This privacy notice tells you about the information we collect from you when you register via one of our websites. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
Who are we?
We are Cibyl, a division of GTI Media, a company which is part of our parent company Group GTI. Our main address is:
The Fountain Building, Howbery Park Benson Lane, Wallingford Oxfordshire, OX10 8BA, UK
You can contact us by post at the above address, or by via email at data.protection@groupgti.com or by telephone on +44 (0)1491 826262.
Cibyl provides insights to employers and other organisations in relation to graduate recruitment market. We do this through consultation and bespoke reporting based on research we conduct.
We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above asking for the person responsible for data protection.
GTI Media is registered with the ICO under registration number: ZA492838
What personal data do we collect?
When you participate in one of our surveys, we request certain personal information from you in order to for us to better understand the trends and drivers underpinning the graduate recruitment market, so that we can better advise our clients on approaches to their graduate recruitment strategies.
Personal data requested may also contain “special category data” as defined in the GDPR, or “sensitive personal data” as defined in the DPA. In both cases this may include racial or ethnic origin, sexual orientation and health (ie. whether you are self-identify as having a disability).
Through the use of cookies and similar technology we may record your interaction with our websites and systems to help improve the delivery of our services. In addition as part of our security measures we may also record the IP address from which you are engaging with us.
Where else may we get your data from?
Any data we hold in relation to you is obtained directly from you through engagement with one of our surveys.
Why do we collect this information?
We collect information to be able to analyse trends, provide feedback to clients about their brand, and assist them in mapping out a strategic direction for their graduate recruitment programmes.
Where is my information stored?
Your information is stored in the databases that are called by our websites and other systems, which are based in the UK or Europe.
What do we do with your information?
The personal information you provide helps will be anonymised and aggregated for analysis and reporting purposes. We exclusively use your name and email address for administering the incentives and/or prize draw, after which both your name and email address will be deleted. At this point information we hold cannot be used to be directly linked back to you.
Who we might share your data with?
We do not share your data with anyone in a non-anonymised form. Any data we present to clients form part of a report where you as an individual cannot be identified from the aggregate data.
However, for some surveys conducted on behalf of our wider organisation (GTI Media) we may offer an option to register with an associated website providing careers and job opportunities. We require your consent to do this. Where consent has been given, we will transfer some of the personal details provided to register you on the site.
Automated processing and profiling
There are no automated decision making processes that would impact you as a result of any automated processing. No judgements or decisions are made of an individual as a result of any processing that may take place.
Legal basis for processing your data
The legal basis for processing under both the DPA and GDPR across our sites are outlined in the table below:
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| Data category | Description | Legal basis |
|---|---|---|
| Personal details obtained from surveys | Information that has been supplied in relation to a survey | Contractual necessity (Article 6(1)(b)) and legitimate interest (Article 6(1)(f)). Where consent has been given for the transfer to one of our websites then the legal basis for processing is consent under Article 6(1)(a) in relation to the transfer |
Consent
Where you have agreed to have the data you provided for a survey to be used to register with one of GTI Media’s careers websites (eg. targetjobs.co.uk or taregtcareers.co.uk), then the processing of your data for this purpose will be with your consent.
Contract
It may be necessary for GTI to process your data in order to fulfil a contract with you such as sending you the proposed incentive to complete the survey or notify you that you have won a prize.
Legitimate interest
GTI may also process your data when it is in our legitimate interest to do so and in doing so it does not override any of your data protection rights.
You have the right to object to the processing of your data under legitimate interest should you feel that such legal basis is not warranted or feel that it overrides any of the rights that you may have. Please note that once your data has reached a stage when it has been anonymised it will no longer be identifiable for restricted processing to take place.
How long do we keep your information for?
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| Data category | Minimum period |
|---|---|
| Personal details from surveys | Person identifiable information (eg. name and email address) is kept for the purposes of contact for delivery of any incentives to complete the survey or notification of prize draws. After which this information is deleted. |
Your rights over your information
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.
You can also ask us to give you a copy of the information and to object to us using your information you believe we are not doing so lawfully.
To submit a request by email, post or telephone, please use the contact information provided above.
In addition to the above you have the following rights under GDPR:
- The right to ask what personal data is held
- The right to ask to update and correct any out of date or incorrect personal data that we hold free of charge.
- The right to erasure of personal data where consent is the only legal basis for processing and that consent has been withdrawn.
- The right to data portability in the sense that personal data provided directly by the data subject is exportable in an open format like CSV where the legal basis for processing is based on either contract or consent.
- The right to restrict or object to the processing of your personal data where:
- You contest the accuracy of the personal data and the accuracy needs to be verified;
- You object to the processing under legitimate interest grounds and consideration needs to be made whether GTI’s legitimate interest overrides that of the individuals;
- The processing was unlawful and you request restricted processing over erasure;
You can withdraw consent at any time where consent has been relied upon. If consent is the sole legal basis for processing, we will stop processing the data after the consent is withdrawn. The data will then be placed in a restricted processing mode unless you have asked to exercise your right to erasure (in which case your personal data will be deleted) or the personal data falls outside stated retention period (whichever comes first).
Please note that the above rights are only applicable to the extent that the data provided by you is able to identify you as an individual. Once we anonymise the data, we will no longer be able to identify you and the data does not come under the scope of the GDPR and therefore the above rights will not apply.
Our communications with you
We may communicate with you by email for the purposes of arranging delivery of any incentive offered for completing the survey or the awarding of a prize. The legal purpose for which is do this under the legitimate interest provision under both GDPR and the Privacy and Electronic Communications Regulations (PECR).
However, should you be concerned about the content of these communications (such as unwanted marketing communications you can contact us by telephone or letter at the details provided above.
Changes to this privacy notice
From time to time we may need to make changes to this notice. We will attempt to inform you of any changes that are made either through both email notifications or through associated websites. You can obtain the most recent version of this notice from groupgti.com/privacy/cibyl or by contacting us directly. or by contacting us directly. This privacy notice was last updated on the 6th of November 2020.
Your right to complain
If you have a complaint about our use of your information you can do so with the relevant supervisory authority within the EU to which you are a resident, whom may refer the complaint to the UK supervisory authority.
Complaints in the UK can be made to the Information Commissioner’s Office via their website at www.ico.org/concerns or write to them at:
Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF