PRIVACY POLICY

Reviewed: January 2024

We, The LPI (Learning & Performance Institute) use your personal data to provide membership services for the enhancement of Learning & Development (L&D). We take seriously our responsibilities to look after your data and we are committed to protecting your data. This policy describes how we collect, store, secure and use your data.

When we talk about data and personal data in this Privacy Policy, we mean personal data which could be used to identify you either directly or indirectly such as your name and contact details. It may also include information about how you use our websites and mobile applications.

1. Who is responsible for your data

LPI is responsible for your data. We are registered as a company in England and Wales and are registered with the ICO for Data Processing under ref: Z5281857. We are the data controller of the data which we collect from you as a client or as an employee and as such we control the ways your personal data are collected and the purposes for which your personal data are used. We are a data processor for the provision of our L&D services

2. Personal data we collect about you

Depending on how you use our services and our websites, we might collect the following kinds of information about you:

What we collect When we collect it
Your name and contact details

(email address, telephone number, IP address and network stats)

When you create an account with us

When you fill in forms on our website

When you attend a recorded webinar

Communication we have with you

(emails, letters, telephone calls, messages to our online chat service, messages sent to us through our social media platforms, feedback, and other future protocols)

When you get in touch with us
Information about you, your location, IP address, network stats and how you use our website, mobile applications When you accept our cookies placed on your device

When you update your account information

When you fill in forms on our website

When you get in touch with us

When you opt in to receiving messages from us

When you complete a case study or video

For the provision of our services, we do not process any sensitive or special category data

3. Why do we collect this information?

We collect your personal information:

  • to provide you with the services that you may request from us or as under contracted agreement
  • to provide information about goods and services which we feel may be of interest to you
  • for our legitimate interests in the relationship we have with you as a business contact or client
  • to meet our legal and regulatory obligations as an employer
  • for the safeguarding and care of our staff and guests
  • for use in business promotions in the form of case studies or recorded video content but only with your consent

We are committed to keeping your information up to date as far as is reasonably possible However, if you believe that we have made an error, then please contact us as we have outlined below and we will use reasonable endeavours to correct.

4. Keeping your information safe and secure.

We are committed to ensuring that your personal information is secure and protecting it from being inappropriately or accidentally accessed, used, shared or destroyed, and against it being lost. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online and in paper form. We only provide access to your data to staff who require access. As a business we are certified to the IASME scheme (including Cyber Essentials and GDPR) https://iasme.co.uk/iasme-governance/. This is subject to annual recertification.

5. Sharing your data with third parties

Access to your personal information is only allowed when required by the law or is required as part our fulfilling our service obligations. We do not, and will never, sell your personal information with other third parties. We may disclose your personal information to third parties to assist us in our business operations and administration without obtaining further consent from you including:

  • The outsourcing of business functions to our business partners, suppliers and subcontractors for the performance of any contract we enter into with you such as, but not limited to, our CRM system; administration of our digital badges, events and webinars; the LPiLEARN system; the Capability Map for skills assessments; Stripe for payment processing.
  • Where we use the services of another processor, we will ensure that any such service provider adheres to at least the same obligations of security with regard to your data as undertaken by us.
  • Where we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms & Conditions and other agreements; or to protect our rights, property, or safety of our employees, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

For specific details of supplier and subcontractors please contact [email protected]

6. International Data Transfers

We are a UK based company and following Brexit we are outside the EU but we will continue to store and process personal information mainly in the EEA, as above. Please note though that your data may be exported to as well as stored and processed in countries outside of the country in which you reside, including, without limitation the United States. For data subjects residing in the EEA, this means that your personal information may be exported, stored, and processed outside of the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of data privacy and 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 UK and European Commission.
  • Where we use service providers who are not in territories approved by the UK or EU commission, we will look to implement additional safeguards such as a detailed review of security measures and the use Standard Contractual Clauses (SCCs) approved by the European Commission which give personal data the same protection it has in Europe
  • Where we use providers based in the US, we formerly would have relied upon the assurances of the US Privacy Shield. However, from July 2020 we will now apply additional safeguard as outlined above.

To receive information on the recipients of your data or if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us at [email protected]

7. How long do we keep personal information?

We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In general terms we will retain the data:

  • Of our clients for the duration of the services provided under contract and up to 3 years after the end of the contract.
  • For prospect clients or businesses that have not or have yet to subscribe to our services we will retain your data for up to a maximum of 24 months.
  • For anyone who applies or enquires about joining or working at LPI but does not work for us we will hold your details for a maximum of 6 months.
  • For our staff the records are held in line with HMRC requirements for up to 6 years after you leave us.
  • As agreed with you for business promotional materials.

For full more details of our retention please contact our Data Champion, [email protected]

8. Marketing & Market Research

LPI undertake a range of marketing activity using the data held within our database. This includes:

  • To share our newsletter or other promotional information.
  • We make use of Social media channels such as Facebook, LinkedIn and Twitter for business promotion.
  • We use cookies to gather statistics around email opening and clicks using industry standard technology to help us monitor and improve the information we send out.
  • We may with your consent use case studies or videos to help promote the value of our collaborative services.

We may also make unsolicited approaches to new potential contacts or business clients, using prospect information held within our records or using information drawn from publicly-available sources. These approaches are made in a fully complaint manner as governed by PECR (the Privacy of Electronic Communications Regulation), with the contacts being given the option to opt out from such contact.

9. How We use Cookies

We may gather information about you via our website by using a cookie file. Cookies are downloaded to your computer automatically and stored on the hard drive of your computer. They help us to improve our website and the service that we provide to you by collecting statistical data about your browsing actions and patterns; they do not identify you as an individual.
Some of the cookies we use will need your permission, by way of ‘Consent’. This is obtained when you first visit our site but can be amended at any subsequent time. Other cookies, (usually session cookies) are essential, and do not require your Consent. However, regardless of whether we need your Consent or not, we will inform you if we are using them, by including information within this Policy.

The following is a synopsis of the cookies we deploy:

Social Network Sharing

We encourage users to share our content and/or like our on profile on the popular Social Media websites Facebook, Twitter, YouTube, Google+ and LinkedIn. In order to make ‘Social Sharing’ accessible, our website utilises widgets either provided directly from the Social Networks and/or via amalgamative widgets from third parties such as AddThis. Cookies and privacy implications from the social networks vary and will be dependent on your nominated privacy settings with each Social Network. Social Sharing buttons will only deploy cookies if you are signed to that respective Social Network at the time of being on our website.

Analytical Tracking

Our website has Google Analytics installed which allows us to track and compile anonymous visitor statistics. The information collected ranges from simple traffic volume to the type of browser you are viewing our website with. This information is valuable to us not just for marketing analysis and quantification, but to improve the usability, security and load speed of our website content. Google Analytics is a popular, secure, flagship webmaster product from Google. The privacy and security of Google Analytics data is a high priority at Google that you can read more about on Google’s Analytics Data Safeguarding page. Google also offer a Google Analytics Opt-out Browser Add-on that will allow you to automatically Opt-out of all websites that track your activity via Google Analytics. No personal information is collected by Google Analytics.

WordPress

Our website, either in full or in part, is built on the popular open-source CMS framework – WordPress. WordPress utilises cookies to allow visitors to register, login and comment on our website’s content. If you do not wish to participate in commenting on our website, WordPress will not deploy any cookies onto your device. Cookies will only be created by WordPress if you actively register or comment via the clear forms on our website.

Enquiry Forms

Visitors can choose to contact us via enquiry form(s) on our website. In order to prevent spam enquiries, we protect our forms with a ‘CAPTCHA’ challenge to ensure the submission is from a living person, rather than a computer bot. This CAPTCHA challenge creates a cookie that is used only to check the input response from the user is correct. The CAPTCHA cookie does not store any other information from your enquiry.

Google Maps/Places

Our website may have our Google Maps/Places profile embedded within an iframe. Google Maps creates cookies that enable the functionality of their powerful mapping software. No personal information is stored or shared on the cookies deployed by Google Maps/Places

Actual Cookies Deployed

Below is a table of information which lists all cookies deployed and used on our website.

COOKIE TYPE DURATION DESCRIPTION
_ga 2 years The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_gat_gtag_UA_100578528_1 1 minute Set by Google to distinguish users.
_gcl_au 3 months Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.
_gid 1 day Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
_lfa 2 years This cookie is set by the provider Leadfeeder. This cookie is used for identifying the IP address of devices visiting the website. The cookie collects information such as IP addresses, time spent on website and page requests for the visits. This collected information is used for retargeting of multiple users routing from the same IP address.
asp_transient_id 7 days No description available.
cookielawinfo-checkbox-analytics 0 11 months This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Analytics”.
cookielawinfo-checkbox-functional 0 11 months The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”.
cookielawinfo-checkbox-necessary 0 11 months This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.
cookielawinfo-checkbox-others 0 11 months This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.
cookielawinfo-checkbox-performance 0 11 months This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”.
Learning & Performance Accelerator session session ullpidli
lpv687263 30 minutes No description
mf_a2d1fb0d-d429-48cc-b061-f6020b43c8c1 session No description
mf_user 3 months This cookie is used to identify whether the user is new to the website or a revisitor.
pardot past This cookie is set while the visitor is logged in as a Pardot user. The cookie indicates an active session and is not used for tracking.
PHPSESSID session This cookie is native to PHP applications. The cookie is used to store and identify a users’ unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.
test_cookie 15 minutes The test_cookie is set by doubleclick.net and is used to determine if the user’s browser supports cookies.
viewed_cookie_policy 0 11 months The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
visitor_id687263 10 years No description
visitor_id687263-hash 10 years No description
Google

_utma, _ga, _gat – A Google Analytics cookie, which keeps track of the number of times, a visitor has been to the site, when their first visit was, and when their last visit occurred.
_utmb – A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor enters a site.
_utmc – A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor leaves the site.
_utmv – Used for reporting in Google Analytics classifying the visitor.
_utmz – A Google Analytics cookie which tracks where the visitor came from, what search engine was used, what link was clicked on, what keywords used, and where in the world the site was accessed from.
PREF, NID – This cookie is set by Google Maps when you load a map of our location

WordPress

wp-settings-1, wp-settings-2, wp-settings-3, wp-settings-time-1, wp-settings-time-2, wp-settings-time-3, wordpress-test-cookie, devicePixelRatio – This is a cookie is to verify if you are logged into the website or not.
wordpress_, wordpress_logged_in – WordPress cookie for a logged in user.
comment_author, comment_author_email, comment_author_url – When you enter a comment on this site you will be asked to provide certain information about yourself including your name, email and website address.

Learning and Performance Accelerator

ullpidli – this is used to track if a user is logged in.

LPI Capability Map

ullpidli – this is used to track if a user is logged in.

Cookie Consent Check

As mentioned above, upon your first visit our website displays a banner alerting you about cookies and seeking your consent for the application of any non-essential cookies. For our website to remember your choice of opting-in, we store an anonymous cookie to remove the alert banner for 28 days. To prevent this cookie being stored, simply do not accept and close the alert. If you have already accepted the alert and you wish to remove or change your cookie consent, please click Manage Consent (displayed in the lower left of the website).

How to disable cookies

Most modern browsers allow you to control your cookie settings for all websites that you browse. You can disable cookie deployment completely by editing your browser settings, however in doing this you may be limiting the functionality that is displayed on our website. To learn how to disable cookies on your preferred browser we recommend reading this advice posted by Google. If you are concerned about cookies tracking your movements on the Internet, then you may be concerned about spyware. Spyware is the name given to a particular band of cookies that track personal information about you. There are many anti-spyware programs that you can use to prevent this from happening. Learn more about anti-spyware software – http://en.wikipedia.org/wiki/Spyware. As mentioned earlier in this page you call also disable Google Analytics on all websites by downloading the Google Analytics Opt-out Browser Add-on.

10. Controlling your personal information (Your Rights)

It is important that the personal information we hold about you is accurate and current. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect. Under certain circumstances, you have rights under UK Data Protection Act 2018 (DPA) and General Data Protection Regulation (GDPR) in relation to your personal information. You may have the right to:

  • access information held about you. Your right of access can be exercised in accordance with data protection law;
  • object to us processing, or ask us to restrict our processing of your personal information for any of the purposes listed in this policy, at any time.
  • ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge.
  • ask us to erase or delete your personal information (in certain circumstances). We will do our best to respond to such requests, but these are subject to certain limitations such as legal requirements
  • Request a transfer of your personal information (in certain circumstances).

If you wish to exercise any of the above rights or to review, verify, correct or question anything detailed in this policy or are unhappy with any aspect of how we use your data please email [email protected] or contact us on +44 (0)2476 496210

You also 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. You can contact the Information Commissioner’s Office by telephone on 0303 123 1113, or by using the live chat service which is available through the Information Commissioner’s website 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.

Our registered company address

167-169 Great Portland Street, 5th Floor, London, W1W 5PF

Ce Cert
Iasme Cert

NOTE: Our registered company address has changed to 167-169 Great Portland Street, 5th Floor, London, W1W 5PF. This certification was attained at our previous registered company address.