The Pay Index Privacy Policy

Privacy Policy

Last modified: 8th November 2023

Effective 8th November 2023. You can find the previous version of our Privacy Policy here.

Contents:

1. HOW INFORMATION IS PROVIDED TO US

2. INFORMATION WE COLLECT ABOUT YOU

3. INFORMATION WE RECEIVE FROM OTHER SOURCES

4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE

5. WHERE WE STORE YOUR PERSONAL INFORMATION

6. DISCLOSURE OF YOUR INFORMATION

7. HOW LONG WE RETAIN YOUR PERSONAL DATA

8. YOUR RIGHTS

9. COOKIES

10. THIRD PARTY WEBSITES

11. CHANGES TO THIS POLICY

12. CONTACT

Information About Us

The Pay Index is owned by SL Pay Index Limited registered in England and Wales, having its registered office address at 2 Heywood Avenue, Maidenhead, SL6 3JA, Berkshire, UK (“our”, “us” or “we” or “The Pay Index”).

What Does This Policy Cover?

Protecting your data, privacy and personal information is very important to The Pay Index. This Privacy Policy (“Policy“) relates to services provided through our website at https://thepayindex.com.

This Privacy Policy applies to the personal data of:

any web user accessing our website;

individuals registering an account with us and providing personal data through the use of our service; [and]

any representative of a business or institution using our services provided to business or institutional users]]

(our “Website” and “Subsidiary Website") or using any of the services offered via the Website, such as The Pay Index widget on a client or partner website

Definitions

“End User” means any individuals using our services to access compensation data, products and services.

“Controller” means a person or company that decide the purposes for which personal data is used and how it is processed.

“Client” means any business user accessing our data services.

“Partner” means a third party that hosts The Pay Index widget on their website.

“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).

“Client Microsite” is a self-contained collection of webpages built specifically for a client. These typically contain a login portal, and access to specific tools for the user to gain access to. They might also contain other learning documentation and videos.

“Student” (“Student”) means any user that is at school, college or already studying in university or higher education.

“Brand Ambassador” (“Ambassador”) means a person acting on behalf of The Pay Index as its representative and interacts with other University Students.

“Website” means a set of related web pages located under a single domain name namely www.thepayindex.com, our subsidiary website https://propella.uk and our subsidiary websites https://inspo.uk and https://inspo.online

For the purpose of the General Data Protection Regulation (the “GDPR”)

Website and Client Microsite/s Users

For all respective occasions above we ensure that we comply with existing Data Protection Laws.

Our Client Microsite/s and Website Users is only for those aged 13 or over (Year 9 plus)

Our Client Microsite/s and Website is only intended for use by persons aged at least 13 years of age. DO NOT USE THE PAY INDEX IF YOU ARE NOT AT LEAST 13 YEARS OF AGE.

How to contact us

If you wish to access an older version of our Privacy Policy, please click here or alternatively please contact us

dpo@thepayindex.com

This policy (together with our Terms and Conditions and any other documents referred to therein), sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by The Pay Index.

Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.

1. HOW INFORMATION IS PROVIDED TO US

You will be asked to provide us with your information when you:

fill in forms on our Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk and inspo.online, Client Microsite/s, or correspond with us by phone, email or otherwise;
register to use our Client Microsite/s (creating a The Pay Index account or Propella.uk account or inspo.uk or inspo.online account);
report a problem with our Client Microsite/s; or
complete any surveys we ask you to fill in (although you do not have to respond to these if you do not want to).

Where you enter any details relating to a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.

For the avoidance of any doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.

2. INFORMATION WE COLLECT ABOUT YOU

The Pay Index acting as a Data Controller or as a separate Data Controller with our Client

In respect of all End Users, with regard to each of your visits to our Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk, inspo.online or use of The Pay Index’s Client Microsite/s, we may automatically collect the following information:

device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
details of your visits to our Website or Subsidiary Website Propella.uk or Subsidiary Websites inspo.uk, inspo.online including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk, inspo.online or Client Microsite/s.

The Pay Index acting as a Data Controller

In respect of End Users of The Pay Index’s Client Microsite/s we collect the following types of information and The Pay Index acts as a Data Controller of such Personal Data which is captured as encrypted. Such Personal Data may include but is not limited to:

Contact information such as names, telephone number and email addresses;
Gender;
Location;
Level of Education;
University;
Course;
Graduation Year;
Company Name;
Company Headcount;
Company Annual Revenue;
Industry;
Sub-industry;
Function;
Sub-function;
Specialism;
Skills;
Geographical scope;
Structural level;
Scope of responsibility;
Job Title;
Working arrangement;
Office Location;
Start Date;
Tenure;
Currency;
Last annual base salary;
Last annual bonus;
Equity;
Current Day rate and Days of work
Course;
Primary Major;
Graduation Year;
University;
Year Group;
School/College Name;
First and Last Name;
Postcode;
Free School Meals;
Sexual Orientation;
Disability;
Age;
Date of Birth;
[any information which you provide in any free text field provided for completion on our Websites or in the course of the provision of any of our Services.]

We also create, collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 policy.

Certain types of particularly sensitive personal data known as “special categories of personal data” are given additional protection under data protection laws. We current process the following types of special categories of personal data:

Ethnicity

We invite End Users accessing our services to provide information about their ethnicity. The provision of this data is optional, and you will be able to access our services without providing this data. However, if you do choose to provide information about your ethnicity, this data will be used and stored in accordance with this policy.

3. INFORMATION WE RECEIVE FROM OTHER SOURCES

When using our Platform, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Platform:

Social networks connected to the services. If you provide your social network account credentials to us via the bio field or otherwise sign into the Platform, Website or Subsidiary Website Propella.uk or Subsidiary Websites inspo.uk or inspo.online through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
Partners. If you sign up to access The Pay Index through a third party partner website, The Pay Index and/or our partner may indicate that certain data will be shared with that third party.

4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE

Use of personal information under data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground we rely on in respect of each type of personal data which we use, as described in the privacy policy.

The following legal bases apply to our routine use of your personal data:

Contract performance: where the use of your information is necessary to enter into or perform a contract with you;
Legal obligation: where we need to use your information to comply with legal obligations;
Legitimate interests: where we use your information for one of more legitimate business purposes having appropriate regard to your rights and freedoms; and

4.A Purposes for the use of your Personal Data:

In respect of the use of the Platform, The Pay Index uses information held about you (and information about others that you have provided us with) in the following ways:

Types of Personal Data collected	Purpose for the use of Personal Data	Lawful Basis
School and College students (Year Groups 9 - FE Level 2)
Gender; Year Group; School/College Name; First and Last Name; Postcode; Age; Email Address; Password	To enable students to engage with The Pay Index platform	Contract performance Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
	To enable the Client to analyse School and College Student engagement data.	Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).
University Students
Email Address; Contact Number; Password; First Name; Gender; Location; Highest level of education; Course; Primary Major; Graduation Year; University; Password The Pay Index or Clients may request additional Personal Data to be processed for use of the Platform.	To enable students to engage with The Pay Index platform.	Contract performance, consent (to the extent you provide any sensitive personal data in any free text box, you are consenting to the processing of such sensitive personal data).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
	To enable the Client/s to analyse University Student engagement data.	Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).
Ethnicity	To collate statistical data	Monitoring equality of opportunity.
Professionals/Executives, Alumni & Business School Students
Gender; Location; First Name; Contact Number; Email address; Level of Education; University; Course; Graduation Year; Company Name; Company Headcount; Company Annual Revenue; Industry; Sub-industry; Function; Sub-function; Specialism; Skills; Geographical scope; Structural level; Scope of responsibility; What is your Actual Job Title?; What is your working arrangement?; Where is the office in which your role is based?; When did you start your current role?; How many total years of work experience do you have?; Currency; Last annual base salary; Last annual bonus; Equity; Current Day rate and Days of work The Pay Index may request additional Personal Data to be processed for use of the Platform.	To enable Professionals, University Alumni and Business School Students to engage with The Pay Index platform.	Contract performance, consent (you have the right to opt out at anytime by contacting The Pay Index). Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
	To enable the Client/s to analyse Professional, Alumni & Business School Student engagement data.	Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).
Ethnicity	To collate statistical data	Monitoring equality of opportunity.
Parents/Carers/Guardians
First Name; Last Name; Contact Number; Gender; Location; Email Address; Child's age The Pay Index may request additional Personal Data to be processed for use of the Platform.	To enable parents/carers/guardians to engage with the Platform	Contract performance, consent (you have the right to opt out at anytime by contacting The Pay Index). Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
Ethnicity	To collate statistical data	Monitoring equality of opportunity.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you with information, news, and offers on our services. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time by following the opt-out links on any marketing message sent to you. You have the right to withdraw consent to marketing at any time by contacting us.

We do not use your personal data in any automated decision making and/or automated profiling. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

5. WHERE WE STORE YOUR PERSONAL INFORMATION

Your Personal Data is maintained, processed and stored by us in the UK. Your Personal Data may be accessed from outside of the UK by our service providers and these countries may not offer an equivalent level of protection for personal data.

Your passwords are stored on The Pay Index’s servers in encrypted form. We do not disclose your account details to anyone except when legally required to do so. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although The Pay Index will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or Client Microsite/s, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorised access.

6. DISCLOSURE OF YOUR INFORMATION

We may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure and third party(s) to which disclosure might be made	Use Justification
The Pay Index may share certain Personal Data with Clients and Partners where necessary for the provision of our services. Such Personal Data may include: Personal Data submitted in the creation of a The Pay Index account (such as name, email, etc)	Contract performance, legitimate interest (to allow our service providers to provide the necessary services).
If The Pay Index or substantially all of its assets are acquired by a third party, personal information about our Clients will be one of the transferred assets.	Legitimate interest (to sell our Company or assets), Consent (for sensitive personal data).
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of The Pay Index, our Clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.	Legal obligation.
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.	Legal obligation (to cooperate with law enforcement and regulatory authorities).

7. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will hold the above information for as long as is necessary for the purposes relevant to the use of such information, as set out in this privacy policy. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 14 days.

Some Personal Data may need to be retained for longer than this to ensure The Pay Index can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing. If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.

8. YOUR RIGHTS

General Data Protection Regulation (GDPR and GDPR UK)

Under the General Data Protection Regulation (EU) 2017/676 and General Data Protection Regulation (UK) and Data Protection Act 2018, you have various rights in relation to your Personal Data.

School Students, College Students, University Students, Business School Students, Alumni, Professionals/Executives and Parents should contact The Pay Index in the first instance as their Controller at dpo@thepayindex.com

The Data Controller, is primarily responsible for ensuring you can exercise these rights.

You have the following rights in relation to your Personal Data.

Rights	Details
Right to access	You have the right to access Personal Data held by the Controller(s), including a description of your data. Personal Data processed can be found in the profile section of your The Pay Index account.
Right to rectification	You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify us of any changes to the personal information that you have provided by sending a request to rectify your personal data where you believe the personal data collected is inaccurate or incomplete.
Right to erasure/ ‘Right to be forgotten’	Asking the Controller(s) to delete all of your Personal Data will result in the deletion of your personal data held by that Controller without undue delay (unless there is a legitimate and legal reason why the Controller is unable to delete certain Personal Data, in which case you will be informed of this in writing).
Right to restriction of processing	You have the right to ask the Controller to stop processing your Personal Data at any time in certain circumstances. Such a request will result in the Controller restricting its processing of such data.
Right to data portability	You have the right to request that the Controller provides you with a copy of all of your Personal Data and to transmit your Personal Data to another Data Controller in a structured, commonly used and machine-readable format, where it is technically feasible to do so where such processing is based on consent or pursuant to contractual performance.
Right to object	You have the right to object to processing of personal information in certain circumstances, including where personal information is used for marketing purposes – you have a right to object to processing being carried out by us if (a) we are processing personal information based on legitimate interests or for the performance of a task in the public interest (including profiling), (b) if we are using personal information for direct marketing purposes, or (c) if information is being processed for scientific or historical research or statistical purposes.
Right to complain	You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our End Users and Clients to engage with us in the event they have any concerns or complaints.

The Pay Index will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the Personal Data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

Requests to stop processing your Personal Data or deleting your Personal Data will likely mean that you are no longer able to use The Pay Index’s Client Microsite/s.

Where you exercise any of your rights above, the Controller may notify third parties to whom such Personal Data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right.

To exercise the rights described above, you must send us a Subject Access Request/Valid Request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 30 day period of receipt for all Valid requests under GDPR. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

By sending an email to dpo@thepayindex.com

By post: The Pay Index, Equitable House, 47 King William Street, London, EC4R 9AF, United Kingdom, marked for the attention of the [Founder/CEO].

9. COOKIES

The Pay Index and our third-party partners, such as our analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookie Policy, which includes information on how to control or opt out of these cookies and tracking technologies.

10. THIRD PARTY WEBSITES

Our Website may, from time to time, contain links to third party websites. If you follow a link to any of those third party websites, plug-ins or applications please note that they have their own Privacy Policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

11. CHANGES TO THIS POLICY

Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review the Website from time to time to stay informed of how we are processing your information. Your continued use of the Client Microsite/s and the Website shall be deemed your acceptance of the varied Privacy Policy.

12. CONTACT

If you have any questions and comments about this Privacy Policy or want to report a potential data breach please address these to dpo@thepayindex.com

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. However, we welcome the opportunity to resolve your concerns ourselves, so please contact us first.