Privacy Policy

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The Positive Transformation Group Ltd customer privacy notice

Registered name: Positive Transformation Group
This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• How to complain
  Contact details: Email info@positive-transformation.org
  

What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:

• Names and contact details Occupation
• Video recordings
• Records of meetings and decisions

or use the following personal information for information updates or marketing purposes: Names and contact details

• Profile information

or use the following personal information to protect client welfare: 

• Names and contact information

or use the following personal information for dealing with queries, complaints or claims: 

• Names and contact details
• Address
• Video recordings of public areas
• Photographs Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may
  apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data
  protection rights may apply except the right to object.
• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be
  performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

bases for collecting or using personal information to protect client welfare are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  

Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Where we get personal information from

• Directly from you
• CCTV footage or other recordings
• Providers of marketing lists and other personal information
• Suppliers and service providers

How long we keep information
We store relevant information as follows in accordance with our data retention schedule; as follows:
1. Personal Data
Retention Period: 5 years
Purpose: To comply with legal and regulatory requirements, and to provide ongoing support to clients. Data Types: Names, contact information, course details.
2. Course Records
Retention Period: Course Duration plus 2 years
Purpose: To maintain records of course offerings, attendance, and completion for quality assurance and regulatory compliance. Data Types: Course schedules, attendance logs, progress, certificates of completion.
3. Financial Records
Retention Period: 7 years
Purpose: To comply with tax regulations and financial auditing requirements. Data Types: Invoices, receipts, financial statements, tax filings.
4. Employee & Associate Records
Retention Period: 7 years
Purpose: To comply with employment laws and regulations.
Data Types: Employment & Associate contracts, performance reviews, payroll records, feedback.
5. Marketing Data
Retention Period: 3 years
Purpose: To manage marketing campaigns and analyze customer engagement. Data Types: Email addresses, marketing campaign responses, customer feedback.
6. Training Materials
Retention Period: Indefinite
Purpose: To maintain and update training materials for future use. Data Types: Training manuals, presentation slides, course content.
7. Miscellaneous Records
Retention Period: 5 years
Purpose: To comply with general business practices and potential legal inquiries. Data Types: Meeting minutes, internal communications, policy documents.

Who we share information with

Data processors

Training Partners

Some of our training partners do the following activities for us: Processing learners, enrolment and training.
We have a joint controller relationship with some Training Providers & Associates.
We process your personal information with that joint controller for the following reason: Our Education Providers, Associates and Coaches have their own Privacy Policies..

Others we share personal information with

• Organisations we’re legally obliged to share personal information with
• Publicly on our website, social media or other marketing and information media
• Suppliers and service providers
• Professional consultants
• Third parties such as our PTG Coaching Associate Network
  

How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint