Effective Date: May 25, 2018
The Center for Creative Leadership is a non-profit organization and has a research mission to advance the understanding, practice and development of leadership for the benefit of society worldwide. Our research is used to provide powerful models, best practices, and new knowledge. CCL often gathers, retains and uses data provided to us by organizations and individuals. The data is analyzed and the results are presented and published for our constituents including leaders, scholars, and leadership development practitioners. We publish in journals, books, blogs, newspapers, etc. We also write reports for sponsoring organizations.
We acknowledge the value of the data provided by the entities and individuals with whom we are privileged to work. As a matter of course, we regularly aggregate, use codes or pseudonyms, or fully anonymize the data that we use for such research. That said, we recognize that certain data may have a sensitive nature, and may be either: (a) potentially re-identified to an individual with additional pieces of information, or (b) not possible to de-identify from an individual in the first place. Thus, we wish to describe the manner in which we protect the confidentiality and integrity of the data, along with the privacy of its origin, and seek your explicit, informed consent for its use, where information that is potentially personally identifiable to you is involved.
Your consent to have information that can be identified to you (your “Personal Information”) included in CCL-led research is completely voluntary and is not required to use any of our products or services. Even if you consent to participate in the research, you may withdraw your consent at any time, but your information will not be removed from research that is in progress or completed. We encourage you to carefully read the full text below before deciding whether to give consent.
The full text of the Informed Consent is below and explains the following:
- What is the Leadership Research Mission?
- What am I agreeing to if I consent?
- Who conducts the research?
- What Personal Information is used?
- How is my Personal Information used and shared if I give consent?
- How is my Personal Information protected?
- If I consent, will CCL or Collaborators and Collaborator Partners contact me?
- Are there any risks to me?
- Are there any costs if I consent? Do I receive compensation or other benefits if I consent?
- Do I have to consent to the Mission?
- What is my alternative to participating?
- Can I withdraw from the Mission?
- Who can I contact about the Mission?
FULL INFORMED CONSENT
1.) What is the Leadership Research Mission?
At CCL, part of our mission is to advance research related to the study of understanding, practice and development of leadership for the benefit of society worldwide. One way we do that is to offer you the opportunity to participate in research performed in the United States and in other countries designed:
- To create new product concepts aligned with CCL’s strategies,
- To generate new paradigms useful to leadership development,
- To create new methods and processes for developing leaders, and
- To transfer advances from the social sciences into the realm of leadership development
(together, the “Purpose”).
We refer to all research focused on the Purpose that CCL or others may do over time as the CCL Leadership Research Mission (the “Mission”). We refer to CCL and our affiliated companies collectively as “CCL,” “us,” “we,” or “our.”
2.) What am I agreeing to if I consent?
By giving consent to participate in the Mission, you agree that all Personal Information that you share with us (as further described below), including:
(a) through your use of our websites, mobile applications, products, or in-person evaluations that exist now, or in the future (“CCL Services”, as further described in our Participant Terms of Service), and/or
(b) through CCL’s independent research activities,
can be collected and used for CCL-led research consistent with the Purpose and the Mission.
CCL’s Mission is largely focused on adults, but CCL’s Mission also encompasses minors (generally, ages 8 to 18) in school and educational settings through CCL’s Societal Advancement division. By agreeing to this document on behalf of a minor, you represent that you are the minor’s parent or legal guardian. You hereby explicitly consent to the collection and processing of Personal Information concerning such minor, and you represent and warrant that you have authority to do so.
This Informed Consent is not meant to cover research activities that are performed by CCL specifically as a service for clients or individuals. Such research services are within the scope of “CCL Services” that are addressed in our Participant Terms of Service and associated Participant Privacy Statement. That said, any later, CCL-led research using data collected from any such research activities performed as a service, are appropriately covered by this Informed Consent.
Also, for clarity, this Informed Consent is not applicable to the research that is already covered by CCL’s contractual relationship with you or CCL’s legitimate interest, such as is the case with already-covered research for CCL development of current products or enhancement of customer experience as described by our Participant Terms of Service, Participant Privacy Statement, and Marketing Privacy Statement. This Informed Consent is meant to cover a broader range of CCL-led research activities.
3.) Who conducts the research?
Employees of CCL perform some of the research for the Mission. We also work with researchers from other organizations and companies who share our Purpose. This might include academic institutions as well as non-profit and for-profit businesses and/or government agencies (“Collaborators”).
These Collaborators may also work with other entities to conduct research associated with our Purpose (“Collaborator Partners”). The research for the Mission may be performed solely by us, or by Collaborators with or without help from CCL researchers or Collaborator Partners. All researchers, whether affiliated with CCL, our Collaborators, or Collaborator Partners are referred to in this Informed Consent as “Researchers.”
Find out more about our Collaborations here.
4.) What Personal Information is used?
When you give consent, Researchers may use all your Personal Information that you provide to us, including without limitation:
- General Personal Information about you: information that you share with us when you register, create a profile, or use your account, and information we obtain from other sources, such as publicly available sources, like LinkedIn and other social media sties, or demographic information; and
- Leadership Development Information from CCL Services: “Your Leadership Development Information” is the leadership-development-related Personal Information (identifiable to you) that CCL collects and processes in the course of delivering CCL Services. As part of CCL Services, CCL may offer certain supplemental services (“Supplemental CCL Services”). These Supplemental Services include without limitation:
- individual, team, organization, and community tools, assessments, and surveys (including without limitation, psychology and personality assessments, and 360-degree feedback tools),
- executive coaching,
- in-person evaluations, such as end-of-day or end-of-module reviews and feedback,
- focus-groups and interviews,
- audio and video recordings and photos to assess and improve speaking skills and group discussion dynamics in meetings,
- assessment of health (including ethnicity, medical history, and fitness),
- analysis of blood or other biological samples,
- and/or analysis of your social media content.
Thus, Your Leadership Development Information will include, where you have agreed to the Participant Terms of Service and have chosen to participate in any Supplemental Services, the Personal Information that you provide in the course of engaging in any such Supplemental Service.
Please note that your participation in Supplemental Services may lead to disclosure of Sensitive Personal Information. “Sensitive Personal Information” is defined as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
- Personal Information generated in CCL-Initiated Research: the information that you may share with CCL researchers, or their collaborators, when you engage their invitations to participate in focus groups or one-on-one interviews (whether live, or through telecommunications) and/or any of the assessments or activities that may be used in the research study and which are referred to in the context of CCL Services as “Supplemental Services” as described above.
- Additional Personal Information that may be shared in the future: other information you voluntarily share with us as we expand our CCL Services and activities, such as:
- Biosensor Personal Information recorded by mobile phones or activity trackers or health and wellness data collected from other devices. You are under no obligation to share additional data with us. However, if you do and you have given consent to participate in the Mission, it may be used by the Researchers.
We take your privacy seriously and value the trust you put in us when you allow us to use your Personal Information. Our privacy statements describe how we handle your Personal Information and our compliance with applicable laws for cross- border transfers of Personal Information. As part of the Mission, Researchers outside the United States may access and use your Personal Information. If this occurs, those further cross-border transfers of Personal Information will be made in compliance with the mechanism described in our privacy statements. For more information, refer to our privacy statements.
5.) How is my Personal Information used and shared if I give consent?
If you decide to participate, the Researchers may use your Personal Information, for:
- research that is consistent with our Purpose; and
- publication of research in journals, books, blogs, newspapers, and in other publications and presentations, provided that names, contact information and other common identifying information is always removed prior to making any research public.
Personal Information may be shared with Collaborators and Collaborator Partners, but whenever possible, will be shared without your name, contact information or other common identifying information. When not possible to share without identifying information, such as with video or audio content that is itself inherently identifiable information, your Personal Information will be shared under confidentiality obligations from our Collaborators and Collaborator Partners.
When we collaborate with government agencies on research, we take all necessary steps to protect the privacy and integrity of your Personal Information in accordance with laws and regulations pertaining to government funded research. In some instances, if we partner with, or our research is funded by, certain U.S. agencies, we may be required to contribute certain Personal Information to a national database that will be accessible by other researchers. In the event such contribution is required, we will only provide Personal Information that has had identifying information removed in accordance with U.S. federal regulations.
Your Personal Information may also be shared with others who review the quality and safety of the research (for example, regulatory agencies or an institutional review board at a university). Unless we have your explicit consent, we will never knowingly disclose or interpret your Personal Information for use by employers or insurers for employment or insurance purposes.
6.) How is my Personal Information protected?
As described in our privacy statements, we use multiple layers of physical, technical, and administrative procedures to protect your Personal Information from unauthorized access while conducting our business. These same procedures are used by us to protect your Personal Information used in the Mission. In addition, we require our Collaborators and Collaborator Partners to use similar physical, technical, and administrative procedures to protect the Personal Information we share with them.
7.) If I consent, will CCL or Collaborators and Collaborator Partners contact me?
We, CCL, may contact you from time to time to request additional information for the Mission, like a survey about your leadership behaviors. You are not required to respond to any requests from us about the Mission – the choice is yours. If you do not respond or do not want to provide additional materials for the Mission, we may continue to use your Personal Information as permitted by this Informed Consent but for no additional purpose.
Also, if we or a Collaborator wants to use your Personal Information in a manner beyond what is described in this Informed Consent or to conduct research unrelated to the Purpose, we will first contact you to see if you’re interested in hearing about this new research opportunity and if you are interested in possibly providing additional informed consent.
8.) Are there any risks to me?
There are no physical risks involved with having your Personal Information used in this Mission. There are some potential risks to participating in the Mission as follows:
- Researchers may have access to my Personal Information in formats that reveal personally identifiable information.
- Personal Information about you could become public as the result of a security breach. Although we have strong policies and processes in place designed to minimize the possibility of a security breach (see the controls described above) and we require our Collaborators and Collaborator Partners to have similar controls, we cannot provide a 100% guarantee that a breach will never happen.
- When Researchers publish results from the Mission, such results may include your Personal Information, but only as part of aggregated results across many people to minimize the chance that your Personal Information is identified. But it is possible that third parties could identify you from research that is made publicly available, for example if they are able to combine Personal Information with other information about you that is available to them that links the Personal Information to your name or other common identifying information. However, identification of your individual Personal Information would be extremely difficult because your information would be published as part of an aggregated summary of information for many people and without any common identifying information.
- If we were to provide you with information about your Personal Information, you may learn information about yourself that you do not expect or that makes you uncomfortable, such as your potential health risks or 360-dgree feedback data.
There may be additional risks to participation that are currently unforeseeable.
9.) Are there any costs if I consent? Do I receive compensation or other benefits if I consent?
There is no cost to you individually for consenting to CCL’s use of your Personal Information in the Mission. (Of course, you or your organization may have paid for a CCL Service from which data was generated. Also, please note that if you or your organization wishes to engage CCL to generate research work, there are associated charges.)
There is no monetary benefit to you consenting to use of your Personal Information in the Mission, but CCL and its collaborators often provide research results as an incentive for your participation in CCL-initiated research efforts. You will, however, enjoy the satisfaction and sense of purpose of having supported CCL’s non-profit Mission.
10.) Do I have to consent to the Mission?
No, your participation is voluntary. No one is required to participate in the Mission. If you choose not to participate in the Mission, you can still use our CCL Services, including obtaining your Leadership Development Information in connection with the assessment, program, or other CCL Services. We do not consider the participation of an employee, or an employee’s relatives, in the Mission when making employment or benefit decisions. No one should influence or pressure you to participate in the Mission.
11.) What is the effect of not giving my consent?
If you are a participant in CCL Services, you will still receive your normal results from CCL regardless of your consent to use your Personal Information broader research, but your Personal Information (your personally identifiable information) will not be used for the broader Mission of Leadership Research.
If you are volunteer in CCL initiated research activities, you may still receive any results of assessments or feedback promised to you in consideration of participating in research, regardless of your consent to use your Personal Information broader research, but your Personal Information (your personally identifiable information) will not be used for the broader Mission of Leadership Research.
A note about aggregated data:
CCL may disclose user information in an aggregated or otherwise anonymized form as part of the CCL Services, in marketing, or in research and in publications published by us or our research partners. For example, we might note the percentage of participants that are from a particular geographic region or country. Such disclosure will never include Personal Information, that being, information that can identify you as a living individual.
12.) Can I withdraw from the Mission?
Yes, you can withdraw your consent at any time. Until you withdraw or we end the Mission, there is no limit to how long we will use your Personal Information for the Mission. If you withdraw, we will cease using your Personal Information for the Mission within 30 days and the Personal Information will not be used in future research. However, Personal Information cannot be withdrawn from research already in progress or completed, or from published results and findings. In those cases, Researchers may have access to such Personal Information about you indefinitely. There is no negative impact to you for withdrawal of your consent, and you will continue to be able to use our CCL Services as before. If you want your Personal Information destroyed or your Personal Information deleted from CCL products and services, we will promptly do so at your request but additional steps are required. Please contact the applicable number below for assistance.
Note that aggregated or anonymized information is not considered your Personal Information, or Personal Information or Your Leadership Development Information since it cannot be linked to you as an individual living person; and therefore aggregated or anonymized information will not be deleted.
This Informed Consent does not have an expiration date. If you do not withdraw consent, it will remain in effect until you withdraw or we end the Mission.
13.) Who can I contact about the Mission?
Please contact us if you have any concerns or questions about the Mission:
Center for Creative Leadership
Attn: Client Services
1 Leadership Place
Greensboro, NC 27410
+1 336 545 2810
In accordance with applicable law, you may have a right to seek access to, rectification of, or object to use of your Personal Information. You may contact us and your local data protection regulator (if you are in the EU) should you wish to lodge a complaint about our handling of your Personal Information.
If you have a question about our processing or would like to exercise one of your rights, please contact our Data Protection Officer:
a) by e-mail (firstname.lastname@example.org); or
b) by mail:
DPO, Legal Department
Center for Creative Leadership
rue Neerveld 101-103
1200 Brussels, Belgium
Also, note CCL’s contact address in the USA:
Center for Creative Leadership
1 Leadership Pl
Greensboro, NC 27410, USA
This Informed Consent for CCL-Led Research is available on our CCL website, but we encourage you to print a copy for your records.