As part of Two Circles’ commitment to its data protection obligations, this privacy notice covers the processing of personal data in Microsoft Teams meetings and any subsequent transcriptions organised by Two Circles.
What personal data is being collected
When attending a Two Circles meeting via Microsoft Teams, we will be collecting your name, email address, Microsoft Entra affiliated organisation, video and audio recording where your camera is enabled, user-generated personal data through the discussion and any instant messaging using Microsoft Teams.
Why do we use your data and what is our legal basis for it?
Two Circles will use personal data as part of facilitating efficient business administration and for the training and development for our employees. The lawful basis for processing your personal data will be under Article 6(1)(f) of the UK GDPR, as the processing of personal data is necessary for Two Circle’s legitimate interests.
Who has access to this data?
In the first instance, only participants on the call will have access to Teams recordings, transcripts and summaries. These can be shared with others within the business and externally, but will only be done where appropriate and necessary and lawful to do so.
Who do we share your information with?
We will share your data with the following organisations upon a reasonable and lawful request, strictly on a case-by-case basis:
- Microsoft Ireland Limited;
- Our group companies;
- Our clients and partners; and
- Others where required to do so by law.
Transferring your data to other countries
Where we transfer your data outside of the UK, we will use what is known as a “Transfer Mechanism” under UK GDPR to ensure that your data is handled with substantially similar protections. Where your country has specific rules around transfers to other countries, we will ensure that the data is only transferred where it will continue to have the necessary measures to ensure the security of the data.
How long do we keep your data for
We will retain the meeting recordings and transcripts for a maximum of 30 days.
More information
If you want to see more information about your rights, please see our main privacy notice. If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting our DPO at Two Circles at the following address: dpo@twocircles.com.
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