controller of your personal data.
Changes to the privacy notice and your duty to inform us of changes
Historic versions of this document can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Below is a list of the categories of data we may process. Some of these categories will not apply to the data we process about you; please see the next sections to see which categories apply to the processing of your data.
- Contact Details: examples include name, email address, telephone number, address.
- Financial Data: examples include billing address, credit card number, bank account details.
- Household and Relationships: examples include emergency contact, marital status, next of kin.
- Identifiers and Legal Documents: examples include passport, national insurance number, proof of residence, national identification number.
- Personal Characteristics: examples include sex, nationality, gender, date of birth, cv information, academic qualifications.
- Location Data: examples include gps location, tracking data.
- Images and Recordings: examples include cctv footage, photos, videos.
- Views and Opinions: examples include survey responses, testimonials, non-political, religious or philosophic opinions.
- Work-related Data: examples include details of grievance, completed tasks, disciplinary proceedings.
- Technical Identifiers: examples include ip address, username, encrypted passwords.
- Special Category Data, examples include:
- personal data revealing racial or ethnic origin
- personal data revealing religious or philosophical beliefs
- personal data revealing trade union membership
- genetic data
- data concerning health
- sexual orientation
- Aggregated Data: examples include such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
3. How we use your data if you are one of our Clients
This is how we process your data if you are an employee of one of our Clients.
Purpose | Personal Data Category | Legal Justification |
---|---|---|
Accounts Receivable | Contact Details, Financial Data | Contractual Obligations |
B2B Digital Marketing | Contact Details, Household and Relationships, Personal Characteristics, Views and Opinions | Legitimate Interest |
Calendar Scheduling | Contact Details | Legitimate Interest |
Collecting customer reviews | Contact Details, Views and Opinions | Legitimate Interest |
Collecting Testimonials and quotes | Contact Details, Views and Opinions | Legitimate Interest |
Collecting customer reviews | Contact Details, Views and Opinions | Consent |
Customer Relationship Management (CRM) | Activity and Behavioural, Contact Details, Personal Characteristics | Legitimate Interest |
Customer Support | Contact Details, Views and Opinions | Legitimate Interest |
Targeted Advertising | Activity and Behavioural, Contact Details, Household and Relationships, Location Data, Personal Characteristics | Legitimate Interest |
Transactional Emails | Contact Details | Legitimate Interest |
Website Interaction Tracking | Activity and Behavioural, Technical Identifiers | Consent |
4. How we use your data if you are a candidate being assessed
This is how we process your data if you have been invited to take one of our assessments.
Purpose | Personal Data Category | Legal Justification |
---|---|---|
Assess your performance on an assessment | Contact Details, Personal Characteristics, Views and Opinions | Legitimate Interest |
Customer Relationship Management (CRM) | Activity and Behavioural, Contact Details, Personal Characteristics | Legitimate Interest |
Customer Support | Contact Details, Personal Characteristics, Views and Opinions | Legitimate Interest |
Transactional Emails | Contact Details | Legitimate Interest |
Website Interaction Tracking | Activity and Behavioural, Technical Identifiers | Consent |
When we act as data processor
When a Client uses our services, we process your data on their behalf (they are the data controller). Accordingly, we process your data explicity in accordance with the Client's instructions. For details on how we process your data on their behalf you can request a copy of the Data Processing Agreement we have in place with the Client, or alternatively refer to the Client's privacy policy.
As data processor, there may be instances where the data controller instructs us to process special category data. For example the Client may transfer to us your sexual orientation, ethnicity, gender, or disability in order to protect against group differences and to make reasonable adjustments to your assessment. It is infrequent for us to regularly process such special category data but if we do any such processing would adhere to the conditions established by the Client on whose behalf we are processing your data.
Data relating to children
On rare occasions we are instructed by the data controller to process data relating to individuals who are under the age of 16, for the purpose of assessment in relation to employment. In such cases, the data controller has instructed us to process data of this nature, as it is necessary for entering into a contract of employment between you (the data subject) and the organisation (the data controller). We do not knowingly process data relating to individuals who are under the age of 13 and have implemented additional safeguards to protect any data we hold in relation to a child.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
Automatic profiling
Although we use statistical algorithms to score your assessments, you will not be subject to decisions that will significantly impact you based solely on automated decision-making. We have a legitimate interest in performing profiling, because this is the most appropriate way to provide our service, and such processing is based on your assessment performance only (for example, to make inferences regarding your behavioural preferences based on your responses to a personality questionnaire). We do not use any special category data for profiling purposes. The profiling described is necessary for the provision of our psychometric assessments, and forms part of our contractual obligation to our clients (the data controller), who has instructed us to provide the assessment service. We conduct DPIAs to address any potential risks to the rights and freedoms of individuals before introducing new profiling activities. We regularly test our algorithms and processes for accuracy. If you would like more information regarding such processing, please contact us by sending an email to info@testpartnership.com.
5. How we use your data if you are one of our staff
This is how we process your data if you are employed by on on a permanent or temporary basis.
Purpose | Personal Data Category | Legal Justification |
---|---|---|
Calendar Scheduling | Contact Details | Legitimate Interest |
Customer Relationship Management (CRM) | Contact Details | Legitimate Interest |
Internal Communication | Communications Data, Contact Details, Views and Opinions | Legitimate Interest |
Legal Archiving | Contact Details, Identifiers and Legal Documents | Legal Obligations |
Media Production & Hosting | Contact Details, Images and Recordings | Legitimate Interest |
Password and Credential Safekeeping | Contact Details, Technical Identifiers | Contractual Obligations |
Payroll | Contact Details, Financial Data, Identifiers and Legal Documents | Contractual Obligations |
Staff Onboarding | Contact Details, Identifiers and Legal Documents, Personal Characteristics | Contractual Obligations |
6. How we use your data if you are one of our website users
This is how we process your data if you are interacting with our website.
Purpose | Personal Data Category | Legal Justification |
---|---|---|
Consent Management | Activity and Behavioural, Technical Identifiers | Legal Obligations |
Customer Support | Activity and Behavioural, Technical Identifiers | Legitimate Interest |
Embedding Videos | Activity and Behavioural, Technical Identifiers | Consent |
Product Development and Gathering Insights | Activity and Behavioural, Contact Details, Personal Characteristics, Technical Identifiers, Views and Opinions | Legitimate Interest |
Website Hosting | Technical Identifiers | Legitimate Interest |
Website Tracking/Webapp tracking | Activity and Behavioural, Technical Identifiers | Consent |
7. How your personal information is collected
We collect personal information about you from the following sources:
- Our clients (the data controller) who invited you to take one of our assessments.
- Direct interactions. You may give us your Identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- purchase our products or services;
- create an account with us;
- complete our assessments;
- subscribe to our service or publications;
- contact us regarding feedback, queries or customer support;
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal or technical data about you from various third parties as listed in section.
8. Data sharing
We will use the following third party services to process your personal information for the purposes of providing the assessment service and storing the results of assessment(s):
Sub-Processor | Purpose | Encryption | Data Residency | Their Policy |
---|---|---|---|---|
Calendly | Appointment booking | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
Cronos Internet | Main hosting provider | Encryption in Transit | UK | Privacy Policy |
Email and Website Analytics | Encryption in Transit, Encryption at Rest | USA | Privacy Policy | |
Hubspot | Tracking of website visitor behaviour | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
Tracking of website visitor behaviour | Encryption in Transit, Encryption at Rest | USA | Privacy Policy | |
Microsoft | File storage | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
SendGrid | Email notifications | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
Stripe | Payment handling | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
YouTube | Tracking of website visitor behaviour | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
Zendesk | Livechat support | Encryption in Transit, Encryption at Rest | USA | Privacy Policy |
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website our assessment web application may become inaccessible or not function properly. For more information about the cookies we use, please read our cookie policy
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9. International transfers
Some of our external third parties are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and Europe.
- Note: since the Schrems II ruling on 16 July 2020 we no longer rely on the EU-US Privacy Shield for transferring data outside the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on instruction from the data controller, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
11. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you are a Candidate taking one of our assessments, we will retain your personal information for a period of time specified by the Client that instructed us to assess you. This is typically 24 months after you have completed our assessment(s), or within twenty business days of receiving from you or the Client a request to delete your data, whichever is the sooner. To confirm how long the Client has instructed us to keep your data please check the privacy policy of the organisation that invited you to take our assessment, or alternatively contact us.
12. Your legal rights
You rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Invoke your rights in relation to automated decision-making and profiling in regard to your personal data, where such automated decision-making or profiling may be carried out. Such as requesting further information regarding such processing or requesting that we check our algorithms and processes for accuracy.
If you wish to exercise any of the rights set out above, please contact info@testpartnership.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you, to help us confirm your identity, and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.
13. Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business, to enable us to give you the best service/product, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract (either with Test Partnership directly, or with the Client that has instructed Test Partnership to process data on their behalf).
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third parties
Third parties include:
- Service providers who act as sub-processors based in either the EEA, in an adequate country, the USA privided they comply with the UK Extension to the EU-U.S. Data Privacy Framework, or non-adequate countries provided they comply with UK Addendum to the EU Standard Contractual Clauses (SCCs) or the free-standing UK International Data Transfer Agreement, who provide and system administration services.
- Professional advisers acting as processors including lawyers, auditors and insurers based in the UK provided they comply with the UK Addendum to the EU Standard Contractual Clauses (SCCs), who provide consultancy, legal, insurance and accounting services.