Fair Processing Notice

Date Published: Dec 4, 2021

Introduction

Short Moments understands that your information is important and in the wrong hands it poses a risk to your rights and freedoms. In order to help you protect your information this notice will explain what information we collect, why we collect it, what we do with it, how long we keep it, who can access it and what your rights are.

What we need

In order to provide you with enhanced offering on our websites:

• Name
• Email Address
• Address
• Gender (optional)
• Age (optional)
• IP Address
• Cookies session ID
• Login/Username
• Your access level based on your history of participation in our offerings (for example, completion of the Twelve Empowerments will provide you with access to more features on our website, such as media, access to 24/7 Live Support etc.)
• Your Consent (when an account upgrade is available to you)

In order to handle local and global newsletters and email signups:

• Name
• Email Address
• Address (optional)

In order to handle your general inquiries:

• Name
• Email Address
• Message of Inquiry

In order to handle scientific studies and surveys:

• Name (usually optional)
• Email Address (usually optional)
• Content of your message/survey which can include information about physical and mental health, finances, beliefs and views and any other personal and sensitive information you consciously choose to share with us.

In order to handle applications for trainings:

• Name
• Email Address
• Address
• Phone Number
• Gender
• Age
• IP Address
• Details About Your Mental or Physical Health that might impact your ability to participate in the training
• Payment Details – Credit Card, Paypal, Cash or Other Form of Payment
• Special Needs (for a residential training, such as the Sweden Center)
• Food Preference (for a residential training, such as the Sweden Center)

In order to handle one to one calls:

• Name
• Email Address
• Address
• Gender
• Age
• IP Address
• Content of what you will share which can include information about physical and mental health, finances, beliefs and views and any other personal and sensitive information you consciously choose to share with the trainer.

In order to handle support emails and live chat support for participants who have completed the Twelve Empowerments:

• Name
• Email Address
• Address
• IP Address (Live Chat Support)
• Login and User Name (Live Chat Support)
• Content of your message which can include information about physical and mental health, finances, beliefs and views and any other personal and sensitive information you consciously choose to share with the trainer.

In order to handle responses to trainings questions (for example, Twelve Empowerments and Principles of Benefit and Service, but other trainings as well):

• Name
• Email Address
• Content of your responses which can include information about physical and mental health, finances, beliefs and views and any other personal and sensitive information you consciously choose to share with us.

In order to handle and maintain the Testimonials Archive - Value Letters:

• Name
• Email Address
• Content of your message which can include information about physical and mental health, finances, beliefs and views and any other personal and sensitive information you consciously choose to share with us.

In order to handle our pictures and videos for archive and promotional purposes:

• Name
• Address
• Still and/or Video Footage
• Your Consent

In order to handle participants’ video shares and training recordings:

• Name
• Email Address
• Content of your message/survey which can include information about physical and mental health, finances, beliefs and views and any other personal and sensitive information you consciously choose to share with us.
• Your Consent

In order to provide you with web support:

• Name
• Email Address
• Login/Username
• Content of your message

In order to respond to your subject access request:

• Name
• Email Address
• Login/Username
• Content of your message/request

 

Why we need it

We need to collect this information to:

Enhanced Offering on Our Websites – to share additional features and content that is available for the specific access level to which you have provided consent. Improve our website experience.

Email and Newsletters Signups – to share relevant information about Short Moments activity in the areas of interest where you have provided consent.

General Inquiries – to respond within 24-48 hours to inquiries and at times forward it to the right person or department based on legitimate interest.

Scientific studies and surveys – we conduct periodical studies to show the results of the training in a wide range of participants from all over the world who have provided their consent. At times we send surveys to consider and improve specific aspects of our offerings. These usually have the option of being kept anonymous.

Applications for Calls and Training – to recommend the training that will be most suitable for the participant who has provided their consent and to process their payment.

One to One Calls – to recommend the training that will be most suitable for the participant and to process their payment. This process is based on the participants consent and if they decide to purchase the course it is based also on contractual necessity.

Support Emails and Live Chat Support (for participants who have completed the Twelve Empowerments)– to carry out our consultation and customized support to participants who have provided their consent and contractual necessity. Anonymized live chat records are needed for research and technology development for bettering our offering of support.

Testimonials Archive - Value Letters – to collect and maintain a unique archive of global participants’ experiences of using the training in their everyday life. Anonymized Value Letters are needed for research and technology development for bettering our offering of support.

Responses to trainings questions (for example, Twelve Empowerments and Principles of Benefit and Service, but other trainings as well) – to assess progress and offer specific feedback and support to a participant in a training who has provided their consent.

Pictures and videos for archive and promotional purposes – to share testimonies of participants who have provided their consent on our websites, social media and promotional channels and to archive these for historical purposes.

Participants’ video shares and training recordings – to publish with their consent participants’ video shares for publicity and archive purposes, and, with consent, training recordings are shared at times with other participants who are going through the same training.

Web Support – to provide our users a seamless experience, attend to their suggestions and fix issues when using our sites based on legitimate interest.

Subject Access Request – to attend to subject access request in accordance to GDPR as part of its legal obligation.

 

What we do with it

Enhanced Offering on Our Websites – online registration on our websites is available for free, an email or a notification is received to our system. Upon completion or participation in specific trainings the Website User Manager assigns the user(s) to the appropriate access level. We also check our analytics periodically.

Email and Newsletters Signups – paper signup details are being transferred to the relevant contact list which is kept on a shared sheet, newsletter platform and/or email account.

General Inquiries – email is sent to the global or local information admin account and forwarded to the right person/department for consideration and follow up with a response.

Applications for Calls and Training – the responsible trainer(s) and relevant administrative personnel review the application (online or paper) and share either approval for the training and payment details or another follow up response. Key information is kept in a shared sheet.

One to One Calls  – a request for a call comes through an application and scheduling system, it is then forwarded to the available trainer who reviews the application as preparation for the call. An email is sent to confirm the call and share additional details at times. Key information is kept in a shared sheet.

Scientific studies and surveys – the data is received via online form or email and is collated into a sheet. If there is the request for responses (on some surveys), a response will be sent to the participant.

Support emails and live chat support for participants who have completed the Twelve Empowerments – a support email is received from a participant to their primary trainer and the trainer responds accordingly. When additional guidance is needed the trainer will consult with their Service Mentor. Live Chat Records are received and kept on the Chat Platform and a transcript is sent to the operators email and at times to a Service Mentor for review. The participant can choose to receive a transcript to their email address. Some of the chat records are being reviewed on a weekly basis for training purposes and improvement of our services. Given the participant does not object the use of their live chat record for research and technology development the live chat record is anonymized (this means that it is not possible to trace the record back to an individual person anymore) and only then used for the above mentioned purposes.

Responses to trainings questions (for example, Twelve Empowerments and Principles of Benefit and Service, but other trainings as well) – the participant shares the responses on an attached document or in the body of the email to the supporting trainer(s). The trainers review and respond to the participant and provide guidance when needed.

Testimonials Archive - Value Letters – an email is sent to a specific email account with some trainings kept in a database. At times, a compilation of the Value Letters for specific trainings is sent via email to the relevant trainers. Some Value Letters may be anonymized and then used for research and development.

Pictures and videos for archive and promotional purposes – the media is being kept locally on hard-drives and/or sent via cloud services to be kept and used by our Media and Publicity Departments. Promotional pictures and videos will be used on social media, newsletters and our websites.

Participants’ video shares and training recordings – the media is recorded and edited on a computer, the raw files are kept on the local Editing Team hard-drive and are deleted from their devices, the Participant Video Share is shared with the participant for their approval and consent and then uploaded to our websites, YouTube, social media and other platforms.

Web Support – requests or error reports are being sent by users via form or email, these are being forwarded via email or task management system to our Websites IT Team and when needed to a third party company that provide us with IT services.

Subject Access Request – a request from a user is being received to our Data Protection Department via email or form. The responsible person attends to that within the agreed timeframe and according to the processes set forth in our Subject Access Request Policies. The responsible person might need to contact another department and/or others in the organization in order to make sure they follow the steps requested in accordance with the user’s request. Once it is done the user is notified via email. 

At times we will transfer your data to another country, due to the global nature of our reach and operation.

We do not use automated decision making.

 

How long we keep it

Enhanced Offering on Our Websites – as long as the user is active and wishes to keep their registration

Email and Newsletters Signups – paper signups are being destroyed within 7 days and the user information is kept on the systems as long as the user wishes to receive the information.

General Inquiries – 5 years.

Scientific studies and surveys – indefinitely unless a user asks to remove or amend their records.

Applications for Calls and Trainings –5 years.

One to One Calls  – 5 years. 

Support emails and live chat support for participants who have completed the Twelve Empowerments – 5 years. Anonymized live chat records are kept indefinitely.

Testimonials Archive - Value Letters – indefinitely unless a user asks to remove or amend their records.

Responses to trainings questions (for example, Twelve Empowerments and Principles of Benefit and Service, but other trainings as well) - 5 years.

Pictures and videos for archive and promotional purposes – indefinitely unless a user asks to remove or amend their records.

Participants’ video shares and training recordings – Indefinitely unless a participant asks to remove or amend their records or the Management Team decides to remove media.

Web Support – 5 years.

Subject Access Request – 2 years.

In special circumstances such as ongoing legal proceedings we may be required to retain your data until proceedings allow us to remove your data. At times a Primary Trainer might request a specific participant to keep their records for a longer period than 4 years, this will be set forth in a specific agreement with the participant’s consent.

 

Who can see it

Enhanced Offering on Our Websites – Web Support Team, User Management Team, IT Support Company, Bright Team for Bright Platform, Online Courses Service Provider, Server Host Provider.

Email and Newsletters Signups – Local Information Admins, Local Trainers, Local Publicity Teams (depends on the question and the area of inquiry) Email Provider, Newsletter Service Providers, Bright Team for Bright Platform, Online Coursers Service Provider, Server Host Provider.

General Inquiries – Local Information Admins, Local Trainers, Management Team, depends on the question and the area of inquiry, Email Provider.

Scientific studies and surveys – Management Team, IT Team, Email Provider, Forms Platform.

Applications for Calls and Training – Local Information Admins, Local Trainers, Management Team, depends on the question and the area of inquiry.

One to One Calls for Call Requests, Scheduling Service Provider, Email Provider and Video Conference Service (in case used).

Support Emails and Live Chat Support (for participants who have completed the Twelve Empowerments) – Primary Trainer, at times Service Mentors, Email Provider, Forms Platform (for some services), IT Team (can but not using this option), Live Chat Service Provider.

Responses to trainings questions (for example, Twelve Empowerments and Principles of Benefit and Service, but other trainings as well) – Primary Trainer, Facilitating Trainer(s), Training Admin Contact (for Principles of Benefit and Service, for example).

Testimonials Archive - Value Letters IT Team, Management Team, Primary Trainer (when shared with them), Email Provider, Server Host Provider.

Pictures and Videos for Archive and Promotional Purposes – Local and Global Publicity and Media Team, Cloud Service Provider, Email Provider.

Participants’ video shares and training recordings – specific user groups on our websites, the public in on public channels (open on our website, YouTube etc.), Media and Editing Teams.

Web Support – Web Support Team, Email Provider.

Subject Access Request – Data Protection Department, Management Team, Relevant Departments and Role Holders in case needed to involve them. We might use the services of GDPR consulting company.

 

How we protect it

Short Moments is GDPR compliant and according to these clear guidelines we respect  personal data. We educate trainers, staff and volunteers in data protection and information security. We use the services of a GDPR consultation company to support us to maintain high levels of data protection and information security.

 

What your rights are

You may

• Request a copy of the data we hold on you. If you wish to do this then please send your request to [email protected] with subject line ‘subject access request’. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.
• Request that we correct or update the data that we hold on you. If you wish to do this then please send your request to [email protected] with subject line ‘subject access request’. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.
• Request that we delete the information we hold on you. If you wish to do this, then please send your request to [email protected] with subject line ‘subject access request’. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.
• Request that we keep your data but do not use it. If you wish to do this then please send your request to [email protected] with subject line ‘subject access request’. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.
• Request that we send a copy of your data to another organization. If you wish to do this then please send your request to [email protected] with subject line ‘subject access request’. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.
• Object to how we are using data. If you wish to do this then please send your request to [email protected] with subject line ‘subject access request’. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.
• Raise a compliant with the Information Commissioner’s Office about us. If you wish to do this, then please follow this link: https://ico.org.uk/concerns/
• Take us or the Information Commissioner’s Office to court.
• Withdraw consent to process your data at any time. If you wish to do this, then please send your request to [email protected]. Please be aware that we will use the email address you send from to communicate information regarding this but this email address will not be used for other purposes.

Additionally, we must inform you of the following:

• If we suffer a data breach and your data is affected in a way that it poses a risk to your rights and freedoms.
• If we carry out your request to correct/update, erase or not use your data.

 

Contact information

Contact Details for the controller of your data:

Short Moments Data Protection and Information Security Department [email protected] – we will respond to your inquiry within 24-48 hours.

 

Contact Details for the Data Protection Officer

DPO – [email protected] – we will respond to your inquiry within 24-48 hours.