PRIVACY POLICY
Updated on 14 November 2022
Contact Details
Benjamin Newton is the person responsible for Data Protection. He provides coaching services under the trading names “Coaching Academics” and “The Gloucester Coach”.
The Gloucester Coach, Unit 88262, PO Box 92, Cardiff, CF11 1NB
Coaching Academics and The Gloucester Coach are registered with the Information Commissioner’s Office (ICO) registration number ZB270776.
Information we use
Your Information and Website Use
This website uses cookies and plugins to enable it to function. The legal basis for this is consent. If you do not consent, please discontinue use of the website. If you choose to contact Coaching Academics through the website’s contact form, you are consenting to share your personal data (and if you choose, your sensitive personal data) with Coaching Academics.
Your Information & Coaching Services
Coaching Academics collects, stores and processes personal information for the purpose of providing coaching services. This information is provided by individuals who have expressed an interest in coaching. Some of these individuals will go on to enter into a contractual relationship with Coaching Academics [described in this agreement as clients].
The legal basis for processing data to provide coaching services is contractual and covers individuals who have expressed an interest in coaching services and those who have signed a coaching agreement and become clients. We use the following types of personal information to provide coaching services:
• Name
• Email address
• Phone numbers
• Postal address
• Payment information
Your Sensitive Information & Coaching Services
During the course of coaching, clients may disclose information to the coach that is considered sensitive. This includes (but is not limited to) information relating to a client’s:
• Race
• Political views
• Health
• Sex life
• Sexual orientation
• Religion.
This information is not routinely sought and processed by Coaching Academics but may arise from the nature of coaching whereby information may be disclosed by the client. In order to provide a coaching service, there will be times when this information will be processed and stored by the Coach as part of record keeping.
There will also be times when, with explicit additional consent, audio and/or video recordings will be made of coaching sessions that capture personal and sensitive information.
In order to receive coaching services, individuals will need to explicitly consent to the processing of sensitive information. The legal basis for this processing will be contractual and will be based on the processing condition of explicit consent.
Your Information & Marketing
Coaching Academics collects, stores and processes personal information for the purpose of marketing services. The legal basis for marketing coaching services is consent and covers individuals, including clients, who have expressly opted in to receiving marketing information.
We use the following types of personal information that individuals have provided to Coaching Academics in order to market coaching services:
• Name
• Email address
• Phone numbers
• Postal address
We will never sell your information to third parties.
Data Sharing
To provide coaching services including marketing, we use third party service providers such as email services, secure data storage, payment processing and e-signing companies. We share personal and sensitive data with them securely for the purpose of providing clients with a service or to market services.
There may be rare instances where individuals disclose information where a serious criminal offence has been committed and this represents a threat to life. There may also be instances where individuals disclose information highlighting a risk to their own or other’s wellbeing. In these rare instances, information may be shared with appropriate authorities using the lawful basis of vital interests.
In the rare instances where there is a prospect of litigation, we may share personal information with third parties such as insurers and solicitors. We would rely on legitimate interests as the lawful basis for this.
The service providers we use may be located outside of the UK and European Economic Area (EEA). Where we transfer your personal and sensitive data outside of the UK and EEA, we have ensured that these service providers meet current regulatory requirements so that your personal data is secured.
Data Retention
Personal and sensitive data provided by clients to Coaching Academics for the provision of coaching services will be securely stored electronically for seven years from the last coaching session provided. Personal and sensitive data captured in audio/video recordings will be covered by individual consent forms which will specify with mutual agreement, how long data will be retained for.
When individuals have provided their data but not signed a coaching agreement, their personal data will be securely stored electronically and will be erased after 30 days from the last contact they have had with Coaching Academics. Anonymised, non-personal data in the form of brief notes about the meeting will be kept for seven years.
Data provided for marketing purposes will be securely stored electronically until you withdraw your consent.
Data Rights
Individuals have a number of rights regarding how their data is used. This includes the right to be informed about their data being used, the right to access and receive a copy of their data, the right to have inaccurate data rectified, the right to have their data erased, the right to restrict processing of their data, the right to data portability and rights around automatic decision making based on personal data. Coaching Academics does not use your data to make automated decisions.
You may exercise your data rights pertaining to data held by Coaching Academics, by contacting info@coachingacademics.co.uk and stating your request. We will respond within a one month time frame and there is no charge for submitting your request.
If you wish to complain to the Information Commissioner’s Office, you may do so by accessing their website https://ico.org.uk/make-a-complaint/ or phoning 0303 123 1113. Their address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.