COACHING CONVERSATION LTD trading as LEADERKIND
Purpose of Privacy Notice
The processing of personal data is governed by the General Data Protection Regulation (GDPR) as retained in UK Law post-Brexit and the UK Data Protection Act 2018. From 25th May 2018 this new legislation gave more rights to individuals, and more obligations to organisations holding their personal data. One of the rights is a right to be informed about how personal information is shared and stored.
Who am I?
I am Agnieszka Walczuk, Director, Head Coach & Facilitator at Coaching Conversations Ltd trading as LeaderKind. This means I decide how your personal data is processed* and for what purposes. The lawful basis under which I process your data is GDPR Article 6 ‘Consent’. I am registered with and accountable to the Information Commissioner’s Office (ICO).
*’Processing’ means any use of data such as obtaining, recording, holding, organising, amending, retrieving, using, disclosing, erasing or destroying that data.
Whose information does this privacy notice apply to?
This privacy notice applies to information I collect from:
- Prospective clients
- Current clients
- Former clients
- Visitors to my website
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in my possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your client notes.
How do I process your personal data?
I comply with my obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.
I use your name, address, telephone number and email address to make and rearrange appointments, and communicate with you about other relevant professional matters.
I hold data about you on my mobile phone that will include your first name and telephone number so that I can recognise who is contacting me, and so that I can contact you by phone if I need to.
If at any time I have more than one contact sharing a first name I will use your initials instead. My mobile phone is twice protected, by password, and finger recognition.
Email/Online Enquiry Forms
Some prospective clients and clients return pre-appointment questionnaires or tell me about their psychological, mental, conditions by email or online enquiry forms. I do not use encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send to me is within the bounds of the law.
My electronic records are securely stored in a password-protected file on a password-protected computer with an encrypted hard drive. My records are also stored securely on paper in a locked filing cabinet.
I may use your date of birth to help identify clients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a client to another practitioner so that they correctly identify the client.
I keep a record of our sessions including reviews of previous sessions to enable me to: review the progress, plan future work and sessions; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
In the event of an adverse incident occurring to any of my clients I report the matter to my registering body, International Coach Federation (ICF), and my insurance company to enable the insurance company to deal with any potential claims and to help the ICF to develop its safe practice guidelines.
I keep an electronic diary to record all appointments of clients attending my sessions, workshops and events, for tax purposes, and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the ICF.
Contact via the Internet
I primarily use Zoom for my online sessions, which is GDPR compliant. From time to time I may use Apple FaceTime (iPhone & Laptop only in my private office.)
All these methods of online communication are encrypted and are never recorded by me, unless previously agreed for coach supervision purposes.
For more information about these products please see their websites listed below:
FaceTime – https://www.apple.com/uk/privacy/approach-to-privacy/
Zoom – https://support.zoom.us/hc/en-us/articles/360000126326-Official-Statement-EU-GDPRCompliance
My broadband service is password protected. My laptop is encrypted, password protected and locked with a fingerprint scan. My iPhone is locked with a passcode and fingerprint scan.
I use a third party service called SiteGround to host my website. SiteGround use Google Analytics to collect anonymous information about users’ activity on my website to monitor and report on the effectiveness of the site and help improve it. SiteGround help maintain the security and performance of my website. To deliver this service it processes the IP addresses of visitors to my website.
My website uses Secure Sockets Layer (SSL) certificates to verify my identity to your browser and to encrypt any data you give me. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
For more information about how SiteGround processes data, please see: https://www.siteground.com/blog/siteground-is-gdpr-compliant/
Subscribers to my Newsletters and Marketing
Only with your explicit consent, I use your name, address, telephone number and email address to send you newsletters and marketing materials. I do not sell or market your details to any other individual or organisation. I use a third party provider to deliver my e-newsletters. I gather statistics around email opening and clicks using industry standard technologies to help me monitor and improve my e-newsletter.
If I receive a complaint from a person I make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. I will only use the personal information I collect to process the complaint and to check on the level of service I provide. I may need to provide personal information collected and processed in relation to complaints to the ICF and my insurance company.
I will keep personal information contained in complaint files in line with my retention policy. This means that information relating to a complaint will be retained for three years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared:
- with named third parties with your explicit consent; or
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I am subject e.g. a court order; or the police if necessary to protect yours or another person’s life; or
- with the police or a local authority for the purpose of safeguarding children or vulnerable adults; or
- with my regulatory body, the ICF, or my insurance company in the event of a complaint or insurance claim being brought against me; or my solicitor in the event of any investigation or legal proceedings being brought against me.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk.
How long do I keep your personal data?
I keep your personal data for no longer than reasonably necessary; currently client data is retained for a period of 6 years from close of client engagement. Client data is kept in case of any legal claims/complaints, or for safeguarding purposes. Your data is updated electronically during and after you work with me. At the end of six years your data is permanently deleted.
In the event of an emergency
I have written a Professional Will. In the event of any unforeseen emergency an appointed trusted executor will communicate with you where I am unable to do so, and in the event of long term incapacity or the event of my death an appointed trusted executor will respectfully and confidentially process any client data I hold and close my practice.
Your rights and your personal data
At any time you may request that changes are made to your contact details.
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
- the right to request a copy of your personal data that I hold about you and to receive this within one calendar month
- the right to request that I correct any personal data if it is found to be inaccurate or out of date
- the right to request your personal data is erased where it is no longer necessary for me to retain such data
- the right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
- the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- the right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
- the right to be informed if your data is lost. I shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
- the right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.
My contact details
To exercise all relevant rights, queries or complaints please in the first instance contact me at email@example.com 07988083689.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
END OF PRIVACY NOTICE