Participant Privacy Notice

Participant Privacy Notice

Updated 30th April 2021

This Participant Privacy Notice explains how Lumina Learning uses your personal data when you are a Participant.

If you use our other services that are not covered by this Notice, we may hold additional data about you that is used for other purposes. Please consult our other privacy notices for further information.

About Us

Reference to “Lumina Learning, we, us, our” in this Notice refers to Lumina Learning Ltd (registered in England and Wales, Company Number 07021544). We are committed to treating your data fairly and transparently. We encourage you to contact us if you have any questions about this Notice.

About Participants

You are a Participant taking part in development, research or recruitment process that we offer as part of our services. We ask you to complete tasks, such as questionnaires about yourself and others. We may provide services to you at your own request or on behalf your sponsor. Your sponsor is the person or organisation that sponsors you to take part in our services, such as your employer.

Please note, if you create an account on the Lumina Platform (our website located at https://luminalearning.com or our mobile apps) before completing a task, we gather additional data about you that is used in accordance with our General Privacy Notice. Please consult this notice if you require further information.

Your Data

We collect and receive the following types of data about you:

               •   “Task Data” – when you complete a task, we ask that you share some data from your Lumina Account and Participant Profile on the Lumina Learning Platform, including your name, email and gender or pronoun preferences. We also ask you for additional data during the task. For example, questions about your workplace performance, psychological preferences, competencies, responses to stress, goals and development areas. In a recruitment context, we may ask you additional questions, such as details of your education and employment history. We may also gather data about you from others. For example, your colleagues may provide us with information about you by completing a feedback questionnaire.

               •   “Other Participant Data” – we gather other data about you when it is necessary for you to use our services. For example, your sponsor may provide us with information such as your contact details or details of previous tasks you have completed, or you may interact with us outside of the Lumina Platform, such as by email.

How Your Data is Used

We use your data for the following purposes:

               •   To provide our development, research or recruitment services to you and your sponsor.

               •   To produce personalised reports and other analysis of your data.

               •   To respond to your requests.

               •   To provide you with communications relating to the process you are taking part in.

               •   To research, analyse and enhance our products and services, including to avoid bias and discrimination.

               •   To conduct customer and market research.

               •   To analyse the performance of our business, such as to monitor the usage of our products and services.

               •   To support the maintenance, enhancement and security of our systems.

               •   For legal reasons, including our record keeping, to defend legal claims, comply with legal obligations and to prevent fraud and other illegal or harmful activities.

We process your data gathered in connection with this Notice based on your consent. You have the right to withdraw your consent at any time and we will erase your data.

For details about how to exercise your data rights, see ‘How to Exercise Your Data Rights’.

Your Personalised Reports and Profiling

When we use your data to produce personalised reports and other analysis of your data, this is termed ‘profiling’. We ask you to provide responses to our questionnaires, typically by asking you to self-assess how strongly you claim certain personality traits, qualities and competencies. We analyse your responses to build a comprehensive picture of your traits, qualities and competencies. We do this by comparing your scores with those of a representative sample of the population. This is termed ‘norming’. This information, typically presented in your personalised report, indicates how strongly you possess a certain trait, quality or competency relative to other people in the population. If you take part in a process where you receive feedback from colleagues, we ask them to assess how strongly they believe you possess certain personality traits, qualities and competencies. In your personalised report, we present a comparison between your self-assessment and feedback scores.

We do not use your data for automated decision making. Any decision that is taken involving your personalised report, such as in a recruitment context, will always be performed by a human. Your personalised report will be used in conjunction with other sources of data when making any decision.

How Your Data is Shared

Data we share with others

We share your data with the following third parties:

               •   The Lumina Learning Network – these third parties represent our business globally and perform some of our purposes on our behalf. They are typically termed ‘Lumina Learning Partners’, ‘Lumina Learning Strategic Alliances’ or ‘Lumina Learning Associates’ or ‘Lumina Learning Practitioners’.

               •   Professional and service providers – these third parties help us run our business by providing their services and expertise. For example, providers of tools like helpdesk software and providers of professional advice like legal, accounting and consultancy services.

               •   Business sale or change of control – if the ownership of all or part of our business changes, or if we enter administration, your personal data may be shared with the other parties involved. This includes where we take preparatory steps in connection with such activities.

               •   Legal obligations and defence of legal claims – we may share your data where we are subject to a legal obligation or if necessary to defend a legal claim against us.

We never sell your data to third parties for marketing purposes.

Data we share with your consent

We share your data with the following third parties with your consent:

               •   Participants in team activities – when you attend a learning event, we may share your name and a high-level summary of your personality report data with other attendees at the learning event. Examples of learning events include ‘workshops’, ‘development sessions’ and ‘qualifications’. Sharing this data aids with learning and allows you to fully partake in all elements of the learning event, such as interactive workshop experiences. For example, during the learning event, you may experience the Lumina Splash app or other digital interactive tools in an interactive workshop context. To allow you to take part, we may share your name and a high-level summary of your personality report data (such as your Splash and Aspect scores) with other attendees.

               •   Other individuals to whom you provide feedback – when you complete a feedback task about another person, we may share your name and your feedback with that person.

               •   Your sponsor – when you complete a task at the request of a sponsor, such as your employer, we may share your data with them.

International Transfers of Your Data

We may share your data with third parties that are outside the UK and European Economic Area (EEA).

Where a third party detailed under ‘Data we share with your consent’ is located outside the UK and EEA, it may not provide safeguards for your data and we cannot guarantee how they will use it. We ask for your explicit consent to share this data so that you understand these risks.

Where we share your data with any other third party, we do so only when there are appropriate safeguards in place. Where possible, we use third parties located in countries that the EU Commission has approved as providing adequate safeguards, or third parties taking part in EU Commission approved schemes that provide appropriate safeguards. Where these options are not available, we ensure adequate safeguards by using model contract clauses provided by the EU Commission.

Age Limit

Where you are under the age of 13, you can only take part in our services with the permission of your guardian. Please contact us and we will arrange to obtain this permission.

Retention of Your Data

We retain your data for as long as necessary for the development, research or recruitment service you are taking part in. You always have the option to exercise your data rights. Please see ‘How to Exercise Your Data Rights’.

How to Exercise Your Data Rights

You have the right to access, rectify, port and in some cases erase your personal data.

We process your data based on your consent, meaning you have the right to withdraw your consent at any time and we will erase your data.

To exercise your data rights, please contact us using the details below.

Updates to this Notice

We may update this Notice from time to time. We will post updates here and notify you of any changes that materially affect you.

Questions and Complaints

If you have concerns about how we have handled your personal data, we encourage you to contact us directly using our contact details below. We commit to resolving your issue wherever possible.

You also have the right to complain to a supervisory authority, including your local supervisory authority and our local supervisory authority, the United Kingdom’s Information Commissioner’s Office.

Contact Us

To contact us, please email
privacy@luminalearning.com.