Conscious Coaching Ltd (T/A The Conscious Company)
As a professional coaching company our client and coaching relationship will always be built on transparency, trust and confidence in each other. Confidentiality will always be paramount.
We are committed to protecting your privacy. We will only use the information that we collect about you lawfully (in accordance with the relevant Data Protection Acts).
DATA PROTECTION PRINCIPLES
We will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only if necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT CLIENTS
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 information about you for 2 reasons:
- to process payments
- to provide you with the best possible coaching service
We will collect, store, and use the following categories of personal and business information about our clients.
- Company contact details such as name, title, addresses, telephone numbers, and company email addresses
- A coaching contact for the company with which we are engaged
- Birthday (if offered)
- Marital status and dependants (in the coaching notes)
- Information about your health, medical conditions, or disabilities (in the coaching notes)
WHY WE HOLD INFORMATION ON CLIENTS
It is necessary for us to retain data on clients in order for us to fulfil our contractual obligations and hold data for legitimate business needs.
We will only retain data which we reasonably require and for a period which is reasonably necessary.
We will not disclose your data to third parties unless you have consented for us to do so, we need to fulfil a business requirement (in the case of using online tools ie Belbin, Survey Monkey), we are otherwise required to do either contractually or under another law or enactment.
The information we hold will be accurate and up to date. You can check the information that we hold about you by emailing us. If you find any inaccuracies we will delete or correct it promptly.
The personal information which we hold will be held securely in accordance with our internal security policy and the law.
HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you
- Where we need to comply with a legal obligation
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. The situations in which we will process your personal information are listed below.
- Administering the contract we have entered into with you
- Dealing with legal disputes involving you
- To prevent fraud
- To market other products or services which we offer which may be of interest to you
- To inform you about updates about our services
- To administer our business which may include disclosure of client data to our accountant
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
In certain circumstances listed above, we hold your data to market other services to you, send you information that we think may interest you or connect with you again after the conclusion of our contract. We have a legitimate business interest in retaining your data for this purpose, but you may ‘opt out’ of receiving these types of communication from us.
DISCLOSURE OF YOUR PERSONAL DATA
We will never share your personal details with any third party without your consent. Below are the instances that some data may be disclosed (in accordance with the relevant Data Protection Acts):
- Our computer maintenance company, who provide supervised IT and system administration support
- professional advisors including lawyers, bankers and auditors
- service providers who provide online tools for our business ie Survey Monkey, Belbin.
We require all of these third parties who could have access to your data to respect the security of your personal data and to treat it in accordance with the law. They are all bound by Data Protection Agreements and their own Privacy Policies. They are only allowed access to your data on our instructions and with supervision.
We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. The transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with us by email then you assume the risks of such communications being intercepted, not received or delivered, or received by individuals other than the intended recipient.
We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so. In certain circumstances you can ask us to delete your data.
We may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We will only retain your personal information 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
In respect of client data, you can expect us to hold data for a minimum period of seven years, and not more than fifteen years, after completion of the last coaching interaction. The reason for this is that the Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to six years after the events. We therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.
Given the nature of our services clients often return to us with repeat business within weeks, months or years of contacting us in the first instance. The seven-year minimum period referred to above will start from the last contact we had with the client, third party or supplier, to ensure we are able to assist as and when we need to. Should you not contact us for fifteen years, we will confidentially destroy all data held for you.
You have the right to ask us to delete the personal data we hold about you in certain circumstances.
You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail on the ICOs’ website (click here).
In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive, or excessive in which case we may charge a reasonable fee or decline to respond.
We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months.
KEEPING YOUR DATA UP TO DATE
We have a duty to keep your personal data up to date and accurate as long as you are a client of ours, so from time to time we may contact you to ask you to confirm that your personal data is still accurate and up to date.
COOKIES POLICY ON OUR WEBSITE
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
The Conscious Company
2 Wyevale Business Park