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COACHING THROUGH COVID & BEYOND – PRIVACY POLICY

JANUARY 2022

As a provider of a professional service, your privacy and client confidentiality are very important to us. To ensure we comply with the data protection laws, we want to make you aware of how we will collect and use your information.

We are committed to ensuring the security and protection of the personal information that we hold and process, and to providing a compliant and consistent approach to data protection.

We refer in this document to the term ‘data processing’. Processing covers a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by sharing with third parties, dissemination or otherwise making available, restriction, erasure or destruction of personal data.

1. HOW WE USE YOUR INFORMATION AT COACHING THROUGH COVID & BEYOND

We will only collect and use information when the data protection law allows us to, where it is necessary to do so and relevant to providing our services to you, or where processing is necessary in order for us to comply with data protection law

Your contact details, and details of services we deliver to you, as provided directly by you or your trust/organisation, are kept in our records to provide our services to you, to schedule meetings and to correspond with you.

These are the ways we may use your personal data:-

  • Registering you as a new coach or client
  • Delivering services to you
  • Carrying out administration in connection with the delivery of services to you, including:
    – processing application forms
    – Sending matching information
    – Recording session dates
  • Sending relevant onboarding and update communication and information to you,
    collecting feedback data and comments from you
  • Managing queries relating to services we or any of our partners have delivered to you historically
  • Seeking your input or support in developing or promoting the activities of CtCaB
  • Managing our relationship with you, which will include notifying you about changes to our terms or privacy policy

Our partner coaches are members of professional bodies, including the Association for Coaching, the EMCC (European Mentoring and Coaching Council), the ICF (International Coach Federation) and APECS (Association of Professional and Executive Coaches and Supervisors), and we abide by the Global Code of Ethics, to which these bodies are signatories. As part of upholding professional qualifications, we are required to maintain client records. As part of this, your name, phone number, company and email address are held on file.

All our conversations with coaching clients (whether verbal or by e-mail) are totally confidential except as agreed between the client and the coach they are matched with.

We may also share anonymised/aggregated information with third parties where we believe it helps further the objectives of CtCaB.

We may send you information from time to time, to include learning events, thought leadership articles, updates, or any other materials related to your coaching programme

2. OUR PARTNER COACHES

We only share client contact details and initial brief with the partner coach delivering the coaching. Any further information or data collected by a coach, for example any session notes they may take, should be covered by agreement between the coach and the client

3.THIRD PARTIES & SERVICE PROVIDERS

We use third-party service providers to help us operate the service we provide, including, for example, processing application forms, holding and filing our own content or to provide administrative support. This may involve their holding your personal data in line with their standard terms of business

4.PRIVACY & SECURITY

We have in place appropriate security measures to prevent unauthorised or unlawful access to, or accidental loss of or destruction or damage to, your information. Our computer security obligations under law are fully covered, and our central backup is encrypted, covering our data for secure backup.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

5. DATA RETENTION

We will only retain your personal data 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.

We will keep a record of some of your contact data indefinitely, for the purposes of identifying you as a client.

6. YOUR DATA PROTECTION RIGHTS AS AN INDIVIDUAL

Complaint to the ICO
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance at info@coachingthroughcovid.org.

Your data protection rights
Your data protection rights are as follows:

  • The right to be informed: You have the right to be informed about our processing of your personal data.
  • The right of access to your personal data (a ‘data subject access request): This enables you to receive a copy of the personal data we hold about you and the information contained in this privacy policy. In most cases you will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, where your request is manifestly unfounded or excessive we may charge a reasonable fee for the administrative costs of complying with the request or refuse to comply with your request. We may also charge a reasonable fee if you request further copies of your data following a request.
  • The right to rectification: You have the right to have inaccurate or incomplete personal data rectified.
  • The right to erasure: You have the right to have personal data erased (this is also known as the ‘right to be forgotten’) in the following circumstances:
    – the personal data is no longer necessary for the purpose which we originally collected or processed it for
    – we are relying on consent as our lawful basis for holding the data, and you withdraw your consent
    – we are relying on legitimate interests as our basis for collecting and using your data, and there is no overriding legitimate interest to continue this collection and use
    – we are collecting and using your personal data for direct marketing purposes, and you object to that collection and use
    – we have processed your personal data unlawfully
    – we have to process your personal data to comply with a legal obligation.
  • The right to restrict processing: You have the right to request the restriction or suppression of your personal data. In other words, you can limit the way that we use your data. This is an alternative to requesting the erasure of your data. Your right to restriction may be because you have issues with the content of the information we hold, or how we have processed your data in the following circumstances:
    – you contest the accuracy of your personal data and we are verifying the accuracy of the data
    – the data has been unlawfully processed, you oppose erasure and you request restriction instead
    – we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim; or you have objected to our processing your data and we are considering whether our legitimate grounds override those of you as an individual.
  • The right to data portability: You have the right to receive personal data that you have provided to us in a structured, commonly-used and machine readable format. You also have the right to request that we transmit this data directly to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • The right to object: You can object to the processing of your personal data. This effectively allows you to ask us to stop processing your personal data. The right only applies in certain circumstances, depending on our purposes for processing and the lawful basis for processing. You have the absolute right to object to the processing of your personal data if it is for direct marketing purposes.

YOUR CONSENT

You can withdraw your consent to our processing your data at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.#

By applying to work with or receive coaching from Coaching Through COVID & Beyond, you consent to our keeping and processing your data as described in this Privacy Policy.

Please contact us: –
– If any of your personal information changes
– If you would like to request a copy of the information that we hold about you and/or notes we have kept of your coaching sessions
– If you have any questions, changes or requests regarding how we hold or use your personal information
– If you would like to withdraw your consent, request the erasure of any of your information or object to how your information is used.

Please email us at info@coachingthroughcovid.org clearly stating your request.