GDPR

All employees, consultants and Interns working for GTB, and who have or may have access to personal data, must sign and comply with GTB’s Confidentiality Contract. No third party may access personal data held by GTB without having first entered into a data confidentiality agreement, which imposes on the third party obligations no less onerous than those to which GTB is committed, and which gives GTB the right to audit compliance with the agreement.

The consequences of breaching this contract are set out in GTB’s disciplinary policy and in contracts and agreements with third parties.

In determining its scope for compliance with BS 10012:2017 and the GDPR, GTB considers: All Employees, Consultants and Interns are responsible for ensuring that any personal data that GTB holds and for which they are responsible, is not under any conditions disclosed to any third party unless that third party has been specifically authorised by GTB to receive that information and has entered into a confidentiality agreement.

All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Access Control Policy. All personal data should be treated with the highest security and must be kept at GTB’s office and only accessible by Dr Sarah Lewis Director and anyone else with their consent.

Password Policy:

All staff computers require anti-virus protection and password protection (password, finger print or face recognition). Additionally, all staff are required to ensure software is automatically updated on any device that is used for work purposes. This software must be credible in nature, with all cyber activities aligning with our Cyber Security requirements. Employees need to provide information regarding their devices and software annually, to ensure Cyber Security certification is upheld, alongside an annual IT audit.

GTB Staff must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees should exercise caution when asked to disclose personal data held on another individual to a third party.

The GDPR permits certain disclosures without consent so long as the information is requested for one or more of the following purposes:

• to safeguard national security.
• prevention or detection of crime including the apprehension or prosecution of offenders.
• assessment or collection of tax duty.
• discharge of regulatory functions (includes health, safety and welfare of persons at work);
• to prevent serious harm to a third party; and 
• to protect the vital interests of the individual, this refers to life and death situations. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for, the conduct of GTB’s business.

All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures must be specifically authorised by the Data Protection Officer (DPO).

Non Disclosure Agreement

GTB intends to disclose information (the Confidential Information to the Recipient for the purpose of providing services, training resources for use when delivering GTB training courses and services (the Purpose), including (but not limited to) PowerPoint presentations, related handouts, activities, customer details and contacts.

The Recipient undertakes not to use the Confidential Information for any reason, except the Purpose, without first receiving the written consent from the Director of GTB.

The Company and the Recipient agree to give access to certain confidential information relating to their affairs solely for purposes of considering and developing joint working arrangements and joint ventures.

The Recipient and the Company agree to obtain, inspect and use such information only for the Purpose described above, and otherwise to hold such information confidential and secret pursuant to the terms of this agreement.

The Company has or shall furnish to the Recipient confidential information and may further allow contacts, employees or representatives of the Company to disclose information to the Enterprise:

• The Company’s plans and financial affairs
• The Company’s trade secrets, trading details and products
• Details on funding sources and business opportunities
• Intellectual property of the Company including concepts, ideas, models and research findings
• The Company’s publications, reports and written documents
• Details of meetings, discussions and communications relating to third parties
• Strategies, aims and objectives in pursuit of business goals
•  The Recipient undertakes to keep the Confidential Information secure and not disclose it to any third party (except to customers of GTB who are receiving training or services).

The undertakings of this Agreement apply to all information disclosed by GTB, regardless of the way or form in which it is disclosed or recorded but they do not apply to (a) any information which is or in the future comes into the public domain (unless as a result of a breach of this Agreement); or (b) any information which is already known to the Recipient and which was not subject to any obligation of confidence before it was disclosed to the Recipient by GTB.

You understand that all documents, presentations, activities and associated materials are the intellectual property of Grow, Transform, Belong. You will not amend them without permission or use them to deliver training not directed by GTB. This may include training you have been paid to develop on behalf of GTB but does not include materials you have developed for your own training sessions/personal use.

Nothing in this Agreement will prevent the Recipient from making any disclosure of the Confidential Information required by law or any competent authority.

The Recipient will, upon request from GTB, immediately return all copies and records of the Confidential Information disclosed and will not retain any copies or records of the Confidential Information for their own use.

The Recipient understands that they must not seek to deliver a course or service of the same or similar subject that they deliver for GTB, to another organisation from the sectors GTB delivers to; namely, the criminal justice, Approved premises Schools social care statutory and charity sectors, as a sole trader or under their own company umbrella. However, this does not preclude them from facilitating other subjects themselves or similar services for another training organisation.

Neither this Agreement nor the supply of information grants the Recipient any license, interest or right in respect of any Intellectual Property rights of GTB, except the right to copy the Confidential Information disclosed by the other party solely for the Purpose.

In accordance with the terms of this Agreement, you shall not, either during your engagement with GTB or during the period of six months after the date of termination of this Agreement, directly or indirectly induce or seek to induce any employee or facilitator engaged by GTB (at the date of termination of this Agreement and with whom you had material contact/dealings) to leave GTB.

In accordance with the terms of this Agreement, you shall not, either during your engagement with GTB or during the period of one year after the date of termination of this Agreement, directly or indirectly induce or seek to induce any customer or employee of a customer to work independently with you and/or terminate their services with GTB, whether or not this would constitute a breach of the Staff Agreement GTB has in place with that customer.

The undertakings in this Agreement will continue in force until it is terminated by either party.

This Agreement is governed by and is to be construed in accordance with English law. The English courts will have non-exclusive jurisdiction to deal with any dispute which has arisen or may arise out of, or in connection with, this Agreement.

Contact: info@growtransformbelong.com

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Last Reviewed: 4th Jan 2024