Whose data do we hold?
We may hold data about the following people:
- Customers and clients
- Suppliers and service providers
- Advisers, consultants and other professional experts
- Complainants and enquirers
What data will we collect?
We will only collect information from you that is relevant to the matter we are dealing with. In particular we may collect the following information from you which is defined as ‘personal data’:
- Personal details
- Family, lifestyle and social circumstances
- Financial details
- Business activities of the person whose details we are processing
- Services provided
- Education details
- Employment details
We may also collect information that is referred to as being in a ‘special category’. This could include
- Physical or mental health details.
- Racial or ethnic origin.
- Religious beliefs or other beliefs of a similar nature.
- Criminal convictions – offences and alleged offences.
Basis for processing
The basis on which we process your personal data is one or more of the following:
- It is necessary for the performance of our contract with you.
- It is necessary for us to comply with a legal obligation.
- It is in our legitimate interests to do so.
- You have given us your consent (this can be withdrawn at any time by advising our data protection officer).
How will we use your data?
We may use your information for the following purposes:
- Provision of coaching, consulting, advisory services and training including advising clients.
- Promotion of our services.
- Provision of education and training to customers and clients.
- Maintaining accounts and records.
- Supporting and managing staff.
Who will we share your information with
Using our Code of Conduct there are very strict rules about who we can share your information with and this will normally be limited to other people who assist with your matter. This may include:
- Business Associates and Professional Advisors.
- Family associates and representatives of the person whose data we are processing.
- Financial organisations.
- Healthcare professionals, social and welfare organisations.
- Current, past or prospective employers.
- Educators and examining bodies.
- Regulatory bodies.
Where you authorise us, we may also disclose your information to your family, associates or representatives.
How long will you keep information for?
We will normally keep your information throughout the period of time that we work with you and afterwards for a period of six years as we are required to do so by law and also by the regulations that apply to us.
Transfer to third party countries
- We may from time to time transfer your date to a country outside of the EEA.
- Normally this will be necessary for the performance of your contract with us.
- Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times.
- We shall ensure that all of the information that you provide to us is kept secure using the appropriate technical and organisational measures.
- In the event of a personal data breach, we have in place procedures to ensure that effects of such a breach are minimised and shall liaise with the ICO and with you as appropriate.
- More information is available from our data protection officer.
You have the following rights under GDPR:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
Right of access
- You have a right to see the information we hold about you.
- To access this you ned to provide a request in writing to our data protection officer, together with proof of identity.
- We will usually process your request free of charge and within 30 days, however we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and/or is very complex.
Right to erasure
- You have a right to ask us to erase your personal data in certain cases (details may be found in Article 17 of the GDPR).
- We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend legal claims.
Who can you complain to?
- If you are unhappy about how we are using your information or how we have responded to your request then initially you should contact our Data Protection Officer, Alison Delaney at firstname.lastname@example.org
- If your complaint remains unsolved then you can contact the Information Commissioners Office at ico.org.uk
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