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Welcome to The Growth Company Limited privacy notice for the Made Smarter Programme.
[Version 4.0 - Jan 2021]

We recognise the importance of the privacy and the security of your personal information and this privacy notice explains what we do to look after your personal data.

It tells you:
• Where and how we collect your personal information
• What we do with your information and how we keep it secure
• What your privacy rights are and how the law protects you
• How we look after your personal data
• Your rights over any personal information we hold about you
• How to contact us with any queries that you have

Please use the Glossary at the end of the privacy notice to understand the meaning of some of the terms used here.

1. Important information and who we are
  • a. What does this privacy notice cover?

    This privacy notice applies to you if you work with us as part of the Made Smarter Programme. Whether this is online, by phone, in person, through written forms. This privacy notice gives effect to our commitment to protect your personal information acting as The Growth Company Limited.

    It is important that you read this privacy notice together with any other privacy information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

  • b. Who we are

    The Growth Company Limited is a not-for-profit organisation which drives business, economic, personal and professional development within communities by boosting employment, skills, investment and enterprise for the benefit of all. As part of the Made Smarter Programme we are working with the Greater Manchester Combined Authority (GMCA) who are funding the programme. The GMCA is a body with various powers that is funded by the public and tries to make changes to improve the lives of everyone who lives in Greater Manchester. It has representatives for the people of Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan. These people all work together with the Mayor of Greater Manchester, Andy Burnham.

    As we are working together closely on this Programme it has been decided that both The Growth Company Limited and the GMCA are Data Controllers for the personal data used to deliver and evaluate the programme.

    The Growth Company Limited have appointed a data protection officer (DPOwh) o is responsible for overseeing questions in relation to this privacy notice across The Growth Company Limited. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

  • c. Contact Us

    If you would like to exercise one of your rights as set out in this privacy notice, or you have a question or a complaint about this privacy notice or the way your personal information is processed, please contact us by one of the following means:

    By email: DPOfficer@growthco.uk

    By post: Data Protection Officer, Lee House, 90 Great Bridgewater Street, Manchester M1 5JW.

    You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Go to ico.org.uk/concerns to find out more. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  • d. Changes to this privacy notice and your duty to inform us of changes

    This version was last updated in August 2020 and any historic versions can be obtained by contacting us.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  • e. Third Party Links

    Our website and other documents you receive from us may include links to third-party websites, plug-ins and information. Following these links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

2. The data we collect about you
  • The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We will collect, use, store and transfer different kinds of personal data about you depending on how you engage with Made Smarter which we have grouped together as follows (with examples of each data type):
    • Identity Data includes first name, last name, username or similar identifier, title, and gender.
    • Contact Data includes business address(s), email address and telephone numbers.
    • Financial Data includes bank account, payment card details and details about payments from you and other details of products and services procured as part of the Made Smarter Pilot.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Profile Data includes your username and password, your preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate the number of participants on the programme that have accessed a service. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    If you fail to provide personal data:
    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?
  • How is your personal data collected?

    We use different methods to collect data from and about you including through:

    Direct interactions: You may give us your Identity, Contact, Employment & Educational, Financial Status, Payment and Marketing & Communications Data in person, by filling in forms on paper, online or electronically, by corresponding with us by post, phone, email or otherwise or providing information as part of a contract.

    This includes personal data you provide when you:

    • apply for our services
    • apply to provide goods and/or services to us
    • create an account on our website
    • submit information via our website
    • subscribe our service or publications
    • request marketing to be sent to you
    • enter a competition, promotion or survey
    • give us some feedback or evaluate our services

    • Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy on our website for further details.

    Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources (such as when a referral into the Made Smarter programme is judged to be beneficial to an organisation or individual).

    The data received is as set out below:

    • Identity, Contact, Payment and Financial Status Data from data brokers or aggregators, including credit reference agencies.
    • Technical Data from analytics providers and advertising networks.
    • Financial Status and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
    • Identity, Contact, Marketing & Communications and Technical Data from third party delivery partners, including those who fund, licence and co-deliver our activities and those who refer clients to us. Examples include government bodies, non-departmental public bodies, private companies, membership organisations and external consultants.
    • Identity, Contact, Profile, Usage, Marketing & Communications, Employment & Educational, Payment and Financial Status Data from third party website portals into which you have entered your personal data.
    • Student Placement Information, where a student has been placed into an SME as part of the Made Smarter programme: Student Name, employment/placement arrangements, evidence of defrayal (payment).
    • Leadership and Management Training Information, where representatives from an SME have signed up for an attended the Leadership and Management training part funded by the Made Smarter Programme: Delegate name, phone number, email, job title, business information.
4. How we use your personal data
  • Introduction

    The Growth Company Limited will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation. More information about the lawful basis we use is found in the Glossary.

    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message or where required to process Special Category Data. You have the right to withdraw consent to marketing at any time by contacting us.

  • a. Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


    Type of data

    Lawful basis for processing including basis of legitimate interest

    To register you as a new customer/engagement

    a) Identity
    b) Contact
    c) Business Information

    a) Performance of a contract with you
    b) Necessary for our legitimate interests in developing our relationship with you as a potential client

    To deliver agreed services to you (or prepare for their delivery)

    a) Identity
    b) Contact
    c) Profile
    d) Technical
    e) Usage
    f) Marketing &

    a) Performance of a contract with you
    b) Necessary for our legitimate interests in (i) delivering a service we offer, and (ii) tracking and reporting on contract progress

    To manage our relationship with you which will include:
    a) Managing your account and providing services support
    b) Notifying you about changes to our terms or privacy notice
    c) Asking you to leave a review or take a survey

    a) Identity
    b) Contact
    c) Profile
    d) Marketing and

    a) Performance of a contract with you
    b) Necessary to comply with a legal obligation
    c) Necessary for our legitimate interests in keeping our records updated and studying how customers use our products/services)

    To use data analytics to measure and report on the performance of our services

    a) Identity
    b) Contact
    c) Usage
    d) Profile

    a) Performance of a contract with you
    b) Necessary to comply with a contractual obligation to the funders BEIS and GMCA
    c) Necessary for our legitimate interests in keeping our records updated and studying how customers use our products/services)

    To administer our day-to-day business operations, including (i) enabling you access our facilities and/or services, (ii) meeting our legal obligations in carrying out our business, (iii) assessing applications to deliver services to us, and (iv) appointing oversight bodies to govern and advise on our activities


    a) Identity
    b) Contact
    c) Usage
    d) Profile

    a) Performance of a contract with you
    b) Necessary for our legitimate interests in ensuring our business functions are cost-effective, compliant and accessible

    To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including measure or understand the effectiveness of our website and products / services

    a) Identity
    b) Contact
    c) Profile
    d) Usage
    e) Marketing &
    f) Technical

    a) Necessary to comply with a legal obligation
    b) Necessary for our legitimate interests
    (i) in running our business, providing administration and IT services, ensuring network security, preventing fraud and in the context of a business reorganisation or group restructuring exercise, (ii) in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

    To make suggestions and recommendations to you about goods, services, opportunities or events that may be beneficial or of interest to you

    a) Identity
    b) Contact
    c) Profile
    d) Marketing &

    a) Necessary for our legitimate interests in developing our products/services and growing our business
    b) Your consent, where this is required by law

    Collect and provide specific data required by the GMCA to support the evaluation of the programme in Greater Manchester and nationally.

    a) Identity
    b) Contact
    c) Profile
    d) Financial Status
    e) Technical
    f) Business Information

    a) Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

    Feedback and performance data for stakeholders, delivery partners and interested parties (e.g. LEPs & Catapults)

    a) Business Information
    b) Aggregated Data
    c) Anonymised data
    d) Redacted Data

    a) Necessary for collaboration, e.g. to provide feedback on the number and quality of referrals or leads

  • b. Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

    You will receive marketing communications from us if you have requested information from us or if we can demonstrate that we have a legitimate interest in sending marketing material to you (and you have not opted-out).

    We will get your express opt-in consent before we share your personal data with any company outside The Growth Company Limited group for marketing purposes.

    You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

  • c. Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy on our website.

  • d. Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data
  • Disclosures of your personal data

    We will have to share your personal data with the parties set out below for the purposes set out in the table above.
    • Internal Third Parties as set out in the Glossary.
    • External Third Parties as set out in the Glossary.
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes  and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Disclosures of aggregated data
  • Disclosures of aggregated data

    The table above shows that in addition to non-aggregated data, we will provide aggregated data to enable the Made Smarter programme to be evaluated. The evaluation of this type of programme is very important. It helps the organisations that fund programmes make sure they are investing public money into the right services.

    The GMCA have appointed Steer Development Limited to undertake the evaluation work. The data they provide to Steer Development will also identify you as an individual to enable contact with you to be made.

    Steer cannot use the data for their own purposes and are only permitted to process the data for specified purposes and in accordance with GMCA instructions.

    None of the work produced as part of the evaluation will be used to make any decisions about you. It will be used for improving the quality, effectiveness and delivery of this and similar programmes across Greater Manchester and nationally.

    The outcome of the evaluations may also be included in publicly accessible reports. This information will be mainly charts, diagrams and numbers. You will therefore not be able to be identified from any of the information used or published in this way.

    Supporting the improvement in services as explained above is important. It really helps make services better for you and your communities.

    The GMCA will also provide the same aggregated data to the Department for Business, Energy and Industrial Strategy (BEIS). This will be used for looking the effectiveness of these types of programmes nationally.

    If you want to know exactly what data is being provided to the GMCA please contact us and we can supply you with the list.

7. International Transfers
  • International Transfers

    In some circumstances we may transfer data to, and store data in, countries which are outside the United Kingdom, particularly if we offer you a service which is delivered in close collaboration with countries outside the UK. 

    If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the UK. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these arrangements please contact our Data Protection Officer.

    Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. 

8. Data security
  • Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention
  • Data retention

    How long will you use my personal data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

    For the purposes of the Made Smarter Programme The Growth Company Limited will retain your personal data for a period ending the 31st of March 2032. This retention period is a contractual requirement and condition of the funding provided by BEIS in order to deliver the support delivered in the Made Smarter North West Pilot.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights
  • Your legal rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data.

    Please refer to the Glossary below to find out more about these rights:
    • Request access to your personal data
    • Request correction of your personal data
    • Request erasure of your personal data
    • Object to processing of your personal data
    • Request restriction of processing your personal data
    • Request transfer of your personal data
    • Right to withdraw consent

    If you wish to exercise any of the rights set out above, please Contact us.

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary
  • a. Lawful basis

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

    We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

    You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
    Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data.

  • b. Third parties

    Internal Third Parties
    Other companies within The Growth Company Limited group acting as joint controllers or processors and who are based in the United Kingdom and provide corporate services including IT and system administration, HR, Marketing and Financial services and undertake management reporting. Information will also be shared within the group for marketing purposes where either you have consented for us to do so or where we are legally otherwise able to share this information. This is in order that we can provide a high-quality service across our group and can provide you with advice about our services that are relevant to your interests.

    External Third Parties
    We may transfer your personal information to our partners, suppliers, insurers and agencies, but only where they meet our standards of data and security. We only share information which allows us to provide their services to us or facilitate them providing our services to you. Examples include:
    • Funding, delivery partners and licensing bodies who require information in relation to the services that we provide. In the case of Made smarter this is specifically the GMCA and Steer Development Limited acting as evaluators on their behalf.
    o Steer Development Limited will be commissioning a telephone survey as part of this evaluation, your personal data can be shared by Steer with BMG Research Limited who will use personal data to contact representatives of SMEs engaged with the Made Smarter
    • Consultants and other advisors who deliver services as a subcontractor or on our behalf.
    o Edge Digital have been contracted to deliver and assist in the delivery of the Digital Strategy workshops. The only data shared with Edge Digital is specifically for the purposes of delivering these workshops.
    • Credit check and debt recovery agencies.
    • Service providers who provide professional services to us and those who provide IT and other system administration and/or management services.
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of, or access to, processing activities in certain circumstances.

    Your legal rights
    You have the right to:
    • Request access to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    (a) if you want us to establish the data’s accuracy;
    (b) where our use of the data is unlawful but you do not want us to erase it;
    (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your  personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.