We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.
2. Whose personal data do we collect?
By personal data we mean identifiable information about you, such as your name, email address, gender, age, mobile and home telephone number and your IP address.
In the provision of coaching services, we may also collect (for example, in our coaching notes) special categories of personal data about you, if you provide it to us as a part of. your coaching. Special personal data includes information relating to your race or ethnic origin, political opinions, religious beliefs of other beliefs of a similar nature, physical or mental health or condition, sex life and sexual orientation. We both understand that this data is useful so that we can provide coaching services to you, but equally, you are not obliged to provide any such information if you do not wish to do so.
From time to time you may provide personal data to us. This may be because you wish to:
- use our website;
- receive coaching sessions;
- apply to work with us as a coach; and
- otherwise contact us including with queries, comments or complaints.
You may provide personal data to us directly, or to us through our social media platforms.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identity fraud, we will record this and we may also report this to the appropriate authorities.
At our request, you shall promptly provide evidence of your identity.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, confirming or otherwise, your identity.
3. Lawful use of your personal data
- consent (where you choose to provide it);
- performance of our contract with you, such as the terms on which we provide coaching services;
- compliance with legal requirements; and
- legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.
We may also use your personal data for our legitimate interests including:
- to improve our services;
- in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- to deal with any questions or comments you raise;
- for audit purposes; and
4. Who do we share your data with?
For our legitimate interests, we may share your personal data with our sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including your coach, accountants, auditors and lawyers.
We shall provide our sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
5. Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the United Kingdom or European Economic Area (the EEA) if for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our sub-contractors are based outside of the United Kingdom or the EEA.
Where your personal data is transferred outside the United Kingdom or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.
However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.
You may consent to receive marketing email messages from us about our services. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. We will still contact you as necessary about any coaching services we have agreed to provide to you.
8. Your rights
You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below.
- Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
- Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
- Right to portability: You can request that we transfer your personal data to another organisation.
- Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal data.
- Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.
- Right to stop receiving marketing information: You can ask us to stop sending you information about our services.
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.
9. Retention of personal data
In particular, we shall retain your personal data for as long as we provide coaching services to you. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.
Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Last updated: April 2020