Privacy Policy

Leading,in a changing world…

Arwel Douglas Performance Ltd collects and uses data for use by, and for the benefit of, participants (Data Subject) who attend our workshops. This information must be collected and dealt with appropriately– whether on paper, electronically, or recorded on other material – and there are safeguards to ensure this under the Data Protection Act 1998.

Data Controller

Arwel Douglas Performance Ltd is the Data Controller under the Act, and will determine what purposes the information held will be used for. It is also responsible for notifying the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.


Arwel Douglas Performance Ltd is will not share data with other organisations, but in circumstances where this is required, the Data Subject will be made aware of how and with whom their information will be shared. There are circumstances where the law allows Arwel Douglas Performance Limited to disclose data without the data subject’s consent; these are:

  1. Carrying out a legal duty as authorised by an appropriate legal officer
  2. The Data Subject has already made the information public
  3. Conducting any legal proceedings, obtaining legal advice or defending any legal rights

Arwel Douglas PerformanceLtd places great importance on the correct treatment of personal information as a key element in the success of our working relationships, and in maintaining the confidence of those with whom we deal. Arwel Douglas Performance Limited intends to ensure that personal information is treated lawfully and correctly.

To this end, Arwel Douglas Performance Limited will adhere to the Principles of the Data Protection Act 1998.

Specifically, the Principles require that personal information:

  1. shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
  2. shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
  3. shall be adequate, relevant and not excessive in relation to those purpose(s) shall be accurate and, where necessary, kept up to date
  4. shall not be kept for longer than is necessary
  5. shall be processed in accordance with the rights of data subjects under the Act,
  6. shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
  7. shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal information.

Arwel Douglas Performance Ltd will, through appropriate management, strict application of criteria and controls:

  • observe fully conditions regarding the fair collection and use of information,
  • meet its legal obligations to specify the purposes for which information is used,
  • collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements,
  • ensure the quality of information used,
  • ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
  • the right to be informed that processing is being undertaken,
  • the right of access to one’s personal information
  • the right to prevent processing in certain circumstances and
  • the right to correct, rectify, block or erase information which is regarded as wrong information
  • take appropriate technical and organisational security measures to safeguard personal information,
  • ensure that personal information is not transferred abroad without suitable safeguards,
  • treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,
  • set out clear procedures for responding to requests for information.

Data Collection…

Informed consent

Informed consent is when a Data Subject clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
and then gives their consent.

Arwel Douglas Performance Ltd will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.
When collecting data, Arwel Douglas Performance Ltd will ensure that the Data Subject

  • clearly understands why the information is needed
  • understands what it will be used for and what the consequences are should the Data Subject decide not to give consent to the processing
  • as far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
  • is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
  • has received sufficient information on why their data is needed and how it will be used

Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.
Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.
It is Arwel Douglas Performance Ltd’s responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation which has been passed on/sold to a third party.

Data access and accuracy

All Data Subjects have the right to access the information Arwel Douglas Performance Ltd holds about them. Arwel Douglas Performance Limited will also take reasonable steps to ensure that this information is kept up to date, where relevant, by asking data subjects whether there have been any changes.
In addition, Arwel Douglas Performance Ltd will ensure that:

  1. the Business Manager will oversee compliance with Data Protection,
  2. everyone processing personal information understands that they are contractually responsible for following good data protection practice,
  3. everyone processing personal information is appropriately trained to do so,
  4. everyone processing personal information is appropriately supervised,
  5. anybody wanting to make enquiries about handling personal information knows what to do,
  6. it deals promptly and courteously with any enquiries about handling personal information,
  7. it describes clearly how it handles personal information,
  8. it will regularly review and audit the ways it hold, manage and use personal information
  9. it regularly assesses and evaluates its methods and performance in relation to handling personal information
  10. all staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

In case of any queries or questions in relation to this policy please contact the Arwel Douglas Performance Limited Business Manager.

The following list below of definitions of the technical terms it has used is intended to aid understanding of this policy.

  • Data Controller – The person who (either alone or with others) decides what personal information the Arwel Douglas Performance Limited will hold and how it will be held or used.
  • Data Protection Act 1998 – The UK legislation that provides a framework for responsible behaviour by those using personal information.
  • Data Protection Officer – The person responsible for ensuring that it follows its data protection policy and complies with the Data Protection Act 1998 is Paul Savage. Director
  • Data Subject/Service User – The individual whose personal information is being held or processed by an Arwel Douglas Performance Limited (for example a client, an employee)
  • ‘Explicit consent – is a freely given, specific and informed agreement by a Data Subject (see definition) to the processing* of personal information* about her/him. Explicit consent is needed for processing sensitive* data * See definition
  • Notification – Notifying the Information Commissioner about the data processing activities of Arwel Douglas Performance Limited as certain activities may be exempt from notification.
  • Information Commissioner – The UK Information Commissioner responsible for implementing and overseeing the Data Protection Act 1998.
  • Processing – means collecting, amending, handling, storing or disclosing personal information
  • Personal Information – Information about living individuals that enables them to be identified – e.g. name and address. It does not apply to information about companies and agencies but applies to named persons or employees within an Arwel Douglas Performance Limited.

Sensitive data – means data about:

  • Racial or ethnic origin
  • Political opinions
  • Religious or similar beliefs
  • Trade union membership
  • Physical or mental health
  • Sexual life
  • Criminal record
  • Criminal proceedings relating to a data subject’s offences


At Arwel Douglas Performance Limited we take your privacy very seriously.  To keep you informed about what we do with your data and how it is kept safely we provide you with the following policy statement.

  • We may hold your name and business email address.
  • We hold this data to allow us to provide you with surveys and resources which support your participation in organisation and staff development events.
  • We retain your responses to surveys for a period consistent with providing the services we have been contracted to provide.
  • We securely hold data electronically and on paper.
  • We delete your data (electronic and paper) once the service we have been contracted to deliver has been completed.
  • We do not use your data for any form of direct or indirect marketing, nor do we provide or sell your data to any third parties.
  • Our computer hard drives are destroyed before disposal.
  • We do not allow any third party access to our data, however, our IT support (outsourced) may work on software programmes that hold that data, such as our databases.
  • We store data via third party servers and we use applications including Dropbox, Microsoft and Google products.
  • Data held on third-party servers is highly protected by security features including encryption, passwords protection, firewalls, regular scans against malware and measures to prevent SQL injection.
  • We process and store data using our survey system software. Such software may be located ‘in the Cloud’ and if so we rely on the software provider’s security features and all access is password protected.
  • When software is installed on our local machines all software is double password protected.
  • We may use third-party contractors in our business and they are required to sign a ‘Fit and proper’ declaration which includes a declaration that they will not remove data or pass on data to other parties.

We are registered with the Information Commissioner.

Note to providers of data (Data Subjects)

By submitting data via our questionnaire or other processes you consent to the results being stored on our systems for the purposes of compiling pre-event data in support of your/other people’s development. The data can be accessed by the subject of the survey and the designated administrator of the system via password-protected access. The data will not be used for other purposes or shared with other third parties unless permitted under the Disclosure conditions outlined in the above policy.