Transitions Life Coaching
And as the following website and social media identities:
Facebook: Jackie Fletcher, Transitions Life Coaching and Acts of Kindness
Twitter: MyCoachJackie and MentorCoachJAF
I am a sole trader and the owner of Transitions Life Coaching, a business which trades from 38 Avon Castle Drive, Ringwood, Hants, BH24 2BB. For the purposes of GDPR, I am the data controller – which means that I am the person who determines what personal data is collected, retained and how it is used.
Contact details: address as above and Jackie@transitionslifecoaching.co.uk
Who are you?
When I use the term ‘clients’ in this document, I am referring to people currently working with me and to those who have worked with me in the past. This document also covers people who may visit my website.
Maintaining the security of your personal data is important to me and I am committed to respecting your rights to privacy. Rest assured that I never use any of your data for commercial purposes.
This document sets out my policy and refers to the data I collect and hold about you when you work with me, have worked with me in the past, or visit my website.
Overall, this policy will explain:
- What personal data I collect and hold – and why
- How I use that data
- The steps taken to ensure that your privacy is maintained
- Your legal rights as regards your personal data
What is GDPR?
The General Data Protection Regulation (GDPR) has created significant changes to data protection law and places new obligations on businesses that process EU personal data. These new guidelines, which took effect on 25th May 2018, govern how your personal information is held and processed, and are intended to provide additional protection to ensure the privacy and security of your personal data.
What this means for you is as follows:
- There is clarity about what personal data is collected and how (and why) it is used
- You have clear rights about the ways in which your personal information is handled and when it should be deleted
- You have more choice and control over your personal data and how you are contacted
- You can find out what is being done to keep your data safe
- There is an end to unauthorised sharing
There are two sections to the following information:
- About your personal data – the type of data that is collected or used, including when, how and why
- Your rights – all the ways that you can control what happens with your data
ABOUT YOUR PERSONAL DATA:
Personal data means any information capable of identifying an individual. It does not include anonymised data. Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender. Contact Data may include your billing address, delivery address, email address and telephone numbers.
When you make an enquiry for coaching services
The name and contact details you give and the content of your message(s) are retained for three reasons:
- By your consent
- As part of a ‘contract’ (only while we communicate)
- For legitimate business interests – for good business practice I keep track of who has made contact before, the nature of your enquiry etc
When you make an online purchase as a single purchase, a membership or subscription
This is a contract for services. Your contact details are dealt with as above (consent, contract, legitimate reasons) – also these, your purchase history and the payment details (sent to me from Paypal ) are retained for six years beyond the end of the contract for legal reasons – accounting law.
When you work with me 1:1
With client work, dependent on the type of coaching and nature of our work together, you may wish (or need) to provide personal details of a sensitive nature.
When we start working together you will be asked to complete a client intake questionnaire which will be retained in printed or handwritten format and this form will include your contact and identity details, various questions in answer to which you provide background information and what you hope to achieve from being coached, and where appropriate, your signature.
The sensitive nature of such documents will generally be in relation to health or medical history but only insofar as it will be relevant to the coaching purposes. I do not collect any sensitive data about you such as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about criminal convictions and offences.
Session notes are scant memos handwritten by me for the purpose of fulfilling our contract and keeping track on the work during the session and from one week to the next, filed separately with only initials and date as identifiers so that no other person may connect these details alone to your personal identity.
In both cases I am required by law to retain these records for six years after the completion of our contract – or in the case of a minor, from six years beyond the date of their eighteenth birthday.
When payment for coaching services is made by bank transfer, I will not receive any details whatsoever of your bank account, so I do not hold financial information other than the date and amount of your payment. As regards payment by cheque, I personally keep the cheque until it is banked and no details are retained other than the fee paid and the date of your payment.
Other data sources:
Incoming data is also received from my website host. The information that you provide us through this website and through the application will be hosted on the servers of Vibeke Irene Foss, contracted to the company SiteGround Hosting Limited, a company registered in England and Wales (registration number 09348602), with registered address: 3rd Floor, 11-12 St James’ Square, London, SW1Y 4LB and is the data controller of the personal data that I collect from you via my website. The data processing by this company is regulated by a contract regarding the processing signed between the Provider and this company. Under no circumstances will this data processor outsource services that assume a data processing by third parties without my prior consent.
Use of information I may collect through automated systems when you visit my website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Personal identifiers from your browsing activity
Requests by your web browser to my servers for web pages and other content on my website are recorded.
Information is recorded such as your geographical location, your Internet service provider and your IP address. Also recorded is information about the software you are using to browse my website, such as the type of computer or device and the screen resolution.
When someone visits transitionslifecoaching.co.uk, a third party service, Google Analytics, collects standard internet log information and details of visitor behaviour patterns. This provides me with information such as the number of visitors to the various pages of my website, the length of time each page is visited and which search engine was used to find my site. This information is only processed in a way which does not identify anyone. There is no attempt to find out the identities of those visiting my website.
I may receive information from another coach or a therapist as part of a referral. In such a case you may be unaware that the consented data transfer has taken place, I will therefore inform you of receipt within 28 days.
Sharing your data
Your privacy is important and I do not sell your data nor share it except by your consent or under the law.
When working together, I may give out elements of your personal information to another coach or therapist as part of a referral. This will always only be with your personal consent.
In continuation of current UK law on confidentiality I also retain the right and in some cases the legal requirement to breach confidentiality to inform an authority such as the police or your GP of impending harm or illegality.
The GDPR sets out clearly what your rights are. It also lays out deadlines for a reply and other rules which are reproduced for your information at the bottom of this section.
Right to be informed
You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR.
I must provide you with information including: my purposes for processing your personal data, my retention periods for that personal data, and who it will be shared with. This ‘privacy information’ is provided above.
I must provide you with privacy information at the time I collect your personal data from you, in other words it has to be available to you before you fill in a form or hand over your data such as your email address.
If I obtain your personal data from other sources, e.g. by referral or from the payment service provider your selected, I must provide you with privacy information within a reasonable period of obtaining the data and no later than one month.
There are a few circumstances when I do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it.
The information I provide to people must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. Therefore if there is anything you do not understand, please get in touch.
Right of access
You have the right to access your personal data and supplementary information. This allows you to be aware of and verify the lawfulness of the processing.
You are entitled to confirmation that your data is being processed, access to your personal data, and
other supplementary information as provided in this privacy notice
Right to rectification
You have the right to have the data your personal data corrected if it is incorrect, or completed if it is incomplete.
Right to erasure
You may request, verbally or in writing, to have your data erased. This is also commonly known as ‘the right to be forgotten’. This right only takes effect when:
- Your personal data is no longer necessary for the purpose for which it was originally collected or processed,
- you withdraw your consent when the sole legal basis to hold this information is your consent,
- There is a legitimate interest in processing this data, which does not override your request
- processing/analysing of the personal data was for direct marketing purposes and this is the use you object to
- your personal data was processed unlawfully without a proper legal basis
- There is a legal obligation to comply with your request; or
- If the personal data was processed to offer information society services to a child.
Right to restrict processing
You have the right to request the restriction or suppression of your personal data. In other words you want to stop the data being used but keep it on file.
In this case your personal data cannot be used and can only be stored unless:
- you give your consent;
- it is for the establishment, exercise or defence of legal claims;
- it is for the protection of the rights of another person (natural or legal); or
- it is for reasons of important public interest.
Right to data portability
This allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Doing this is meant to enable you to take advantage of applications and services that can use this data to find you a better deal or help you understand your spending habits. In general this rule exists for data held by big service providers, such as your call history or insurance or gas bill history. The right also only applies to information you have provided.
If, as a private client you wish to carry a copy of your case notes or other sensitive data to another practitioner or other mental, physical or spiritual health service, these may be provided to you or to the nominated service provider, on request.
Right to object
Individuals have the right to object to:
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- direct marketing (including profiling); and
- processing for purposes of scientific/historical research and statistics.
Your objection must be made on grounds relating to your particular situation.
Once you object your data can no longer be processed, unless
- there are demonstrably compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- the processing is for the establishment, exercise or defence of legal claims.
You may complain directly to me using the contact details above.
If you find the outcome unsatisfactory and you are still dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. I would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
You may of course also exercise your right to legal action.
You can claim a right verbally or in writing.
A response should come without delay and at least within one month of receipt. The time limit is calculated from the day after you make the request (whether the day after is a working day or not) until the corresponding calendar date in the next month.
I aim to respond within 28 days.
When you request access to your data, a copy must be provided free of charge. However, you can be charged a ‘reasonable fee’ when a request is:
- manifestly unfounded or excessive, particularly if it is repetitive, unless that’s because I failed to respond; or
- for further copies of the same information (that’s previously been provided).
I may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on my website on the day you use my website or contact me when making an inquiry for coaching services. I advise you to print a copy for your records.