1. We seek to be fair and lawful. This means we will:
a. have legitimate grounds for collecting and using the personal data;
b. not use the data in ways that have unjustified adverse effects on the individuals concerned;
c. be transparent about how we intend to use the data, and give individuals appropriate privacy notices when collecting their personal data;
d. handle people’s personal data only in ways they would reasonably expect;
e. make sure we do not do anything unlawful with the data.
2. We are clear about the purposes for which we use personal data:
a. To communicate SalesLevers insights and thought leadership in the fields of sales, relationship management and business development with individuals whom we have reason to believe have an interest in these subjects because of their role and the organisation they work in.
b. To explore potential projects with these individuals and organisations.
c. To deliver projects with these individuals, the organisations and individuals they involve in the projects.
3. The personal data we process will be adequate, relevant and not excessive. This mean we ensure that we hold personal data about an individual that is sufficient for the purpose we are holding it for in relation to that individual. We do not hold more information than we need for that purpose. This is part of the practice known as “data minimisation”.
4. We recognise that personal data needs to be accurate and kept up to date.
5. We recognise that Personal data should not be kept for longer than is necessary.
6. We recognise that individuals have rights of access to any data we process.
Basis for processing data
We have reviewed the lawful bases for processing data. and have carried out a Legitimate Interest Assessment (available for inspection on request) and have concluded that we can:
a. identify a legitimate interest;
b. show that the processing is necessary to achieve it;
c. balance it against the individual’s interests, rights and freedoms.
Sources of data
As a new business we hold very little historic personal data.
Where we hold personal data relating to individuals who have been or are involved in existing projects we are approaching each individual and gaining their agreement that we can send them content to support them in implementing the project while the project is continuing and for 12 months after the end of the project. After this period we will approach them again to enquire if they choose to receive ongoing content in the form of a monthly update and a quarterly newsletter.
Where the directors have personal professional contacts we will approach each individual to ask if they choose for us to hold limited personal data (Name, title, department, company, business address, email and phone number (business/mobile) for the purpose of updating them on trends in “sales performance in a changing world”.
Where a contact wishes to introduce us to a colleague or a contact where there is a legitimate interest, we will approach that individual as above.
If an individual wishes to explore potential projects or options for co-operation we will seek their permission to process data during this process.
Where individuals will be involved in a live project e.g. being trained or working in the design phase we will approach them in advance explaining the purpose of processing data and our methodology.
Some individuals will approach us via our website and they will be asked for their agreement for us to process their personal data. The directors have extensive contacts on LinkedIn (see LinkedIn Privacy Statement at https://www.linkedin.com/legal/privacy-policy It is our understanding that we are able to continue contact with LinkedIn connections and followers. However if we process any data from LinkedIn contacts within SalesLevers for reasons of legitimate interest (see above) we will seek their agreement.
Where we buy in lists from commercial sources for reasons of legitimate interest, we will ensure they are GDPR compliant and will inform the individuals that we are processing data.
The main location for any data is our CRM Freshsales. We have reviewed the Freshsales security arrangements and are satisfied they are effective.
Other data is held on SalesLevers computer system. The server is kept in a locked building with controlled access. Access to PCs is password protected as is access to any mobile devices. One back up disk is kept in a secure office. Personal data is not held on any data sticks etc.
In the rare instances that personal data is held as hard copy it is located in a secure office.
The only occasion when personal data will be communicated to third parties is where a SalesLevers partner business is providing a service to a client e.g.individuals being coached using a virtual coaching tool. The client company is always informed of our requirement to share any employee data and their communications policies are followed.
SalesLevers is registered with the ICO as a data processor. Ref no. ZA361463. The named contact is Richard Higham who can be contacted at email@example.com or through the company’s registered office 3 Startforth Road, Riverside Park, Middlesbrough TS2 1PT or by phone on 07712 588757.
SalesLevers is committed to sustainable business practice. SalesLevers uses finite resources with consideration for the environment. The business supports innovative developments in products, services and working practices that offer environmental benefit. The business takes into account environmental impact when designing projects, selecting materials, planning logistics and managing disposal of any waste.
An important part of supplier selection and ongoing relationship with Key Suppliers is that our supply chain partners integrate environmental management within their own business policies. It promotes the use of purchasing practices that reduce the environmental burden associated with such operations.
Equality, Diversity and Inclusivity Policy
SalesLevers is committed to eliminating discrimination and encouraging diversity amongst our workforce and our community. Our aim is that our workforce and community will be truly representative of all sections of society and each member will feel respected and able to give of their best.
To that end the purpose of this policy is to provide equality and fairness for all in our practices and not to discriminate on grounds of gender, gender reassignment, marital status (including civil partnerships), race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age. We oppose all forms of unlawful and unfair discrimination.
All employees and members of our community will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.
We are committed to:
a. creating an environment in which individual differences and the contributions of all our community are recognised and valued.
b. providing an environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.c. providing training, development and progression opportunities to all members of our community.
Equality in the business environment is good management practice and makes sound business sense.
We will review all our practices and procedures to ensure fairness.
Breaches of our equality policy by any member of our community will be regarded as unacceptable behaviour and appropriate action will be taken to address it.
This policy is fully supported by all members of our community.
The policy will be monitored and reviewed annually.
Anti Bribery Policy
It is SalesLevers policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
Saleslevers will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.
2. Who is covered by the policy?
This policy applies to:
(a) All individuals working at all levels and grades, including directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with SalesLevers or their employees, wherever located and
(b) Third parties. Where we engage with third parties, we will undertake appropriate steps to ensure that they comply with the principles set out in this policy.
3. What are bribery and corruption?
Corruption is the misuse of office or power for private gain.
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
4. What is not acceptable?
We do not (nor do we procure someone) to:
(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
(b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
(c) accept payment from a third party that we know or suspect is offered with the expectation that it will obtain a business advantage for them;
(d) accept a gift or hospitality from a third party if we know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
(e) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
(f) engage in any activity that might lead to a breach of this policy.
5. Facilitation payments and kickbacks
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
Kickbacks are typically payments made in return for a business favour or advantage. We avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices.
7. How to raise a concern
Third parties are encouraged to raise with us concerns about any issue or suspicion of malpractice at the earliest possible stage. Any concerns or issues should be referred to Richard Higham: firstname.lastname@example.org
8. Monitoring and review
We will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.
Anti Money Laundering Policy
SalesLevers is committed to the ethical principles that underpin anti money laundering legislation. While the nature of our work makes it extremely unlikely we in SalesLevers will come across money laundering activity in our clients or suppliers, if anyone in our business knows or suspects that another person in a client or supplier is money laundering or financing terrorism, they will inform the Managing Director who will communicate with the client’s or supplier’s nominated officer.
Health & Safety Policy
It is Saleslevers policy:
To provide adequate control of the health and safety risks arising from our work activities;
To consult with our employees on matters affecting their health and safety;
To provide and maintain safe plant and equipment;
To ensure safe handling and use of substances;
To provide information, instruction and supervision for employees;
To ensure all employees are competent to do their tasks, and to give them adequate training;
To prevent accidents and cases of work-related ill health;
To maintain safe and healthy working conditions;
To review and revise this policy as necessary at regular intervals.
Policies updated March 2019