In pursuit of the Center for Creative Leadership (“CCL”) mission to advance the understanding, practice and development of leadership for the benefit of society worldwide, CCL must gather, retain, and use data provided to us by organizations and individuals. Thus, CCL holds in highest regard the trust placed in us by our clients. CCL is committed to protecting your Personal Information. CCL subscribes to the American Psychological Association and other appropriate international industry standards, and CCL uses three guiding principles concerning your privacy:
- Simplicity. We try to use simple language to help you make informed choices
- Transparency. We aim to be transparent about what Personal Information we collect and process.
- Control. We give you control over the Personal Information that you provide to us, including all Your Leadership Development Information.
You always maintain ownership of your Personal Information and you can manage and delete it as described in this Privacy Statement.
You should feel informed and confident about how CCL, as a top-ranked, global provider of executive education, collects and processes your Personal Information. CCL’s Privacy Statement is below.
Effective Date: May 25, 2018
The “CCL Services” are the services that CCL provides, including without limitation:
- leadership development courses and programs,
- individual, team, organization, and community tools, assessments, and surveys (including without limitation, psychology and personality assessments, and 360-degree feedback tools),
- executive coaching; and
- knowledge generation, research, and producing custom publications.
CCL may deliver CCL Services in person or over CCL Websites and Mobile Apps. “CCL Websites and Mobile Apps” including without limitation:
- www.ccl.org, the myCCL service, and Internet Assessment System (IAS),
- product blog sites (for example, www.toxicbosses.org; http://www.experiencedrivendevelopment.com and www.ccl-explorer.org)
- any social media platforms used by CCL (for example, Facebook, LinkedIn, Instagram, Twitter, Pinterest, and YouTube);
- and/or other partner websites or mobile apps that link to these Participant Privacy Statement.
2.) Account Creation and Your Engagement with CCL Services
The Personal Information required to create a basic CCL account is only your name, an email address, and a password. Use of assessments, 360-degree feedback tools, engaging in courses or attending leadership development programs, may require additional personal information, including payment details, and Leadership Development Information.
Account creation also requires you to agree to the Participant Terms of Service and this Privacy Statement by clicking to continue on the account creation page.
By clicking to continue, you are telling us that you consent to CCL collecting, processing, and sharing your Personal Information (including Your Leadership Development Information) as described in this Privacy Statement and in any other documents referenced in this Privacy Statement.
At any time, you can request CCL delete Personal Information that you have uploaded into your account. Please see Section 10 for specific details about deleting your data.
If you no longer wish to have a CCL account, please contact us and we will help you close your account.
3.) What Information Does CCL Collect From You?
The table below describes the information we collect from you to provide the CCL Services. In this Privacy Statement, we refer to this as your “Personal Information.”
- Your name
- Your title
- Your organization’s name
- An email address
- A password that you provide us when you create an CCL account
- A mobile phone number that you may voluntarily provide so we can notify you of assessment results or course status, or respond when you contact CCL
Credit Card/Payment Information
Payment information, such as your credit card number, and your billing and shipping address (es), when you purchase something from CCL, such as a CCL book, workshop kit, other tool, or enroll in a program or course.
We collect the information that you provide when you voluntarily create a user profile. This information may be seen by other CCL users
Additional personal details that you provide in your profile (for example, a profile image, your name, your title, your organization, age, location, etc.), will be visible to other CCL users.
User Provided Content
Information you provide about yourself or other living individuals when you voluntarily contribute to the Services, or participate in community discussions.
For example, you might contribute details (including stories, images, or videos) about leadership development goals or challenges of yours or others, or annotate CCL content or records.
Information about deceased persons is not Personal Information under this Privacy Statement.
Social Media Information
If you use a social media site to log into CCL Services, we collect information from your social media profile that you choose to provide to us (for example your LinkedIn profile information).
Additional User Information
Information that you provide to us when you answer email surveys or online questionnaires offered through the CCL Services.
Your 1:1 communications with other CCL users through our communications features, as well as information you provide in communications with CCL.
Contests and Promotions
Personal Information when you voluntarily participate in contests and special promotions we run through our Services.
Your Leadership Development Information
“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 group discussions 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 choose 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.
You always have the option to decline any segment of CCL Services, including any Supplemental CCL Services. By agreeing to CCL’s Participant Terms of Service, you explicitly consent to the collection and processing of your disclosed Sensitive Personal Information in connection with provision of Supplemental CCL Services in which you choose to participate, and you also explicitly agree to the related provisions set forth in Section 2 (“Involvement of Third Parties in Supplemental CCL Services and Use of Your Leadership Development Information”) of the Participant Terms of Service.
*A note about your biological sample(s): Once any diagnostic or measurement kit or laboratory partner has produced an analysis on your biological sample(s), your biological samples are destroyed.
4.) What Information Does CCL Collect Through Your Use of the CCL Websites and Mobile Apps? Computer and Mobile Device Information
Information about how you access our Services, including the website you visited before and after CCL Websites and Mobile Apps.
The Internet protocol (“IP”) address of your computer, mobile device, or the proxy server that you use to access the Internet, in addition to other technical information, such as:
- Your computer operating system, and
- Your web browser.
- Your mobile device identifier provided by your mobile device operating system and your mobile operating system.
- The name of your internet service provider or mobile carrier.
Information from Cookies and similar technologies
Information shared through social media features
If you interact with social media through the CCL Services, for example “Like,” “Tweet,” “Pin,” or “Follow Us” links to sites such as Facebook, Twitter, Pinterest, Instagram, and YouTube, CCL will collect these interactions and whatever account information these services make available to us.
Your interactions with these features are governed by the Privacy Statement of the applicable third party company.
Information from your use of the CCL Websites and Mobile Apps
Information about your use of the CCL Websites and Mobile Apps, such as when you search or access product or service offerings, which pages you view or links you click on, or when you interact with other users of CCL Websites and Mobile Apps.
5.) Information We Collect from Other Sources Information, information from Your Employer (or School or any other Sponsor)
We may also receive information about you from your employer (school or sponsor), if such party has engaged CCL Services for your benefit.
Information from Public Records
CCL may collect records from various public sources, like official record sources, including newspapers and other media, which may contain Personal Information relating to you.
Information from Third Parties
We may also receive information about you from third parties. For example, we may supplement the data we collect with demographic information licensed from third parties in order to personalize the Services and our offers to you.
6.) How does CCL use your Personal Information?
Personal Information (generally)
We use your Personal Information to provide, personalize, improve, update and expand our CCL Services. This includes:
- Authenticating your access to the Services and improving CCL information security;
- Processing your payments for subscriptions/ accounts, CCL Services;
- Building new and improving existing products and CCL Services;
- Helping you progress, and providing insights about, your leadership development based on Your Leadership Development Information;
- Issuing surveys and questionnaires to collect Additional User Information for use in the CCL Services, as well as facilitating product development and research initiatives;
- Conducting scientific, psychological, statistical and historical research; and
- Detecting and protecting against error, fraud, or other criminal or malicious activity and enforcing our Participant Terms of Service.
We use your Personal Information to communicate with you about the Services, such as when we:
- Respond to your inquiries to Member Services;
- Inform you of product changes or new products and services;
- Ask you to participate in CCL media productions or testimonials; and,
- Provide you with information or request action in response to technical, security, and other operational issues.
Market new products and offers from us or our business partners.
We use your Personal Information to market new products and offers from us or our business partners. This includes advertising personalized to you based on your interests.
Your Leadership Development Information
CCL uses Your Leadership Development Information for the following primary purposes:
- Delivering leadership development insights, and other information to help you learn more about yourself and your organization;
- Connecting you with other users of CCL Services, with whom you may have common interests, and also in the grouping of course or program cohort members into teams with contrasting or complementary personality and psychology profiles for the purposes of demonstrating group dynamics;
- Providing you insights based on your individual, team, organization, and community tools, assessments, and surveys (including without limitation, psychology and personality assessments, and 360-degree feedback tools);
- Providing you insights based on your personal health, fitness, and wellness data;
- Studying aggregated leadership development information to better understand leadership development trends in various population groups;
- Conducting scientific, psychological, statistical, and historical research;
- Improving features and functionality in our existing leadership development products, enhancing the customer experience across CCL Services and products, improving the quality of our processes and technology, and building new products and services; and
- and we may also invite you to participate in further surveys and questionnaires, or other CCL Services (entirely optional) based on the foregoing insights.
By agreeing to our Participant Terms of Service, you consent to our collection and processing of Sensitive Personal Information (for example, health history) as required for your elected interactions with CCL Services.
7.) When Do We Share Your Information and who are the Recipients?
CCL does not share your individual Personal Information (including Your Leadership Development Information) with third-parties without your additional consent other than as described in this Privacy Statement. In particular, unless we have your express consent to do so, we will not share Your Leadership Development Information with insurance companies, third-party marketers, employers, schools or other sponsors (even when these parties have engaged and pay CCL for the CCL Services for your benefit). The circumstances described below explain when sharing might occur:
Other CCL Users or others you may choose to share with
Any information you add to your CCL profile may be seen by other CCL users, as will postings or comments to group discussions.
If you share details of Your Leadership Development Info with parties outside of CCL, you do so at your own risk.
We use other companies to help us provide the CCL Services to you. As a result, these partner companies will have some of your information in their systems. Our partners are subject to contractual obligations governing data security and confidentiality consistent with this Privacy Statement and applicable laws.
These processing partners include our:
- Executive coaches;
- Psychology and Personality Assessment providers, including 360-Degree Feedback Tool providers;
- Audio-visual technicians, production companies, and photographers
- Communication and Speech specialists and associated analytical software tool vendors
- Health and Fitness instructors and Medical professionals
- Laboratory partners;
- Biological sample storage facilities; and
- Shipping providers;
- Payment processors;
- Cloud services infrastructure providers;
- Website and Mobile App Platform hosting services and partners
- Vendors that assist us in marketing; analytics, and fraud prevention.
We share Personal Information, including Your Leadership Development Information, with research partners only when you provide us with your express consent to do so through our Informed Consent to CCL-Led Research.
Research partners may include commercial or non-profit, or academic organizations that conduct or support scientific, psychological, statistic, or historic analysis of leadership development. In some circumstances, a research partner or CCL may have a financial interest in the research arrangement. A list of our research activities can be found here.
Legal or Regulatory Process
We may share your Personal Information if we believe it is reasonably necessary to:
- Comply with valid legal process (e.g., subpoenas, warrants);
- Enforce or apply the CCL Participant Terms of Service;
- Protect the security or integrity of the CCL Services; or
- Protect the rights, property, or safety, of CCL, our employees or users.
If we are compelled to disclose your Personal Information to law enforcement, we will do our best to provide you with advance notice, unless we are prohibited under the law from doing so.
If CCL is Acquired
If CCL or its businesses are acquired or transferred (including in connection with bankruptcy or similar proceedings), we will share your Personal Information with the acquiring or receiving entity. The promises in this Privacy Statement will continue to apply to your Personal Information that is transferred to the new entity.
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 psychology and science 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.
8.) Your Choices and Access to Your Personal Information
Subject to certain exceptions, you have a right to request access to your Personal Information and to be provided with a copy of certain information you provided in a portable form, as well as to seek to update, delete or correct this information by using the tools described below or by contacting CCL. Details and options for accessing this information are listed below.
You can access and update the Personal Information (such as your email address, username, profile information, etc.) that you provide to CCL at any time.
You can also control your information using the settings available in CCL’s mobile applications.
Obtaining Your Leadership Development Information
Your Leadership Development Information belongs to you. You always have the option of obtaining Your Leadership Development Information. Please contact us for details on how we can best transfer the desired parts of Your Leadership Development Information to you.
9.) What are CCL’s retention practices?
CCL Services are fundamentally premised on the notion that the personal journey of leadership development and self-discovery is not a one-time event and continues over lengthy periods of time. Additionally, and with particular regard to our subscribers / account holders, the ongoing enhancement of CCL Services and product offerings provide benefits and insights to our users over time. As a result, CCL’s retention practices reflect this ongoing value by retaining user accounts on our system until our users inform us of their desire delete to their data or close their accounts.
In some cases we choose to retain usage information (e.g., visits to sites) in a depersonalized or aggregated form. Once aggregated, this information ceases to be personal and will not be subject to CCL user deletion requests.
10.) How can I delete my Personal Information?
You can delete your Personal Information from CCL in a number of ways.
You can delete your Personal Information from CCL in a number of ways through the settings linked above.
If you require assistance deleting Personal Information you provided as part of your profile or subscription or from our blog or community forum, please submit a deletion request (including the exact wording of the information as it appears on the websites, and the URL where that information is found) to our Data Protection Officer by e-mail (firstname.lastname@example.org).
To the extent you have shared information through the CCL Services (for example, by sharing Personal Information directly with other users), CCL will not be able to remove any copies of information that other CCL members may have retained.
CCL may hold records that contain your Personal Information that we are obligated to maintain as archives. Please direct any request to remove information from linked archival records to the responsible archival entity.
Note: If you request that CCL delete your Personal Data, we will delete from our production, development, analytics, and research systems within 30 days.
Please note that if you have agreed to our Informed Consent to CCL-Led Research, we will not be able to remove Your Leadership Development Information from active or completed research projects, but we will not use it for any new research projects.
Note again that aggregated or anonymized information is not considered 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.
Please note that there may be some latency in deleting your Personal Information from our backup systems after it has been deleted from our production, development, analytics, and research systems. Also, our laboratory partners may retain information they receive from us in order to comply with laws or regulations that may require them to do so, such as the Clinical Laboratory Improvements Amendments regulations administered by the U.S. Food and Drug Administration. CCL may also retain certain information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.
CCL maintains a comprehensive information security program designed to protect our customers’ Personal Information using administrative, physical, and technical safeguards.
The specific security measures used are based on the sensitivity of the Personal Information collected. We have measures in place to protect against inappropriate access, loss, misuse, or alteration of Personal Information (including Your Leadership Development Information) under our control.
CCL’s Security Team regularly reviews our security and privacy practices and enhances them as necessary to help ensure the integrity of our systems and your Personal Information.
We use secure server software to encrypt Personal Information (including Your Leadership Development Information), and we only partner with security companies that meet and commit to our security standards. While we cannot guarantee that loss, misuse or alteration of data will not occur, we use reasonable efforts to prevent this.
It is also important for you to guard against unauthorized access to your Personal Information by maintaining strong passwords and protecting against the unauthorized use of your own computer or device.
Finally, we also have a Security Plan that describes the technical manner in which CCL addresses threats or hazards to the confidentiality, integrity, and availability of any data in CCL’s possession. Please contact us to obtain a copy of the Security Plan.
12.) Data Transfer
Any transfer of your Personal Information from the EU to CCL’s U.S.-based company for processing in the United States is conducted pursuant to established transfer mechanisms such as Standard Contractual Clauses
You can request a copy of any standard contractual clauses relating to your Personal Information that we may have executed by contacting us using the details below.
13.) Changes to this Statement
We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as posting a notice through the Services, on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services.
We will also notify you of non-material changes to this Statement as of their effective date by posting a notice through the Services, on our websites, or sending you an email. Your continued use of our Services after notice of non-material changes means that you consent to the updated Privacy Statement.
If you object to any changes, you may delete your account by contacting us.
14.) California’s Shine the Light Law
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits Users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, CCL currently does not share any Personal Information with third parties for their own direct marketing purposes.
15.) Legal basis under EU General Data Protection Regulation for processing personal information of EU residents.
Where you have consented to data processing, your consent provides the legal basis to process your Personal Information. We rely on your explicit consent to process Your Leadership Development Information, including any Sensitive Personal Information. You have the right to withdraw consent at any time. Please note that your withdrawal of consent to collect and process your Personal Information will not affect the lawfulness of processing your Personal Information based on your consent before you withdrew your consent.
We may also process your Personal Information on the basis of contractual necessity to perform a contract we have with you or your employer. For example, we process your credit card details when you provide them in order to use our Services or purchase access to CCL Services.
We may also process your Personal Information on the basis of our legitimate interests, including in providing and improving the Services. For example, CCL has a legitimate interest in understanding your login history so we can assess your interaction with our Services. We also have a legitimate interest in providing and developing interesting features to provide to our users. We use your Personal Information to keep our Services safe and secure and we do so as it necessary to pursue your and our legitimate interests in ensuring that our Services are secure, and to protect against fraud, spam and abuse.
Where we rely on legitimate interests to process your Personal Information, you have the right to object to such processing (meaning that you can ask us to stop). You can also contact us, using the details below, to object to other forms of processing.
16.) Contact Details
If you have a question about our processing or would like to exercise one of your rights set out below, please contact our Data Protection Officer:
- by e-mail (email@example.com); or
- 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