Privacy Statement and Consent
This Privacy Statement explains the purpose of processing your personal data when you sign up to, and subsequently take part in, coaching sessions with Practice Room Online (PRO), a third-party supplier Rio Tinto has onboarded to assist with workplace conversations.
It also explains how your personal data will be processed and shared, and your rights.
At the outset, please understand that taking part in these coaching sessions is not compulsory, it is completely voluntary. It is an opportunity being provided by Rio Tinto, if you wish to do it, and if you feel it will help you in your role. There will be no consequences if you do not take part, and no negative inferences drawn. Rio Tinto will not be monitoring who does the coaching sessions, and who doesn’t.
You are being given the option to undertake coaching sessions with PRO, as it provides interesting insights into your approach to difficult conversations you may have to have. It is a good opportunity for individuals to practice such conversations, receive feedback, and improve in a safe environment.
Rio Tinto remains the Controller of your personal data for the purposes of applicable data privacy laws. Practice Room Online are Rio Tinto’s Data Processor (or ‘entrusted party’, if you are in China).
1. Processing of your personal data
If you choose to complete a coaching session or sessions, you will need to provide your personal data including your first name, last name, business email address, role, division, country, timezone, preferred language and session availability, to PRO.
As part of completing the coaching session, you will be asked to prepare one of the available scenarios to role play in the session, and will receive feedback in real time on the call. In addition, at the start and end of the session you will be asked to answer questions and rank certain responses around your confidence regarding handling the scenario – this is so that PRO can track performance metrics and assess how much the sessions are benefitting the Rio Tinto employees. These scores will be aggregated and shared in reports to the Rio Tinto Talent team. Those reports will also contain aggregated statistics of the number of sessions booked by Rio employees, as well as how many were booked, completed, rescheduled, ‘no shows’ and the remaining number of sessions Rio has available for people to book. Such reports will not identify individuals and are intended to map trends and the general effectiveness of the program only.
Personal data processing in the context of the PRO coaching program is carried out on the basis of your consent, which will be documented if you decide to use the details provided and sign up to undertake a session with PRO. Your personal data will be stored by PRO as set out in their Privacy Policy – please ensure you read and understand this policy before you sign up.
Please note that sessions should not be recorded, nor should you share personal information about yourself with the coaches that is not necessary for the session. You also must not share personal information about others during the session, including other individuals within the Rio Tinto business. While you may be preparing for a real-life scenario, it is important that your coach does not learn of any confidential or sensitive business or personal information from you – your sessions, scenarios and discussions must be undertaken with the utmost respect for the privacy of others in the business.
2. Who has access to your personal data?
Other than your own access to the PRO platform, and those who administer the booking process at PRO, the intention is not to process your personal data. PRO coaches will also process the minimum amount of personal data necessary to be able to conduct the session, for example, addressing you by name and having a general awareness of your job role to be able to provide helpful feedback and guidance.
3. Sharing your personal data
PRO have third party suppliers that they use (for example Microsoft), and the PRO coaches themselves (who are self-employed) in the course of business, and such third parties may have limited access to your personal data in order to carry out their service provision, but only if necessary. PRO have implemented contractual protections, to protect your personal data when processed by such third parties.
4. Information about our service providers and international data transfers
Please note that PRO is based in the UK, and hosts data on a UK server. They may also need to transfer your personal data to certain countries, most commonly EU countries, Singapore and/or Australia in line with the activities of the third-party suppliers referenced above – mainly, for the coaches to provide the coaching. While the EU offers an equivalent level of protection of personal data to the UK, you should note that Singapore and Australia may not offer as high a standard as the country where you reside. You are consenting to such international data transfers by consenting to the processing of your personal data if you sign up to undertake PRO sessions.
5. Your privacy rights
You are entitled to:
- seek access to all personal data being processed about you and you have the right to ask to correct any inaccuracies in that information.
- complain about how your personal data is processed.
- information about how personal data is processed and to object to its processing in some circumstances, or restrict the processing.
- request the deletion of your personal data.
- request your personal data and use it for your own purposes, or have it transferred to another organization (the right of data portability).
Please contact PRO, and address your request to the Information Security Manager, at bookings@practiceroomonline.com if you wish to make requests in relation to the personal data processed as part of this program, or to delete your personal data. You can also email askE&C@riotinto.com should you wish to exercise your rights, or if you wish to raise a complaint in relation to the way your personal data is processed.
Please contact your local HR team or your regional Data Privacy Lead if you have any questions about the content of this Privacy Statement.
Consent
If you choose to use the information provided by Rio Tinto to set up a session with PRO, and to provide your personal information to PRO, and if you subsequently choose to voluntarily complete a session or sessions with PRO, you are consenting to having your personal data processed in line with this privacy statement.
You also acknowledge and agree that, as described in this privacy statement, your personal data may be subject to international transfers to other countries, which may not offer as high a level of personal data protection as the country in which you reside.
