Privacy Policy

1. Forward

Effective date: January 1st 2021

NJR Procurement Ltd ("us", "we", or "our") operates the www.developmyteam.com website (hereinafter referred to as the "Service").

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

2. Definitions

  • Service is the www.developmyteam.com website and related surveys operated by NJR Procurement Ltd
  • Personal Data means data about a living individual who can be identified from data either in our possession or likely to come into our possession.
  • Usage Data data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Cookies are small files stored on your device (computer or mobile device).
  • Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed...
  • Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
    • For the purpose of this Privacy Policy, we are a Data Processor of your Personal Data.
  • Data Subject or User is any living individual who is using our Service and is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

If you participate in one of our competency assessment programs we may collect, process and hold your Contact Information together with Capability Information as provided by you or by our representative for the purpose of administering the competency assessment with you. The legal basis for this is our legitimate interests, namely our interest in the proper administration of our services and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • First name and last name
  • Email address
  • Cookies and Usage Data

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We may use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We may use Security Cookies for security purposes.

5. Use of Data

NJR Procurement Limited uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

6. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), NJR Procurement Limited legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

NJR Procurement Limited may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law

7. Retention of Data

NJR Procurement Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

NJR Procurement Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

8. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

NJR Procurement Limited will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

9. Disclosure of Data

NJR Procurement Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of NJR Procurement Limited
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

10. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

11. Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. NJR Procurement Limited aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete
  • The righ to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where NJR Procurement Limited relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

12. Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Our ISPs (Data Service Provider) are:

Digital Ocean - infrastructure and Hosting

Cloudflare - infrastructure security and static file (JavaScript/Images etc)

Google - Email provision via SSL and HTTPS encryption

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

  1. Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [email protected].

13. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

14. Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

14. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us:

Information Security Statement

1. Secure In Transit Communication

All data including Survey responses is collected over a secure HTTPS connection. Communications and traffic between the end users web browser and DevelopMyTeam’s website is conducted over an encrypted connection using Transport Layer Security (TLS). Customers only have access to data through password protected web application and API, never directly to servers.

2. User Authentication

DevelopMyTeam administration uses central user authentication to maintain identity and access management.

DevelopMyTeam imposes password management requirements on its internal systems, including password complexity requirements.

Clients – General

lease note that where DevelopMyTeam have given you (or where you have chosen) a password, which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. DevelopMyTeam request that you do not share a password with anyone.

Clients – Administrators

Client Administrators are provided a random password to use along with their user name (email address). Should too many incorrect passwords be entered access will be locked and only reopened by DevelopMyTeam administrators

Stored passwords are encrypted using the hashing algorithm PBKDF2 (SHA256).

Clients – Participants

A separate random organisation password is generated for survey participants who have no access to administration screens. Their access is automatically removed when they have completed the survey or the survey end date has passed.

3. LOGGING AND AUDIT TRAILS

DevelopMyTeam.com logs interactions on the application for the purpose of technical support and audit trails. These logs are only accessible to DevelopMyTeam IT support team.

4. BUSINESS CONTINUITY / DISASTER RECOVERY

Our server infrastructure is hosted on the Digital Ocean Platform. We take regular snapshots of the virtual servers that will allow us to roll back the application to a previous state if required. Our provider, Digital Ocean has an availability performance of 99.99%. See the links below for more information about Digital Ocean.

https://www.digitalocean.com/community/questions/can-you-please-describe-your-data-center-disaster-recovery-security-features

https://www.digitalocean.com/docs/platform/droplet-policies/

We also use Cloudflare, which provides DDOS attack protection (Distributed Denial of Service) and content delivery.

5. APPLICATION SECURITY

Application Engineering and Coding Practices

Our application is thoroughly tested before any updates are released into the production environment.

Our development team employs secure coding techniques and best practices that are described by The Open Web Application Security Project (OWASP).

DevelopMyTeam.com code uses the Django MVC (Model View Controller) framework for its functionality.

The Django codebase is fully tested to industry standard levels. For more information see the information in the link below;

https://docs.djangoproject.com/en/3.0/topics/security/

The custom functionality for DevelopMyTeam.com is tested in house using a combination of functional testing and automated unit testing.

Important security functions, such as authentication and Cross-Site Request Forgery (CSRF) protection, are contained in shared code libraries.

6. NETWORK AND PHYSICAL SECURITY

DevelopMyTeam’s technical infrastructureare is hosted within world-class, SOC 2-accredited data centers in the UK. We have carefully chosen our hosting provider Digital Ocean as they adhere to security and technical best practices.

7. OTHER THINGS

DevelopMyTeam does issue cookies, which help us to provide the survey tools and to deliver a better, and more personalised service. You may refuse to accept cookies by activating the relevant setting on your browser. However, if you select this setting you may be unable to optimally use certain parts of our site.

The transmission of information via the internet is not always secure. DevelopMyTeam will protect your personal data in accordance with current best practice but, it cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once DevelopMyTeam has received your information, it will use procedures and security features to minimise the likelihood of unauthorised access.