PRIVACY NOTICE (DATA PROTECTION COMPLIANCE)
Since the advent of the General Data Protection Regulation (GDPR) on 25 May 2018, there is a requirement to keep individuals informed about how the data on our servers is collected, stored, processed and generally protected. This Privacy Notice serves to inform our clients, contacts and contractors (“contacts”).
Who we are
We are Chrysalis Coaching & Development Ltd, a company limited by guarantee (company number 11065183). Our registered office is: Goodman House, 13a West Street, Reigate, Surrey RH2 9BL Email: firstname.lastname@example.org
What this privacy notice is for
This policy is intended to provide information about how Chrysalis Coaching & Development Ltd will use (or “process”) personal data about its contacts.
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Contacts are all encouraged to read this Privacy Notice and understand Chrysalis Coaching & Development Ltd’s obligations.
Anyone who works on behalf of Chrysalis Coaching & Development Ltd, such as employees and service providers, should also be aware of and comply with this Privacy Notice.
Given the nature of our work, you can be assured that we give protection of privacy and confidentiality the highest consideration.
Why Chrysalis Coaching & Development Ltd needs to process personal data
In order to carry out its business operations Chrysalis Coaching & Development Ltd needs to process a range of personal data about individuals as part of its daily operation.
Uses of personal data will be made in accordance with the company’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.
The company expects that the following uses will fall within that category of its “legitimate interests”:
- Administration of workshops, coaching programmes and sessions and other training vehicles (including administration of the finance surrounding these operations)
- Publication of regular updates, reminders and marketing materials
- General correspondence (by post, telephone or email)
Types of personal data processed by Chrysalis Coaching & Development Ltd
- Identity data which may include your first name, maiden name, last name, title, gender and date of birth. This may also include a photograph and film featuring your image.
- Contact data which may include addresses (postal and email) and telephone numbers
- Transaction data which may include details about payments between us and other details of bookings made by you or your employer and any notes collected during courses or coaching sessions pertinent to your development
- Technical data which may include IP addresses, browser type and version, browser location, operating system and platform and other technology on the devices you use to access our website
- Usage data which may include information about how you use our website, products and services
- Marketing and Communication data which may include your preferences in receiving marketing communications and your communication preferences.
How Chrysalis Coaching & Development Ltd collects data
The company receives personal data from the individual directly or from their employers. This may be in the form of data collected via our website, from your employer, or during the ordinary course of interaction or communication with you.
How your personal data is stored
- On our office computers. These are password-protected, backed up regularly, and the office(s) are locked out of working hours.
- On paper, in locked filing cabinets, and the offices are always locked out of working hours.
How we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us or between us and your employer
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
Who has access to personal data and who Chrysalis Coaching & Development Ltd shares it with
It is necessary to share your personal data with our team of facilitators and coaches, who may be contractors rather than employees of Chrysalis Coaching & Development Ltd. Our administration, finance and marketing functions may also be performed by contractors and we will also be required to share certain information with them for the completion of their roles. All of our contractors adhere to strict security standards.
Your personal coaching & development files, which may contain the details of any coaching & development sessions, will never be shared with anyone beyond your coach and/or their supervisor.
How we communicate our services to you
You will receive marketing communications from us if you have:
- requested information from us; or
- purchased services from us; and
- in each case, you have opted in to receiving marketing communications from us.
You can ask us to stop sending you marketing messages at any time by contacting us.
How long we keep personal data
Data pertaining to development training and coaching sessions is maintained by the company for a minimum of three years after the completion of your training sessions or coaching with us. Once consent has been granted by you, contact information for marketing purposes will be kept indefinitely.
Images and films
During our work we may photograph or film individuals; however this will always be with the express permission of those involved and is for the purpose of capturing and celebrating the work we do. We will never use images or footage of an individual in any of our marketing material or on our website without first having received written agreement to the usage of their image in this way.
Individuals have various rights under Data Protection Law to access and understand personal data about them held by the company and in some cases ask for it to be erased or amended, or for the company to stop processing it, but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or who has some other objection to how their personal data is used, should put their request in writing to the company either at the address above or by email to email@example.com.
From time to time we may arrange a meeting with you via a Webcam video calling package. The agreed package will not collect your personal information and sessions are not recorded unless express agreement is obtained from you. Video calls take place using Secure Socket Layer (SSL) encryption to ensure they remain confidential. You will be sent details about your session by email or via calendar invitation. If you want to keep these details private please use an email address that only you have access to.
The software may remain on your device once the session has finished, it may also leave cookies. However, these will not contain identifiable information about you or your meeting.
Like most websites, ours uses ‘cookies’, small packets of data that are stored in your web browser. Cookies help us to identify information such as how many people are using our site and what devices they’re using. We also use Google Analytics to analyse data and aggregate patterns of use. This allows us to tailor our service to best meet the needs of the people using it.
We rely on your consent to engage in certain types of electronic (email/telephone) activity. You may withdraw your consent to receiving such communications at any time by contacting the company.
Chrysalis Coaching & Development Ltd will update this Privacy Notice from time to time and an updated policy will be posted on our website. You should check for any changes to the policy at regular intervals. http://www.chrysaliscoaching.co.uk/privacy-notice/
QUERIES AND COMPLAINTS
Any comments or queries on this policy should be directed to the Data Controller:
Data Controller: Sandra Richardson
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office: www.ico.org.uk