Privacy statement
As a professional coach and mediator our professional relationship will always be built on transparency, trust and confidence in each other. Confidentiality will always be paramount.
I have written this statement to inform you that I am committed to protecting the privacy and security of your personal information. This privacy notice describes how I collect and use personal information about you during and after your relationship with me, in accordance with the General Data Protection Regulation (GDPR).
This notice applies to:
Any reference to ‘we’, ‘us’, ‘our’, ‘the company’ shall mean me Sarah Ward-Lilley.
Any reference to ‘you’ or ‘Data Subject’ shall mean any individual receiving this notice for whom I hold personal data. This Privacy Notice also applies to my website; htttp://www.ward-lilley.com
In most circumstances your data will be held by me as a “Data Controller”. This means that I am responsible for deciding how I hold and use personal information about you. I am required under data protection legislation to notify you about the holding of information in this privacy notice.
I may update this notice at any time.
Principles
I will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:
The information I hold
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). There are “special categories” of more sensitive personal data which require a higher level of protection.
I will collect, store, and use the following categories of personal information about my clients.
I may collect, store, and use the following categories of personal information about clients following some coaching interventions.
I will collect, store, and use the following categories of personal information about business clients.
I may also collect, store and use the following “special categories” of more sensitive personal information in respect of client information arising from some coaching interventions.
Why I hold this information
It is necessary for me to retain data on clients in order for me to fulfil my contractual obligations and hold data for legitimate business needs. I will only retain data which we reasonably require and for a period which is reasonably necessary. I will not disclose your data to the third parties unless you have consented for me to do so or I am otherwise required to do either contractually or under another law or enactment.
How I collect information
I collect personal information about clients directly from themselves when they contact me via telephone, email, social media or my through my website. Client and business data is stored within a GDPR compliant email account with data saved on a computer located in my office that is password encrypted. Data on current clients that I am actively working with is also stored in my mobile telephone that is also password encrypted. If our coaching is carried out via Skype or a similar communication application, contact data will be stored within the application for the duration that we are actively in a coaching relationship. I reserve the right to change the systems in which data is stored without notification to another equivalent system but at all times I will ensure the appropriate security of your data and GDPR compliance.
How I use information
I will only use your personal information when the law allows me to. Most commonly, I will use your personal information in the following circumstances:
I may also use your personal information in the following situations, which are likely to be rare:
Situations in which I use your personal information
I need all the categories of information in the list above primarily to allow me to perform my contract with you and to enable me to comply with legal obligations. In some cases I may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which I will process your personal information are listed below.
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, I hold your data to market other services to you, send you blogs, or send you information that I think may interest you. I have a legitimate business interest in retaining your data for this purpose, but you may ‘opt out’ of receiving these types of communication from me.
If you fail to provide personal information
If you fail to provide certain information when requested, I may not be able to perform the contract I have entered with you or I may be prevented from complying with our legal obligations.
Change of purpose
I will only use your personal information for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If I need to use your personal information for an unrelated purpose, I will notify you and I will explain the legal basis which allows us to do so. Please note that I may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Why might I share your personal information with third parties?
I will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where I have another legitimate interest in doing so.
Data security
I have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Details of these measures may be obtained directly from me. I have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where I am are legally required to do so. The transmission of information via the internet is not completely secure. I cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with me 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.
How long will I use your information for?
I will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements. In some circumstances I may anonymise your personal information so that it can no longer be associated with you, in which case I may use such information without further notice to you. In respect of client data, you can expect me to hold data relating to your instructions for a period of seven 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. I therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue. Given the nature of my services clients often return to me with repeat instructions within weeks, months or years of contacting me in the first instance. The seven-year period referred to above will start from the last contact I had with the client, third party or supplier, to ensure I am able to assist as and when I need to. Should you not contact me for seven years, I will confidentially destroy all data held for you.
Your duty to inform me of changes
It is important that the personal information I hold about you is accurate and current. Please keep me informed if your personal information changes during your working relationship with me.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that I transfer a copy of your personal information to another party, please contact me. Please note that where you ask me to erase, correct, object to process or seek to restrict my processing of data I may refuse your request where I have a legal obligation, contractual or other legitimate business interest to refuse your request. If I refuse your request then I will notify you of this refusal and you will have the right to appeal.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, I may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, I may refuse to comply with the request in such circumstances.
What I may need from you
I may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Data privacy manager
I have appointed myself as a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how I handle your personal information, please contact me. 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.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Cookies
My website uses cookies as part of the user website experience. www.ward-lilley.com is transparent and free of any data tracking. Unfortunately, I cannot guarantee that your user experience will be totally free from data tracking or data analytics if you found the website via a third-party website or search engine. Other cookies may be stored to your computer’s hard drive by external vendors if the website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Changes to this notice
I reserve the right to update this privacy notice at any time, and I will provide a new privacy notice when I make any substantial updates. I may also notify you in other ways from time to time about the processing of your personal information.
Contact and further information
If you have any questions about this privacy notice or wish to submit a complaint, then please email sarah@ward-lilley.com You have the right to make a complaint to the Information Commissioners Office or such other regulatory body or supervisory authority as may be appointed from time to time. If you make a complaint then I will respond to let you know how your complaint will be handled.